telehealth reimbursement, state lines, telehealth consultative model, international telehealth, second opinion service

Telehealth Reimbursement: Legally and Ethically Practicing Over State Lines Using a Consultative Model


January 14, 2019 | Reading Time: 2 Minutes

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The Telebehavioral Health Institute (TBHI) is honored to bring you the first of a series of video moments to advance your understanding of telebehavioral health, telemental health, and distance counseling. This first TBHI video training segment was recently recorded at one of TBHI’s two-day Certificate training workshops. The segment was taken from the workshop program’s section focused on insurance reimbursement. It answered a question about traditional telehealth models for obtaining telehealth reimbursement from Medicare, Medicaid, or third-party carriers across jurisdictions, that is, practicing over state lines.

Telehealth Reimbursement: Consultative Model

When using a consultative model in telehealth, the primary issue to keep in mind is that the consultative model does not include having direct contact with the client or patient. The consultation occurs between you and the client/patient’s treating professional. The moment there is direct contact, a therapeutic relationship is established as per the definition of practice in many states. Understanding the law in whichever state you are entering is essential in all circumstances. Avoiding all direct contact with the client/patient then, may be required. professional contact is with the client/patient’s treating practitioner or practitioners.

International Telehealth Practice

Given that several countries outside the United States now also have laws that require licensure in their countries, the same telehealth consultative model can apply to international practice as well. Working with a clinician who is located in another country can not only be legal but might actually be enjoyable for the specialist who does her homework to identify those foreign countries that might be in need of her specialty focus. Traveling to and from such regions can be a tax write off if the business is involved. Of course, checking with all involved licensing boards is strongly encouraged.

Telehealth Second Opinion Service as Part of International Telehealth Practice

A permeation of this telehealth consultative model is the “second opinion services” market, whereby specialists in one country can make themselves available to people from around the world to review records of patients with complex issues to solve problems. Let’s say a gambling expert resides in the United States, learns how to market his/her services internationally, and sells those services to a worldwide market at a flat rate. The service could be purchased directly from individual or families who may ask for their own records to be reviewed, or perhaps those of a family member. Fees are paid up front, the records are transferred, the consultative opinion is given in writing and the entire transaction is complete. All interaction is between the treating and consulting professional. There is no contact with the patient whatsoever.

Readers interested in participating in such a service is encouraged to take the TBHI Certificate Training level II and complete a FREE profile at

Thereafter, please send your Curriculum Vitae and a cover letter to TBHI here. TBHI is currently exploring opportunities in this area and is forming a pilot group of graduates with whom to conduct a feasibility study. Selected participants will be required to sign non-disclosure and non-compete agreements.

This first video tutorial is entitled, “Telehealth Consultative Model: How can telehealth professionals get reimbursed for consulting over state lines?”

Please leave your comments/questions below and feel free to share this page with your colleagues. Also, please let us know if there are any particular topics that you’d like to see us address in the remainder of the TBHI video training moments.

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Eduardo Guimbarda
Eduardo Guimbarda
4 years ago

Thank you for your assistance in providing me info on current reimbursement of tele-health services by payor

Marlene Maheu, Ph. D.
Marlene Maheu, Ph. D.
4 years ago

My pleasure!

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