Telemedicine and U.S. State Licensure

While some of our clients have leveraged telemedicine technology within a single state — for the purpose of rural outreach, facility oversight, and the like — many of our clients are interested in establishing cross-border, multi-state arrangements with rapid scalability and limitless growth opportunities. A fundamental first step in our telemedicine discussion with a client is state licensure.

State medical boards vary widely in the sophistication, development, or even existence of telemedicine licensure requirements. Although some states offer limited or special-purpose telemedicine licenses, others require a physician to obtain full state licensure. It is essential to understand the scope and application of each particular state’s licensure rules in order to remain compliant in a telemedicine arrangement. By understanding clients’ needs and the state medical board requirements, we have identified opportunities for our clients to implement their telemedicine models and, in some cases, avoid obtaining full licensure by, for example, securing a state consultation exception.