Telemedicine in Indiana: Law, Policies, Rules, and Regulations | Blog

Search for telemedicine rules in Indiana and most of what surfaces describes a statute the legislature replaced in 2021.

Those pages still say the state bars audio-only visits, still say Indiana sits outside the Interstate Medical Licensure Compact, still list four reimbursable CPT categories. Each of those statements was accurate once. None is accurate now.

The distance between old guidance and current rules is measured in denied claims. IHCP now rejects procedure codes T1007 and T1016 when they carry modifier 93, retroactive to January 1, 2025 — and claims already paid under those codes are subject to adjustment or recoupment. Nothing in a 2019 policy summary would have warned a billing manager about that.

Indiana's current framework opened more doors than it closed. Senate Enrolled Act 3 widened the practitioner list well past physicians.

Audio-only moved from prohibited to conditionally billable. Indiana joined the medical licensure compact in 2022, with the expedited pathway live since July 2023. Telehealth-only Medicaid enrollment now exists for practices with no physical location where patients are seen.

What tightened is the paperwork. Documentation has to identify both the practitioner's location and the patient's, and it has to survive postpayment review. Controlled substance prescribing demands live video and an INSPECT check. Prescription notification reaches outside your own chart to the patient's primary care provider.

This walks through what Indiana law requires today: which practitioners qualify, what counts as telehealth, how consent and records have to be captured, what may be prescribed remotely, how remote patient monitoring gets approved, and where Medicaid billing turns on a single modifier.

Telemedicine Definitions Under Indiana State Law

Indiana passed its parity law in 2015. Lawmakers rewrote much of it in 2021 under Senate Enrolled Act 3, and the change reached into the insurance code. The chapter still carries its original title, Coverage for Telemedicine Services. Its working sections now say telehealth.

That matters when we go looking for the rules. IC 27-8-34-5 and 27-13-1-34 define telehealth services as care delivered using technology allowed under IC 25-1-9.5-6. Three methods qualify:

• Secure videoconferencing

• Store and forward technology

• Remote patient monitoring

Covered work includes medical exams and consultations, along with behavioral health services such as substance abuse evaluations and treatment.

Email, instant messaging, fax, internet questionnaires, and internet consultations fall outside that definition — unless the practitioner already has an established relationship with the patient.

A new patient filling out a web form isn't receiving telemedicine in Indiana. The same form sent to an established patient can be.

Private payer coverage rests on four rules:

The payment parity gap catches practices off guard. Coverage is required. The amount paid isn't fixed, so a virtual visit and an office visit can reimburse differently under the same plan.

One more provision deserves attention from anyone shopping for a platform. When a policy covers telehealth delivered by secure videoconferencing, store and forward, or remote patient monitoring, it cannot require the use of a specific information technology application. A payer can tell us what it will cover. It can't tell us which software to run.

Expanding the Definition of Telemedicine

Indiana's Medical Licensing Board launched a telemedicine pilot program in June 2015, shortly after the parity law took effect. Legislators moved on the definition itself the following year.

In July 2016, Gov. Mike Pence signed a new bill into law — House Act No. 1263. It added a new chapter to the Indiana Code, replaced the earlier definition of telemedicine services, and set standards of care for practitioners across the state.

That chapter is IC 25-1-9.5, and it hasn't sat still. Senate Enrolled Act 3 rewrote much of it in 2021. Indiana's Family and Social Services Administration summarizes the shift in one line: "telehealth services" replaces "telemedicine."

Two anchors from the 2016 law survived the rewrite. A practitioner works from a distant site. The patient sits at an originating site, which IC 25-1-9.5-3 defines as any location the patient happens to be in when care is delivered. No qualifying facility, no minimum distance.

HIPAA compliance is written into the definition itself. A platform that can't meet that standard doesn't produce telemedicine in Indiana, whatever else it does well.

Three methods qualify without conditions. Five others depend on who the patient is:

Plenty of guidance still circulating says Indiana limits telehealth to live, two-way video. That stopped being accurate years ago. Store-and-forward and remote monitoring both sit inside the statutory definition, and Indiana Medicaid reimburses designated services delivered audio-only when billed with modifier 93.

The established relationship is the hinge worth remembering. Whether a patient's email counts as telehealth depends on whether we've treated that person before.

