Telehealth Transformation

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Telehealth is at a turning point

New regulations and reimbursement practices have gained new traction and telehealth adoption rates have skyrocketed among patients and providers alike. Providers, payors, tech developers and patient advocates have an opportunity to launch, develop and implement telehealth solutions—but to do so successfully, they need intensive legal, business and government strategies counsel.

The time is now to move care delivery forward – from event-based care to ongoing, preventative medicine, that puts an empowered patient at the center of their own healthcare. We work with the industry’s leading providers, payors and technology innovators to:

  • Navigate the myriad licensure, patient consent and recordkeeping, data privacy, risk mitigation, corporate structuring, reimbursement, US Food and Drug Administration compliance and other regulatory issues that can make or break a telehealth initiative.
  • Knock down barriers for clients so they can efficiently execute their solutions across state lines and secure reimbursement with minimum administrative burden through best-in-class data analytics to forecast pricing and payment trends, medical claims audits, persuasive lobbying strategies, and telehealth-specific billing and coding systems.
  • Develop tools and collaborations that thrive in the complex world of healthcare and meet the needs of clinicians and patients alike, taking into account the unique challenges facing specific care settings, including assisted living, behavioral health and more.

How can we help you pursue telehealth transformation?

IDENTITY REQUIREMENTS FOR TELEHEALTH ENCOUNTERS – WHAT DOES YOUR STATE REQUIRE?

Verifying the identity of a patient prior to delivering telehealth services is important to prevent a range of potential risks, including the creation of fake accounts, insurance fraud and drug abuse/diversion. A growing number of states and health plans require the verification of a patient’s identity. This verification activity has become a standard practice in the telehealth industry and is expected to continue.

Hover over each state for our summary of each state’s requirements. For the complete requirements, click below to download the full report.


This does not constitute legal advice. All research contained herein should be verified prior to reliance thereon, and an attorney should be consulted to assess its applicability to any particular model of care. By accessing this site, you accept the terms of our privacy policy and you acknowledge your understanding that this tool is not a replacement for legal counsel. There is no guarantee that this research is up to date, as laws and regulations in this space continue to evolve.

LAST UPDATED DECEMBER 2022; note this report does not generally reflect waivers issued during the COVID-19 public health emergency, and this research does not reflect any requirements of health plans, including Medicaid programs, which may have their own requirements.

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Trending in Telehealth: A weekly series highlighting the state legislative and regulatory developments that impact the healthcare providers, telehealth and digital health companies, pharmacists, and technology companies that deliver and facilitate the delivery of virtual care.

#TelehealthTuesday by the Partnership to Advance Virtual Care (PVAC): An effort demonstrating the valuable role that telehealth has played during the pandemic, and the role that it can continue to play if current flexibilities are extended beyond the public health emergency. Each week, we’ll be releasing a new data visualization based on publicly-available Medicare data.
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Alabama

Prior to providing any telehealth medical service, the physician, to the extent possible, shall verify the identity of the patient. Ala. Code Ann. §34-24-703

For the complete requirements, click below to download the full report.

Alaska

Alaska does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

Arizona

Arizona does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

Arkansas

Arkansas does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

California

California does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

Colorado

To establish a provider-patient relationship, a provider must verify and authenticate the patient’s identity and location. Colorado Medical Board, Policy Statement Regarding the Provider/Patient Relationship, No. 40-3 (rev. Aug. 2015)

For the complete requirements, click below to download the full report.

Connecticut

Connecticut does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

Delaware

Except for certain instances, health-care providers may not deliver health-care services by telehealth and telemedicine in the absence of a health-care provider-patient relationship, which requires verification and authentication of the location and, to the extent possible, identity of the patient. Del. Code. Ann. § 6003.

For the complete requirements, click below to download the full report.

