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Telemedicine Virginia: A Comprehensive Guide
💡 Telemedicine is legal and widely covered in Virginia, but three rules decide whether a visit is valid and paid.First, licensing follows the...
13 min read
Michael Hsu
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Updated on September 1, 2026
A Maryland practice still using its 2022 telehealth policy is following rules that no longer exist. That is not an exaggeration. Three of the biggest limits from that era are simply gone.
Back then, a phone call was not telehealth. A patient's home was not an approved place to get care. Payment parity was temporary, with an expiration date attached.
Practices built workflows around those limits. They trained staff on them. Then they moved on.
Every one of those rules has changed. Maryland now treats audio-only calls as billable telehealth. Patients can be at home, at work, or anywhere private they agree to. Parity is no longer a countdown clock, because lawmakers removed the sunset date in 2025.
Here is the part that costs money.
Most of these changes expanded what you can do and what you can bill. A practice running on old rules is not taking on risk so much as leaving revenue on the table. It is turning away visits the state would pay for at full rate.
The flip side is real too. Maryland tightened what it expects around consent, records, and technology. And on prescribing, state law and the Board of Physicians' rules are currently out of step. That gap is the kind of thing that causes trouble in an audit.
This guide covers where the law stands now. You will find the parity and reimbursement rules, who can deliver virtual care, what Medicaid pays for, and the telehealth regulations you need to meet before your next visit. It also flags the dates that will force another round of changes.
Where the law is genuinely unsettled, it says so. Read it with your own workflow in mind, because most of what follows is easier to fix than it looks.
Maryland moved early on this. Lawmakers passed Senate Bill 781 in 2012. It required insurers to cover care delivered by telemedicine, which was forward-thinking at the time.
By today's standards it was thin. SB 781 covered interactive audio and video used by a Maryland-licensed provider. It left out phone calls, email, and fax. It said nothing about who could practice or where the patient had to be.
It also gave insurers plenty of room. Plans could charge deductibles, copays, and coinsurance. They could also cap telemedicine benefits with an annual dollar maximum. Coverage was required, but equal payment was not.
Closing the gap between "covered" and "paid the same" took another nine years:
| Year | Law | What changed |
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| 2012 | SB 781 | Insurers must cover telemedicine. Audio-only, email, and fax excluded. |
| 2017 | Insurance Code update | Added the term "telehealth" alongside "telemedicine." Rules unchanged. |
| 2018–2019 | Board of Physicians revisions (COMAR 10.32.05) | Replaced "physician" with "telehealth practitioner." Added store-and-forward, remote patient monitoring, and interpretive services. |
| 2021 | HB 123 / SB 3 | Added audio-only coverage, removed location limits, required payment parity. Set to expire June 30, 2023. |
| 2023 | HB 1148 / SB 582 | Extended parity and audio-only coverage to June 30, 2025. Ordered a state study. |
| 2025 | HB 869 / SB 372 | Removed the expiration dates. Parity and audio-only coverage are now permanent. |
The 2025 law is the one that matters most for planning. It was signed on May 13, 2025 and took effect June 1, 2025. It struck the "July 1, 2021 to June 30, 2025" windows out of both the insurance statute and the Medicaid statute.
A string of temporary extensions became settled law. That changes the math on investment. Practices spent four years hesitant to build permanent telehealth workflows because the payment rules kept expiring. That reason is gone.
In 2017, Maryland updated its Code Insurance to include the term “telehealth” and define circumstances under which insurers must cover telehealth services.
The “update” did not introduce any new rules or regulations, and the wording is nearly identical to the SB 781, with the only notable difference being the use of the term “telehealth” instead of “telemedicine.”
Maryland uses telemedicine and telehealth interchangeably. The same rules and regulations apply to providing examination, diagnosis, and treatment through telemedicine and consultations through telehealth, under state law.
Although both providers and patients in Maryland have quickly embraced telemedicine, the fact remains that Maryland’s telemedicine law is incomprehensive. This prompted the Maryland Board of Physicians to hold a public hearing in 2018, in order to review proposed telehealth rules and comments submitted by the state’s telemedicine advocates, spearheaded by the Maryland Telehealth Alliance.
As a result, the Board replaced the term “physician” with “telehealth practitioner” and expanded telehealth modalities.