Who Can Practice Telemedicine in Indiana?

Indiana used to answer this question by elimination. Practices read the list of non-reimbursable services and worked backward. That changed once IC 25-1-9.5-3.5 spelled out which practitioner types may deliver telehealth, and the list runs well past physicians.

Authorized practitioners fall into these groups:

Being on that list settles one question and leaves another open. Chiropractic, optometric, podiatric, and physical therapy services all appear on the Medicaid non-reimbursed list at 405 IAC 5-38-4, even though those practitioners are authorized to practice telehealth.

A PT can hold a virtual visit lawfully and still get the claim denied. We check both lists before scheduling.

Anyone absent from the IC 25-1-9.5-3.5 list may not practice telehealth or bill for it, and supervision by a listed practitioner doesn't cure that. No workaround exists on that point.

Facility-level reimbursement runs on its own track. IC 12-15-5-11 requires Medicaid to pay federally qualified health centers, rural health clinics, community mental health centers, critical access hospitals, home health agencies licensed under IC 16-27-1, and any other provider the office determines eligible for a covered telehealth service.

The office may not impose distance restrictions or location requirements on either site. A patient across the street and a patient two hours away are treated the same.

Six service categories stay off the table:

• Surgical procedures

• Radiological services

• Laboratory services

• Anesthesia

• Durable and home medical equipment

• Transportation

When it comes to ESRD, the Indiana Health Coverage Program (IHCP) requires at least one monthly visit to be a traditional in-person encounter so the vascular access site can be examined.

One habit worth unlearning: coverage is not assumed. Reimbursement is limited to the procedure codes that appear in the telehealth and virtual services code set, which IHCP updates through bulletins. A service missing from that set isn't quietly covered. It's unbilled.

Practices built entirely around virtual care have a path of their own. Following HEA 1352 in 2023, IHCP opened a telehealth-only provider enrollment for organizations with no physical site where patients are seen.

Indiana Telemedicine Practice Standards

Indiana holds a virtual visit to the same standard as one in the exam room. IC 25-1-9.5-7(a) applies that rule to any practitioner delivering care through telehealth.

Meeting it takes more than good clinical judgment. The statute sets out how we establish a relationship with the patient, how consent gets captured, what we may prescribe, and what has to end up in the record.

Establishing a Valid Physician-Patient Relationship

Indiana lets a practitioner build a relationship with a patient they've never met face to face. No prior office visit is required, so telemedicine stays open to new patients and established ones alike.

A qualifier sits at the front of the rule. The relationship has to be established if establishing one would have been required for the same care delivered another way. Care that needs no formal relationship in the exam room needs none on video.

IC 25-1-9.5-7(b) sets eight minimum steps:

1. Obtain the patient's name and contact information, plus a verbal statement or other data showing the patient's location. Confirm the patient's identity as far as reasonably possible.
2. Disclose the practitioner's name and their licensure, certification, or registration.
3. Obtain informed consent.
4. Collect medical history and anything else needed to reach a diagnosis.
5. Discuss the diagnosis, the evidence behind it, and the risks and benefits of each treatment option, including when in-person care is the better choice.
6. Create and maintain a medical record.
7. Issue instructions for follow-up care.
8. Provide a visit summary naming any prescription written.

Step six carries a second duty that catches practices out. Writing a prescription triggers a notification to the patient's primary care provider, subject to the patient's consent, when the patient has supplied that provider's contact information.

Two situations switch the notification off:

• One is working inside an electronic health record the patient's primary care provider is authorized to access.

• The other is an ongoing relationship built by treating the patient at least two consecutive times through telehealth, though the statute still directs the practitioner to maintain the record and notify the primary care provider of prescriptions in that case.

Record quality isn't graded on a curve. Charts from a virtual visit have to meet the same standards as charts from an office visit.

Informed Patient Consent

Indiana doesn't make you collect a separate consent form for telehealth. IC 16-36-1-15 bars anyone from requiring a health care provider to obtain a separate additional written health care consent for the provision of telehealth services. Private payer coverage carries the same rule.

Consent itself is still mandatory. IC 25-1-9.5-7(b)(3) lists informed consent among the eight minimum elements of a valid provider-patient relationship. What the law relaxed is the form it takes, not the duty.