District of Columbia

District of Columbia does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

Florida

Florida does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

Georgia

Georgia does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

Hawaii

Hawaii does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

Idaho

Idaho does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

Illinois

Illinois does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

Indiana

A practitioner who uses telehealth shall, if such action would otherwise be required in the provision of the same health care services in a manner other than telehealth, ensure that a proper provider-patient relationship is established, which requires the provider to obtain the patient’s name and contact information, and to the extent reasonably possible, the identity of the requesting patient. Ind. Code Ann. § 25-1-9.5-7.

For the complete requirements, click below to download the full report.

Iowa

A licensee who uses telemedicine shall verify the identity of the patient and ensure that the patient has the ability to verify the identity, licensure status, certification, and credentials of all health care providers who provide telemedicine services prior to the provision of care. Iowa Admin. Code 653-13.11(147,148,272C)(13.11(6))

For the complete requirements, click below to download the full report.

Kansas

The Board stresses that each licensee using telemedicine must provide the licensee’s name, location and professional credentials to the patient, and must verify the identity and location of the patient. Kansas State Board of Healing Arts Policy # 21-02, Telemedicine (June 11, 2021).


For the complete requirements, click below to download the full report.

Kentucky

A physician is discouraged from rendering medical advice and/or care using telemedicine technologies without (1) fully verifying and authenticating the location and, to the extent possible, identifying the requesting patient…Kentucky Board of Medicine, Board Opinion Regarding the Use of Telemedicine Technologies in the Practice of Medicine (2014).

For the complete requirements, click below to download the full report.

Louisiana

Louisiana law requires that a physician who uses telemedicine establish a proper physician-patient relationship, which requires the provider to verify the identity of the patient; appropriate contact and identifying information shall be made part of the medical record. 46 La. Admin. Code Pt XLV, 7503.

For the complete requirements, click below to download the full report.

Maine

The technology and equipment utilized in the provision of telemedicine services must be able to verify the identity and location of the patient. Code Me. R. tit. 02-373 Ch. 11, § 3

For the complete requirements, click below to download the full report.

Maryland

A health care practitioner may establish a practitioner-patient relationship through either a synchronous telehealth interaction or an asynchronous telehealth interaction, if the health care practitioner verifies the identity of the patient receiving health care services through telehealth…Md. Code Ann., Health Occ. § 1-1002. Guidance by the Maryland Board of Physicians states that a patient may present photo identification, or a physician may use any other means to identify a patient that would normally be accepted for an in-person encounter. Md. Board of Physicians, FAQs for Telehealth (accessed Nov. 30, 2022).

For the complete requirements, click below to download the full report.

Massachusetts

Massachusetts does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

Michigan

Michigan does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

Minnesota

Minnesota does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

Mississippi

In order to practice any form of telemedicine, a valid “physician patient relationship” must be established, which involves verifying that the person requesting the medical treatment is in fact who they claim to be. 30 Code Miss. R. Pt. 2635, R. 5.4.

For the complete requirements, click below to download the full report.

Missouri

Missouri does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

Montana

The licensee using telemedicine in patient care shall verify the identity of the patient. Mont. Admin. R. 24.156.813

For the complete requirements, click below to download the full report.

Nebraska

Nebraska does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

Nevada

Nevada does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

New Hampshire

Creation of a physician-patient relationship requires the physician to verify the identity of the patient receiving health care services through telemedicine… New Hampshire Rev. Stat. § 329:1-c.

For the complete requirements, click below to download the full report.

New Jersey

Any health care provider who engages in telemedicine or telehealth shall ensure that a proper provider-patient relationship is established, which includes properly identifying the patient using, at a minimum, the patient’s name, date of birth, phone number, and address. When properly identifying the patient, the provider may additionally use the patient’s assigned identification number, social security number, photo, health insurance policy number, or other appropriate patient identifier associated directly with the patient. N.J. Rev. Stat. § 45:1-63(a).

For the complete requirements, click below to download the full report.

New Mexico

New Mexico does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

New York

New York does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

North Carolina

The licensee using telemedicine should verify the identity and location of the patient and should be prepared to inform the patient of the licensee’s name, location and professional credentials. North Carolina Medical Board, Position Statement: Telemedicine (Mar. 2019); see also North Carolina Medical Board, Position Statement: The Licensee-Patient Relationship (Jan. 2021).

