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Telehealth has emerged as a cost-effective and extremely popular addition to in-person care for a wide range of patient needs. A early 2025 survey revealed that 54% of Americans used telehealth and 89% were satisfied with their experience and preferred it to in-person care due to its convenience. To help your healthcare organization achieve its goals and get the most out of your telehealth program, we've identified five critical components that will help you expand your program and navigate the latest telehealth rules and regulations.
1. Getting Telehealth Providers Ready to Work
Understanding Cross-State Licensing Requirements
In most cases, federal and state laws require providers delivering care to be licensed in the state from which they're delivering care (the "distant site") and the state where the patient is located (the "originating site"). For example, if a provider lives in Washington and conducts a telehealth visit with a patient in Florida, they must be licensed in both Washington and Florida.
Fortunately, a majority of states have licenses or telehealth-specific exceptions that allow an out-of-state provider to deliver services via telemedicine, called cross-state licensing. These licenses allow providers to offer care in a different state if certain conditions are met. Understanding and complying with telehealth licensing requirements for each state is crucial for expanding your practice reach while staying compliant.
Streamlined Licensing Solutions
The Interstate Medical Licensure Compact (IMLC) has revolutionized the licensing process, making it significantly simpler for physicians providing telehealth services to hold licenses in multiple states. This compact eliminates much of the administrative burden and reduces the time required to obtain multi-state licensure. For the latest list of participating states and answers to frequently asked questions, visit imlcc.org.
Another valuable tool that can accelerate the licensing process is the Uniform Application for Licensure, a web-based application that improves license portability by eliminating a provider's need to re-enter information when applying for licenses. The Uniform Application collects all information needed for credentials verification as well as board-specific requirements for participating states. For availability in your area, see the list of participating state medical boards.
Credentialing for Telehealth Services
To deliver telehealth services effectively, a provider must be credentialed for and have privileges at the facility they will be working for, regardless of their physical location. This essential step can be accomplished through a traditional in-house credentialing process or through the more efficient credentialing by proxy method.
Credentialing by proxy allows remote providers to be credentialed by a remote hospital rather than following the traditional credentialing process for a hospital where they will never practice in person. This approach significantly reduces administrative overhead while maintaining quality standards.
Rural Telehealth Considerations
Licensing and credentialing providers for rural health facilities follow the same process as for those in urban areas, but with additional opportunities for streamlining. Healthcare facilities in rural locations seeking to optimize their telehealth credentialing process can benefit significantly from credentialing by proxy, allowing community and critical access hospitals to rely on the credentialing process of distant telehealth sites.
Updated Medicare Telehealth Rules for 2025
In March 2025, legislators approved an extension of many of the Medicare telehealth provisions that were implemented during the COVID-19 public health emergency, including several game-changing updates:
- Rural Emergency Hospitals are now eligible originating sites for telehealth
- FQHCs and RHCs can serve as a distant site provider for non-behavioral/mental telehealth services through September 30, 2025
- FQHC and RHCs can permanently serve as a Medicare distant site provider for behavioral/mental telehealth services
- Geographic restrictions have been eliminated for originating sites for non-behavioral/mental telehealth services
- Medicare patients can receive telehealth services for behavioral/mental health in their home
- Behavioral/mental telehealth services can be delivered using audio-only communication platforms
For additional rural-specific credentialing guidelines, visit the NRHA telehealth hub.
2. Getting Reimbursed for Telehealth
Understanding Reimbursement Landscape
The most common question healthcare leaders ask is how to secure proper reimbursement for telehealth services. Reimbursement rates for telehealth services can vary significantly by payor and whether you're receiving payment from a private payor, Medicare, or a state Medicaid plan. Understanding this complex landscape is essential for maintaining financial viability while expanding telehealth services.
Payment parity laws, which are legislated at both the state (Medicaid) and federal (Medicare) levels, can dramatically affect reimbursement rates. The Centers for Medicare and Medicaid Services (CMS) has extended full telehealth payment parity for many provider services permanently, providing much-needed stability for healthcare organizations.
Understanding Pay Parity Laws
As of April 2025, 44 states, the District of Columbia, Puerto Rico, and the Virgin Islands have private payer laws in place that address telehealth reimbursement. There are two distinct types of pay parity that healthcare organizations must understand:
Payment Parity for Telehealth: This is the requirement that telehealth visits be reimbursed at the same payment rate or amount as if care had been delivered in person. This ensures financial sustainability for telehealth programs.
Telehealth Service or Coverage Parity: Also referred to as access parity, coverage or service parity requires the same services be covered for telehealth as they would be if delivered in person. However, coverage parity does not guarantee the same rate of payment, which can create financial challenges for providers.
Staying Current with Parity Laws
Telehealth parity laws as of April 21, 2025, continue to evolve rapidly. Pay parity laws are subject to frequent changes, making it essential for healthcare organizations to stay informed. For the most current status and detailed state-by-state telehealth parity law legislation, visit the Center for Connected Health Policy website regularly.
3. How to Bill for Telehealth
Overview of Billing Categories
Telehealth billing guidelines fall under three main categories that require different approaches: Medicare, Medicaid, and private payor. Each category has distinct requirements and processes that healthcare organizations must master to ensure proper reimbursement.
Medicare Telehealth Billing Guidelines
In 2020, CMS significantly broadened which telehealth services may be reimbursed for Medicare patients, creating new opportunities for healthcare providers. With this expansion of care, Medicare patients are now able to receive virtual treatment from a wide range of providers — from physicians to licensed clinical social workers — and for an extensive range of services.