After the Board’s revision, telehealth in Maryland also includes:
Store-and-forward — The technology is defined as “asynchronous transmission of digital images, documents, and videos electronically through secure means.” Reimbursement for store-and-forward technology remains a bit vague, given that the law states that it “may be reimbursed depending on the State budget and the extent permitted by federal law.”
Remote patient monitoring — The Board defines remote patient monitoring as “the use of telehealth devices to collect medical and other forms of health data from patients” for the purpose of facilitating evaluation, recommendations, and treatment. The same reimbursement rules apply as with store-and-forward technology.
Interpretive service — These services are defined as “reading and analyzing images, tracings, or specimens through telehealth or giving interpretations based on visual, auditory, thermal, ultrasonic patterns or other patterns as may evolve with technology.”
Maryland law does not limit the eligibility of healthcare providers who can offer remote healthcare services to patients in the state.
Any healthcare professional licensed to practice medicine in Maryland can practice telemedicine and telehealth, provided they act within their scope of practice and deliver services that meet the standards of care applicable to an in-person setting.
Healthcare providers in Maryland can establish a valid doctor-patient relationship through telemedicine. The relationship must be established through interactive, live, two-way video communication.
Prior to engaging in telemedicine and telehealth, Maryland providers must obtain and document patient consent. The consent doesn’t have to be written.
Consent is required before the visit, and it has to land in the chart. Auditors look for this. It is also one of the easiest things to fix.
Maryland is practical about the format:
There is one exception. In an emergency that stops you from getting consent, you may go ahead. You then have to document why consent was not available.
For your team, this is a workflow fix. Capture consent during intake instead of at the top of the visit. Then it no longer depends on a busy clinician remembering to ask.
Until recently, Maryland law didn’t provide any legal guidelines regarding the issuance of prescriptions as a result of telemedicine or telehealth visits. We believe this was a huge oversight by Maryland’s legislators, which they somewhat remedied in January 2020 by updating the Standard Related to Telehealth.
The update forbids providers from issuing medication and treatment to patients based solely on an online questionnaire.
Given that telemedicine under Maryland law does not include phone and email consultations or facsimile transmission, it’s safe to assume that online prescriptions require examination and diagnosis performed through live, two-way video communication with the patient.
The Standard Related to Telehealth also states that telehealth practitioners may not prescribe opioids through telehealth. An exception to this rule is telehealth services provided to patients in healthcare facilities who have immediate access to in-person medical care.
Under Maryland state and federal law, providers must document all telemedicine encounters.
This can be quite tedious and time-consuming if you’re using a telemedicine solution that doesn’t integrate with your electronic health record. You would have to manually enter all the relevant medical data after each telemedicine or telehealth visit.
This way, your doctors and medical staff would be wasting valuable time on administrative tasks rather than spending that time treating patients.
When creating Curogram, we wanted to streamline telemedicine as much as possible. That’s why we’ve made sure that our platform integrates with any EHR. Curogram eliminates redundant administrative tasks, allowing you to admit more patients daily, ultimately helping you increase the revenue of your practice.
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Curogram EHR integrations |
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eClinicalWorks |
Athena |
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Epic |
Cerner |
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DrChrono |
NextGen |
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Practice Fusion |
CareCloud |
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Kareo |
OfficeAlly |
The State of Maryland has passed legislation to join the Interstate Medical Licensure Compact, allowing providers licensed in other states to provide telemedicine and telehealth services to patients in Maryland.
The state’s Medicaid program also allows healthcare professionals from adjoining states — Delaware, Pennsylvania, Virginia, and West Virginia — to provide remote medical care to Maryland Medicaid participants if they have an agreement with an eligible originating site in Maryland.
The Maryland Medicaid program issued a Telehealth Program Manual in 2015, implementing detailed guidelines for telehealth providers offering remote healthcare services to the program’s participants.
Maryland’s Medicaid employs a standard “hub-and-spoke” model. “Hub” refers to a distant site or, put simply, the location of the provider who is offering remote healthcare services. “Spoke” is the originating site, or rather the location of the patient receiving those services.
One thing to note regarding Maryland Medicaid’s view of telehealth is that the program also defines a “telepresenter” as a medical professional located at an originating site who facilitates telehealth communication and arranges the necessary equipment.
The inclusion of this definition means that a patient’s home is not an eligible originating site. A Medicaid participant receiving remote healthcare services must be located at one of the eligible medical facilities, where in-person medical care is immediately available to them.