Medicaid adds a step ahead of consent. The member should always be given the choice between a traditional clinical encounter and a telehealth visit. Offer the choice first, then capture the answer.

Consent may be received verbally or by electronic signature, and it has to be documented as such. A spoken yes on a video call is valid, as long as someone records that it happened and how it was given.

Under audit, the documentation matters more than the consent. IHCP requires records that:

• substantiate the services provided and that consent was obtained
• indicate the services were rendered via telehealth
• clearly identify the location of the provider and the patient
• remain available for postpayment review

That third item catches practices out. Both locations have to appear, not just the patient's, and remote patient monitoring is held to the same standard even though the patient never leaves home.

Behavioral health runs stricter than the general rule. Clients must:

• Be offered in-person services before telehealth is chosen

• Indicate that telehealth is their preferred method

• Have documented acknowledgement of receipt of informed consent covering the risks and benefits of the modality

The modality is then formally reviewed with the client every 90 days.

Online Prescriptions

A prescriber in Indiana can write a prescription for a telehealth patient they have never examined in person. IC 25-1-9.5-8 sets five conditions on any prescription issued that way:

1. The prescriber has satisfied the applicable standard of care.
2. The prescription falls within the prescriber's scope of practice and certification.
3. It isn't for an opioid, apart from one exception.
4. It isn't for an abortion inducing drug, as defined in IC 16-18-2-1.6.
5. If it's for a medical device, the telehealth technology has to be good enough to support an informed diagnosis and a treatment plan that includes the device.

That opioid exception matters for addiction treatment. An opioid may be prescribed when the drug has been approved by the FDA for treating opioid addiction and is used to treat or manage opioid dependence.

IHCP describes the carve-out as covering partial agonists such as buprenorphine. If your practice runs medication-assisted treatment, that's the provision you're working under.

Eyeglasses and contact lenses aren't barred. Ophthalmic devices sit inside the medical device rule, and a prescription for one is also subject to the conditions in section 13 of the chapter.

Controlled substances carry six requirements on top of the five above:

The technology row rules out a phone call. Live video is required for a controlled substance, even for visit types where audio-only would otherwise be reimbursable.

Documentation runs through the relationship rules rather than the prescribing section. IC 25-1-9.5-7 requires collecting the patient's medical history and whatever else is needed to establish a diagnosis, then discussing that diagnosis, the evidence supporting it, and the risks and benefits of the treatment options.

Documenting Telemedicine Encounters

Indiana attaches two record-keeping duties to every virtual visit. IC 25-1-9.5-7(b)(6) requires creating and maintaining a medical record, held to the same standards as records for patients seen in person. Subsection (b)(8) requires giving the patient a telehealth visit summary that names any prescription written. 

Medicaid spells out what the file has to show. Documentation must substantiate the services provided and that consent was obtained, indicate the services were rendered via telehealth, clearly identify the location of the provider and the patient, and remain available for postpayment review.

One duty reaches outside your own chart. Writing a prescription triggers notice to the patient's primary care provider, subject to the patient's consent, when the patient supplied that provider's contact information.

That requirement falls away when the practitioner works inside an electronic health record the primary care provider is authorized to access.

Two problems sit underneath all of this. Protected health information (PHI) has to reach patients over a secure channel, and visit data has to land in your electronic health record without anyone retyping it.

Curogram helps you solve both of these challenges. Our telemedicine platform is fully HIPAA compliant and includes built-in safeguards for handling PHI.

Curogram connects with your EHR, so encounter data flows into the chart directly and visit summaries go out to patients securely. See integrations here.

Cross-State Licensing

Indiana joined the Interstate Medical Licensure Compact under Senate Enrolled Act 251 in 2022, and the Professional Licensing Agency announced the pathway live in July 2023. The rules sit at IC 25-22.5-16.

Physicians already licensed in a compact state can take an expedited route to an Indiana license instead of filing a full application. Indiana issued 963 compact licenses in the most recent year of commission data, placing it among the top five states.

Holding the license settles one question. Where a lawsuit lands is a separate one, and IC 25-1-9.5-9 answers it. A practitioner sitting outside Indiana is treated as providing health care services in Indiana the moment they establish a provider-patient relationship with someone in the state, or decide whether to write that person a prescription.