CMS' most updated fee schedule for Medicare reimbursement went into effect January 1, 2025, which removed the temporary increase in payments that was in place for 2024. In practical terms, doctors and other healthcare providers will receive slightly reduced compensation for their services in 2025, a decrease of roughly 2.83%. This represents an average across all services, not a universal reduction.
Each state maintains ongoing legislation that regularly reevaluates telehealth reimbursement policies, both for private payor and CMS services. Healthcare organizations must stay informed about these changes to maintain compliance and optimize revenue.
Medicaid Billing for Telehealth Services
Medicaid coverage policies vary significantly from state to state, creating complexity for multi-state providers. In response to the public health emergency, many states moved to broaden the coverage for services delivered via Medicaid for telehealth services, though these policies continue to evolve.
As of Fall 2024, the Center for Connected Health Policy (CCHP) released its executive summary of state telehealth laws and Medicaid program policy. As of publication, several states have announced significant changes to their Medicaid reimbursement policy, requiring ongoing monitoring by healthcare organizations.
Billing Private Insurance for Telehealth
Each private insurer maintains its own distinct process for billing for telehealth services, but legislative support is growing. Currently, 44 states, the District of Columbia, Puerto Rico, and the Virgin Islands have legislation in place that requires private insurance providers to reimburse for telemedicine services. To find the most up-to-date regulations in your state, use specialized Policy Finder Tools available online.
4. Telehealth Technology
EHR-Integrated Solutions
Many healthcare facilities leverage the telehealth capability built directly into their electronic health record (EHR) system, which offers seamless integration and workflow efficiency. Popular EHR systems with robust telehealth capabilities include:
- Athena
- Epic
- Oracle
- Veradigm
Standalone Technology Solutions
Beyond EHR integration, healthcare facilities utilize various other technologies including live video conferencing, mobile health apps, "store and forward" electronic transmission, remote patient monitoring (RPM) systems, and comprehensive video and audio technologies. Leading technology solutions include:
- Amazon Chime
- Doxy.me
- GoTo Meeting
- Spruce Health Care Messenger
- Webex for Healthcare
- Zoom for Healthcare
HIPAA Compliance Requirements
All telehealth technology must be HIPAA compliant without exception. This requirement is non-negotiable and affects every aspect of technology selection and implementation.
Key Questions for Technology Implementation
Before implementing any telehealth technology provider, healthcare organizations should ask these critical questions:
- Is your technology fully HIPAA compliant?
- Can visits be scheduled efficiently through the platform?
- Does it require patients to download and install an app?
- Can patients complete necessary forms through the platform (e.g. consent to telehealth treatment form)?
- Can patients upload photos or attachments through the platform?
- How does it integrate seamlessly into my existing EHR system?
For additional comprehensive tips on telehealth technology implementation, see the Health Resources and Services Administration's guide: Getting started with telehealth.
5. Locum Tenens and Telehealth
Growing Interest in Telehealth Locums
A comprehensive 2024 CHG Healthcare survey revealed that 59% of physicians surveyed are either very interested or highly interested in telehealth locum tenens work, demonstrating significant market demand. Notably, only 6% expressed no interest in doing telehealth as a locum physician, indicating widespread acceptance of this care delivery model.
Licensing and Credentialing for Telehealth Locums
Just like the locum tenens providers you bring on-site to your facility, locums providers performing care via telehealth still need to be fully licensed and credentialed, both in the locum physician's state of residence and the originating site (patient's state of residence). This dual-licensing requirement ensures patient safety and regulatory compliance.
Agency Support for Telehealth Programs
Leading locum tenens agencies provide comprehensive malpractice coverage for telehealth locum providers, with the important contingency that healthcare facilities have adequate processes and technology in place to protect them. Many agencies will also assist significantly in physician licensing and credentialing processes. However, healthcare facilities typically need to provide the necessary technology equipment, as most agencies do not include this in their service offerings.
Comprehensive Telehealth Staffing Solutions
Modern healthcare staffing agencies like CHG Healthcare offer extensive support for telehealth programs, including:
- Staffing capability for over 125 physician specialties for both hybrid and telehealth environments
- Ability to establish an entire staffing pool or supplement an existing physician group
- Providers thoroughly screened to meet specific requirements and credentialed by certified CVOs
- Ability to provide staffing in all 50 states and multiple international locations
- Flexible coverage options including nights, weekends, holidays, and 24x7x365 availability
Conclusion
The telehealth landscape continues to evolve rapidly, presenting both tremendous opportunities and complex challenges for healthcare organizations. Success in telehealth implementation requires careful attention to licensing and credentialing requirements, a thorough understanding of reimbursement structures, strategic technology selection, and proper billing procedures.
Healthcare leaders who master these five critical components—provider readiness, reimbursement optimization, billing compliance, technology integration, and strategic staffing—will be well-positioned to deliver high-quality patient care while maintaining financial sustainability. The key to long-term success lies in staying current with regulatory changes, maintaining flexibility in approach, and continuously optimizing processes based on patient feedback and operational data.
As telehealth continues to mature as a standard care delivery method, organizations that invest in building robust, compliant, and patient-centered telehealth programs today will have significant competitive advantages in the healthcare marketplace of tomorrow. The substantial patient satisfaction rates and growing acceptance among healthcare providers indicate that telehealth is not just a temporary solution, but a permanent and valuable addition to comprehensive healthcare delivery.