Maryland Medicaid provides an exclusive list of originating sites eligible for reimbursement.
These sites include:
Maryland Medicaid also provides a list of eligible distant sites.
Providers enrolled in the state’s Medicaid program eligible for telehealth reimbursement include:
Prior to providing telehealth services to Maryland Medicaid program participants, providers must complete online registration. This applies to both originating and distant sites.
According to Medicaid’s Telehealth Program Manual, Maryland's Medicaid covers somatic and behavioral health services delivered through telehealth. All services rendered via telehealth are subject to the same program restrictions, preauthorizations, limitations, and coverage that applies to in-person medical care.
Somatic services — Before offering somatic services via telehealth, providers must contact the participant's HealthChoice MCO and inquire about authorization requirements for telehealth services.
Behavioral services — Providers must first contact Beacon Health Options with questions regarding prior authorization of telehealth services.
In order to comply with the standards of care applicable to in-person settings, Medicaid prescribes the minimum technical requirements every provider must meet before engaging in a telehealth encounter with the program’s participants.
Minimal technical requirements are:
Laws, policies, rules, and regulations regarding the practice of telemedicine and telehealth in Maryland come from various different sources — Senate Bills, the state's Medical Boards, and Maryland Medicaid.
Reading through half a dozen different Bills and manuals to see what policies apply to your practice can be quite consuming and frustrating, given the often vague wording of some policies.
That’s why we’ve compiled a list of ten tips that will help you get started with telemedicine and telehealth in the State of Maryland.
The revisions implemented by the Maryland Board of Physicians replaced the term “telemedicine” with “telehealth,” as well as the term “physician” with “telehealth practitioner.”
The revisions highlight that telehealth services might require face-to-face contact by a healthcare professional at an originating site when they are delivered to a Medicaid program participant.
Changing the term “physician” to “telehealth practitioner” helps expand the usage of telehealth services, by enabling non-physician medical professionals to render such services to patients in Maryland.
The rules set forth by the Board also include other modalities, such as store-and-forward technology, remote patient monitoring, and interpretive services, into telehealth practice, which are reimbursable under special conditions.
Maryland law states that healthcare professionals providing telehealth services will be held to the same standard of care applicable to in-person settings.
The law doesn’t explicitly state that you must refuse patients if you determine that treatment for their medical condition wouldn’t meet the standards when delivered via telehealth. In these cases, you should still advise the patients to seek in-person medical care. Otherwise, you may be subject to disciplinary measures by the state’s Medical Board.
There are several conditions that must be met before you can admit patients remotely in the State of Maryland.
The requirements for telehealth in Maryland include:
A telehealth provider must perform a detailed evaluation of the patient, sufficient for establishing a diagnosis, and identify underlying conditions and contraindications to recommended treatment options before prescribing any medications or providing treatment.
To do so, a telehealth practitioner may rely on physical examination provided by a telepresenter or other licensed healthcare practitioner, or on telehealth devices and live two-way, audio-video communication to perform an examination remotely.
Maryland law allows telehealth practitioners to prescribe medication as a result of a telehealth visit, provided that the medical professional performed an adequate examination of the patient.
This means that telehealth practitioners cannot prescribe medication as a result of a phone or email consultation, or based solely on an internet questionnaire.
There are a few limitations to this rule. Telehealth practitioners may not prescribe opioids through telehealth, except when opioids are used to treat opioid use disorder or the patient is in the presence of a licensed healthcare professional.

If you’re looking for a telehealth solution that would enable you to start offering remote healthcare services to patients in Maryland in compliance with the state’s laws, rules, and policies — Curogram is the perfect option.
Curogram is a fully HIPAA compliant telemedicine platform, designed specifically for healthcare professionals, that allows you to set up your virtual practice in less than 48 hours!
It comes with all the built-in safeguards and capabilities necessary to meet the established standards of care, meaning you won’t have to concern yourself with technical details or consult a medical lawyer.
We designed Curogram in a way that mimics your in-person workflows and made it easy to use for both patients and providers. You can manage your virtual clinic, share PHI, discuss work-related topics, and admit patients online from a single, web-based dashboard.
The patients will receive a link in an SMS that they can click to join your virtual waiting rooms and attend scheduled appointments.
