Physical Examination Requirement
What counts as an exam from a distance?
Telehealth lets physicians examine and treat patients across locations and distances. But each state sets its own requirements — and federal Medicare and Medicaid rules apply on top — to keep the quality of remote care high.
The Basics
One requirement, many moving parts.
As remote technologies mature, physicians can perform more of the physical exam from afar. What actually satisfies the requirement depends on where the patient is located — and it keeps changing as legislation evolves.
What governs it
- State requirements — each state sets its own policies and specifications for its physicians.
- Federal rules — Medicare and Medicaid add their own requirements for telehealth exams.
- Always evolving — check back often to stay current on the latest legislative specifications.
The Components
The requirement, component by component
Store & Forward
The electronic transmission of medical information to a practitioner or specialist, who evaluates the case outside of a real-time interaction. It is less commonly reimbursed by Medicare and Medicaid, which generally require services to be delivered in real time.
Remote Patient Monitoring
The collection of health data — vital signs, weight, blood pressure — from the point of care, transmitted to health professionals in monitoring centers, hospitals, intensive care units, and skilled nursing facilities.
Consent Requirements
Most states include telehealth-specific informed-consent requirements in statute, administrative code, or Medicaid policy. Under Medicare the requirement is exclusive to communication technology-based service (CTBS) codes, where the patient must be made aware of any cost-sharing responsibility.
Out-of-State Providers
Providers can deliver services across state lines when licensed where the patient is located. Some Medicaid programs restrict out-of-state providers; others allow them if the provider is licensed and enrolls with the program.
Online Prescribing
The DEA, with HHS, extended telemedicine prescribing flexibilities for controlled substances without an in-person evaluation through December 31, 2026 — building on rules first established during the COVID-19 Public Health Emergency.
Licensure Compacts
Because telehealth is rendered where the patient is located, providers typically need a license in the patient's state. Interstate compacts let specific providers practice in member states while holding a license in good standing at home.
Licensure lawsIn Focus
Online prescribing & the DEA.
The DEA, in collaboration with HHS, issued a fourth extension of telemedicine prescribing flexibilities — letting providers continue prescribing controlled substances via telehealth without an in-person evaluation. The extension gives regulators time to finalize long-term policy while preserving access for rural, underserved, and mobility-limited patients.
Key facts
- Fourth extension — issued by the DEA and HHS on December 31, 2025.
- No in-person evaluation required to prescribe controlled substances via telehealth.
- In effect through December 31, 2026.
- Schedule II–V medications — including chronic pain, mental health, and opioid-use disorder.
- Builds on the COVID-19 PHE — the temporary rules first established during the public health emergency.
The exam requirement never sits still.
Keep every remote exam compliant.
CTeL members track the state and federal rules that decide what a telehealth exam must include.