For the complete requirements, click below to download the full report.

North Dakota

A licensee practicing telemedicine shall establish a bona fide relationship with the patient before the diagnosis or treatment of a patient, which requires verification of the identity of the patient seeking care. N.D. Cent. Code § 43-17-44(2)

For the complete requirements, click below to download the full report.

Ohio

A physician may prescribe, personally furnish, otherwise provide, or cause to be provided a prescription drug that is not a controlled substance to a person on whom the physician has never conducted a physical examination and who is at a location remote from the physician by complying with certain requirements, including establishing the patient’s identity and physical location. Ohio Admin. Code 4731-11-09(C).

For the complete requirements, click below to download the full report.

Oklahoma

Unless otherwise prohibited by law, a valid physician-patient relationship may be established by an allopathic or osteopathic physician with a patient located in this state through telemedicine, provided that the physician confirms with the patient the patient’s identity and physical location. Okla. Stat. Ann. tit. 59, § 478.1(A).

For the complete requirements, click below to download the full report.

Oregon

At each telemedicine encounter, the licensee should verify the location and identity of the patient… Or. Medical Board, Statement of Philosophy: Telemedicine (April 7, 2022)).

For the complete requirements, click below to download the full report.

Pennsylvania

Pennsylvania does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

Rhode Island

Rhode Island does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

South Carolina

A licensee who establishes a physician-patient relationship solely via telemedicine shall verify the identity and location of the patient and be prepared to inform the patient of the licensee’s name, location, and professional credentials; S.C. Code. Ann. § 40-47-37

For the complete requirements, click below to download the full report.

South Dakota

Any health care professional who utilizes telehealth shall ensure that a proper health provider-patient relationship is established and includes verifying and authenticating the location and, to the extent reasonable, identifying the requesting patient. S.D. Codified Laws § 34-52-3

For the complete requirements, click below to download the full report.

Tennessee

The patient encounter to establish or maintain the physician-patient relationship via telemedicine between the physician in a remote location and the patient may occur so long as a facilitator personally verifies the identity of the patient (if a facilitator is present); different rules apply if one is not present. Tenn. Comp. R. & Regs. 0880-02-.16.

For the complete requirements, click below to download the full report.

Texas

Texas does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

Utah

A provider offering telehealth services shall, prior to each patient encounter, verify the patient’s identity and originating site. Utah Admin. Code R156-1-603

For the complete requirements, click below to download the full report.

Vermont

It is unprofessional conduct to medical services to a person in response to any communication transmitted or received by computer or other electronic means when the licensee fails to take the following actions to establish and maintain a proper physician-patient relationship, which requires making a reasonable effort to verify that the person requesting medication is in fact the patient, and is in fact who the person claims to be. Vt. Stat. Ann. tit. 26, § 1354(a)(33)(a).

For the complete requirements, click below to download the full report.

Virginia

A practitioner is discouraged from rendering medical advice and/or care using telemedicine services without fully verifying and authenticating the location and, to the extent possible, confirming the identity of the requesting patient. Virginia Board of Medicine, Guidance Doc. No. 85-12, Telemedicine (Aug. 19, 2021) & Virginia Board of Nursing, Guidance Doc. No. 90-64, Telemedicine for Nurse Practitioners (Aug. 11, 2021).

For the complete requirements, click below to download the full report.

Washington

Washington does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

West Virginia

A physician using telemedicine technologies to practice medicine shall verify the identity and location of the patient. W. Va. Code Ann. § 30-3-13a.

For the complete requirements, click below to download the full report.

Wisconsin

Wisconsin does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.

Wyoming

Wyoming does not prescribe standards for identity verification for telehealth encounters as of the publication date of this report. To view requirements for all states that do require identity verification for telehealth encounters, download the full report.

For the complete requirements, click below to download the full report.