Doing either constitutes a voluntary waiver. The practitioner accepts the jurisdiction of Indiana courts and Indiana substantive and procedural law for any claim arising from that care. That waiver reaches the practitioner's employer and contractor too — worth knowing before your group staffs a virtual clinic with out-of-state clinicians.

Paperwork Comes First

PLA requires an out-of-state practitioner to file an individual certification along with their employer's or contractor's certification before establishing a provider-patient relationship or issuing a prescription for anyone located in Indiana. IHCP treats that filing as encouraged for in-state providers and required for out-of-state ones.

Medicaid removes two barriers that used to keep remote practices out. The program cannot require a telehealth-only provider to maintain a physical address in Indiana, and it cannot require a telehealth provider group to hold an in-state service address to enroll.

Out-of-state services normally need prior authorization, but telehealth is exempt when the provider carries the "Telemedicine" subtype on their enrollment.

Remote Patient Monitoring

Remote patient monitoring runs on rules of its own. IHCP defines RPM as scheduled monitoring of clinical data sent through equipment in the member's home, transmitted to the provider's location for a qualified practitioner to read and interpret.

Two separate routes lead to approval:

One counting rule trips up billing teams. An emergency room visit that ends in an inpatient admission counts as a single event, not two.

The home health route adds two duties:

• A licensed registered nurse has to read the transmitted health information, working from the physician's written order.

• The treating physician must certify the need for home health services and document a face-to-face encounter with the patient.

Initial service authorization runs six months unless policy indicates otherwise, with reauthorization available for select services.

Ongoing monitoring doesn't replace in-person care entirely. A member receiving ongoing telehealth services should be seen by a physician for a traditional clinical evaluation at least once a year, unless policy states otherwise, and the distant provider should coordinate with the patient's primary care physician.

Indiana Medicaid Program

Indiana Medicaid used to run telemedicine and telehealth as two separate terms, with telemedicine meaning video visits and telehealth meaning home monitoring. That split is gone.

IHCP now defines telehealth as healthcare delivered between a practitioner at a distant site and a patient at an originating site, using secure videoconferencing, store-and-forward, or remote patient monitoring — the same definition the statute carries at IC 25-1-9.5-6.

What replaced it is a different division, and it drives your billing:

Modifier choice comes down to how the visit happened. Modifier 95 marks a real-time audiovisual encounter; modifier 93 marks a real-time audio-only one, and it's valid only for designated services.

Store-and-forward occupies an odd middle ground. It appears in the definition of telehealth, yet Indiana Medicaid doesn't reimburse it separately. Practices can still use it to support a reimbursable service. It just won't generate its own line item.

Coverage isn't assumed. Reimbursement is limited to procedure codes that appear on the telehealth and virtual services code set, and the rendering NPI has to be enrolled under a specialty allowable for telehealth. A code missing from that set isn't quietly covered.

Rates hold steady across settings. Payment matches the current fee schedule amount for the procedure code billed, apart from services billed by an FQHC or RHC and RPM billed by a home health agency.

Eligible providers and covered service categories follow the same rules described earlier, since telehealth carries the same limitations and restrictions as the in-person version of the service.

Have a Successful Telemedicine Start in Indiana with Curogram

Indiana's rules make specific demands on a platform: live video for controlled substances, documentation identifying both the provider's and the patient's location, and visit summaries naming any prescription written.

Curogram is HIPAA compliant, with built-in safeguards, automatic data backup, and secure file sharing. You can set up a virtual clinic and start seeing patients in under 48 hours, without hiring an IT consultant or a healthcare attorney to check the build.

Our platform connects with your EHR, so encounter data lands in the chart without manual entry. It mirrors your in-person workflow, so staff follow a sequence they already know. Patients get an SMS with a link to join, then reply in that thread to ask a question or reschedule.

Automated intake forms go out days ahead, putting the history in hand before the visit opens.

Reminders send on their own. Across our clients, text confirmation rates run above 75% and no-show rates sit 53% below the industry average. Atlas Medical Center cut its no-show rate from 14.20% to 4.91% in three months, based on our internal data.

Telemedicine by State

Don’t see your state? We just haven’t written about it yet! Stay tuned on our blog or check out our article on telemedicine reimbursement by state.

Telemedicine by State in the US

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