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Here are a few reasons why you’ll love Curogram |
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Full EHR integration |
Curogram integrates with over 700 EHRs and automatically updates your electronic health record following each telehealth visit. Our platform eliminates redundant, manual administrative tasks, allowing you to dedicate more time to your patients. |
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A two-way messaging platform and automated appointment reminders |
Curogram assigns a local number to your practice, allowing you to send automated appointment reminders to your patients. They can respond to the text if they want to reschedule or inquire about your telehealth service, then simply click the link to join the online appointment. |
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Automated patient intake forms |
Curogram automatically sends electronic patient intake forms a few days ahead of the appointment. This means doctors don’t have to spend 15 minutes per appointment onboarding the patients, allowing them to admit more patients daily. |
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Easy and secure internal communication and file sharing |
Curogram includes a messaging platform your medical staff can use to discuss work-related topics and share PHI in a secure environment. |
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Replicates in-person workflows |
Curogram enables you to set up multiple virtual clinics, each with their own virtual waiting room. Our waiting room management tools facilitate patient check-in and check-out and replicate the in-person workflows your medical staff is used to. |
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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Alaska |
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Nevada |
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New Hampshire |
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Kentucky |
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Utah |
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Maine |
Vermont |
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Montana |
Rhode Island |
Maryland did something unusual. Instead of letting pandemic-era telehealth rules quietly expire, the state kept what worked and made it permanent.
Reimbursement parity is settled. Audio-only is covered. The patient's home counts as a valid place to get care.
That stability is an invitation to build properly rather than improvise. The practices that gain the most will treat telehealth as a normal service line with real workflows behind it. Not as a backup option for patients who cannot come in.
The compliance requirements are manageable, but they are specific. Consent has to be captured and recorded. Records have to match in-person standards. Sessions cannot be stored, and technology has to be HIPAA-compliant end to end.
Claims need the right modifier and the right place of service code. None of that is hard on its own. All of it is easy to lose track of when it depends on people remembering.
That is the case for putting it in the system instead of the training manual. Curogram is a HIPAA-compliant patient communication and telehealth platform built for medical practices. It integrates with most EMRs, so visit data reaches the chart instead of being retyped.
It also sends automated text reminders, which matters more than it sounds. SMS sees a 98% open rate. Curogram clients run no-show rates around 53% below the industry average. One client, Atlas Medical Center, cut its no-show rate from 14.20% to 4.91% in three months.
The rest of the workflow is covered too. That includes digital intake forms sent ahead of the visit, secure two-way texting, virtual waiting rooms that mirror your front desk, and text-to-pay for balances.
Maybe you are expanding telehealth in Maryland. Maybe you are fixing a program that grew faster than its processes. Either way, it is worth seeing how the pieces fit together. Schedule a Demo and we will walk through your workflow.
Frequently Asked Questions
Yes. The Preserve Telehealth Access Act of 2025 made audio-only phone visits a permanent part of Maryland's telehealth definition. The call has to result in a billable, covered service. This applies to Medicaid and private insurers alike, and reimbursement must match the in-person rate. A few programs are exceptions, including therapy services and teledentistry, which stay audio-video only.
Yes. Maryland Medicaid now treats the originating site as wherever the patient is. That includes their home or any secure location they agree to. Private insurers must also cover telehealth no matter where the patient is. The older rule requiring an approved facility and a telepresenter no longer applies to general telehealth.
No. Maryland does not issue a separate telehealth license or registration. A valid Maryland license lets you deliver telehealth to patients here, as long as telehealth fits your scope of practice. Maryland also takes part in several licensure compacts, which give out-of-state providers a faster route to practicing here.
The state ban on prescribing Schedule II opioids for pain by telehealth was repealed on June 1, 2025. Maryland now defers to federal and state controlled substance law. Federal DEA flexibilities currently allow Schedule II–V prescribing without a prior in-person exam through December 31, 2026. One caution: the Board of Physicians rule at COMAR 10.32.05.06 lagged behind the statute, so confirm its status with the Board or your counsel first.
Use the -GT modifier for two-way audio-video visits. Use the -UB modifier for audio-only phone visits. Bill the usual procedure code, and use the same place of service code you would use for an in-person claim. Place of service code 02 is not accepted for Medicaid-only claims and is reserved for Medicare crossover. These modifiers do not reduce your reimbursement rate.
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