| Key Takeaways |
- During Q1 and Q2 of 2024, there was a flurry of state legislative activity focused on making it easier for health care providers to obtain licensure in multiple states.
- Other notable activity: Louisiana now requires the state Medicaid agency to cover remote monitoring services for beneficiaries with chronic diseases; Michigan passed a wide-ranging bill that expands Medicaid telehealth coverage by enacting payment parity and audio-only coverage; New York extended its telehealth payment parity requirement for Medicaid and state regulated health plans to April 1, 2026; and Vermont permanently adopted payment parity for video visits (it was previously temporary) and newly implemented payment parity for audio-only visits.
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During the first half of 2024, nineteen states passed laws entering them into an array of different interstate compacts (see table below). Most notably, sixteen states passed legislation to join the Social Work Licensure Compact (SWLC) since the start of 2024.
It is important to note, however, that each of these compacts differ in terms of the licensure flexibilities. For example, the Interstate Medical Licensure Compact provides an expedited pathway for physician licensure in member states; it does not enable reciprocity for physicians to practice across member states. Physicians looking to practice across member states are still required to apply for and obtain licensure in order to practice in other member states. Other compacts, such as the Licensed Professional Counselors Compact (among others), enable true licensure reciprocity—professional counselors licensed and residing in a member state are able to practice in other compact member states without obtaining multiple licenses.
Additionally, some of these compacts are relatively new and not yet active. For example, the Audiology and Speech-Language Pathology Interstate Compact, which allows audiologists and speech-language pathologists licensed in one member state to obtain a privilege to practice in other Compact member states without obtaining licenses in those states. The Compact Commission, however, does not anticipate opening privilege applications for providers until late 2024 to early 2025.
Considerations for States and Policymakers
Compacts can be a useful tool to allow cross-state telehealth practice; however, relying on compacts alone is a somewhat fragmented approach to enabling cross-state telehealth, as each licensed profession must establish its own compact. Only some compacts enable true reciprocity, and many compacts are not yet active.
Alternatively, states may also consider establishing a special purpose telehealth registration or licensure pathway that would allow a wide range of professionals who are licensed and in good standing in other states to register or obtain a special license to deliver telehealth services to in-state residents. Several states have adopted this approach (Florida, New Jersey, Kansas, Louisiana, Minnesota, Nevada and New Mexico, among others) over the past few years, each with their own unique approach to design and implementation. For example:
- Minnesota offers a special telehealth registration that explicitly prohibits physicians from having an in-state physical address or providing in-person services in Minnesota.
- Florida offers an out-of-state registration for physicians and other health professionals licensed outside of Florida. Similar to Minnesota, registered providers are prohibited from having an in-state physical address or providing in-person services in the state and must maintain liability coverage for telehealth services provided to patients located in Florida.
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