Telehealth Provider Credentialing After COVID Waivers
Telehealth After COVID: What Changed
The COVID-19 public health emergency ended in May 2023, terminating most telehealth flexibility waivers. Providers who relied on waiver-era cross-state practice or simplified credentialing requirements now need full multi-state credentialing. Telehealth credentialing services.
Multi-State Credentialing Requirements
For telehealth, payer credentialing requirements are based on the patient's physical location during the visit — not the provider's location. This means: separate state medical license for each state where patients are located, separate payer credentialing with each state's plans, and separate state Medicaid enrollment for each state. ProEnrollment manages multi-state telehealth credentialing across all 50 states.
Current Medicare Telehealth Policies
Congress extended several Medicare telehealth flexibilities through 2026: geographic restrictions waived for most services, originating site requirement suspended for mental health, audio-only coverage maintained. However, providers must be enrolled in Medicare in the patient's state and licensed to practice there. See: Medicare enrollment | psychiatry credentialing.
What Survived the Waiver Era (Through 2026)
Congress extended the key Medicare telehealth provisions: geographic restrictions remain waived for most services, the patient's home counts as an originating site for behavioral health permanently, audio-only coverage continues for mental health, and FQHC/RHC telehealth billing continues. What ended: cross-state licensure flexibilities, relaxed enrollment requirements, and most state emergency provisions. The compliance baseline is back to pre-2020 rules — license and credentialing in every patient state.
Building a Compliant Multi-State Operation
The efficient sequence: licenses first, using compacts where eligible (IMLC for physicians — 40+ states, PSYPACT for psychologists, the Counseling Compact now live for LPCs, NLC for nurses); Medicare PECOS once (it's national); state Medicaid programs next, starting with slow states like New York; commercial payers in all states simultaneously. Critical CAQH detail: every state's practice location must appear in your profile before applications reference it. Budget 120–180 days for a multi-state build done in parallel — or sequential-DIY it in 12–18 months. Multi-state telehealth credentialing | 8-state case study | telepsychiatry credentialing.