Maryland Telemedicine Policy

Telemedicine in Maryland: Policies

With about 88% of general acute care hospitals already using telehealthteleradiology, remote monitoring, diagnostic and image review, Maryland has made giant strides since passing its telehealth laws in 2012.

Although new Maryland telemedicine regulations that went into effect in October 2014 limit the location of patient setting and the allowable types of providers, Maryland is moving forward with innovation and expansion in telemedicine

The MHCC views telehealth as an important strategy to improve access to care and reduce health care costs (click here for more information about MHCC strategic priorities). Over the last ten years, MHCC telehealth initiatives have included a range of activities that provide technical support to providers adopting telehealth, foster peer learning about best practices, assess the effectiveness of select use cases in various settings through demonstration projects, and build consumer awareness about telehealth. Click here for more information about MHCC telehealth initiatives. Click here for more information on initiatives implemented or expanded in response to the COVID-19 public health emergency (PHE).

Maryland Telemedicine & Telehealth Reimbursement Overview

Maryland Telemedicine is a mode of delivering health care services through the use of telecommunications
technology by a health care practitioner to a patient in a different physical location from a health care practitioner.
Telehealth may include both synchronous and asynchronous interactions. It does not include audio-only messages,
emails, or fax transmissions.

Telephonic communication, refers to audio-only interactions between a health care practitioner and a recipient.
During the state of emergency, BHA has allowed for providers who would normally be eligible for telehealth as well
as PRP providers to drop to using audio telephone for almost all clinical services, although audio telephone would
not normally be considered telehealth. This must be done with informed consent by the participant. (Specific
requirements are outlined in the Secretary of Health’s memorandum of March 21, 2020, which is on the COVID 19
section of the BHA website.) A general principle is that voice telephone may be used during the emergency only if
the participant is not able to access true telehealth services. The Department of Health and Human Services has
put out a memo concerning the relaxation of enforcement of certain HIPAA Security Rules for telehealth during the

Providers should bill using the same place of service code that would be appropriate for a non-telehealth claim. The
distant site should bill using the location of the doctor. If a distant site provider is rendering services at an off-site
office, the provider should bill using the Place of Service Code 11 for “Office.” Place of Service Code 02 (Telehealth)
is not recognized for Maryland Medicaid participants except for use on Medicare cross



Maryland Medicaid Telehealth Program

The Secretary of Health has temporarily expanded the definition of a telehealth originating site under COMAR to include a participant’s home or any other secure location as approved by the participant and the provider for purpose of delivery of Medicaid-covered services. The purpose of this expansion of regulatory authority is to ensure individuals can access certain health care services in their own home while mitigating possible risk for transmission of COVID-19. This expansion applies to services delivered to a Medicaid participant via fee-for-service or through a HealthChoice Managed Care Organization (“MCO”). This expansion will remain in place until further notice by the Department. Medicaid distant site providers delivering services via telehealth to a participant in their home must continue to comply with all other requirements of COMAR 10.09.49 and the Maryland Medicaid Telehealth Program Manual.

List of services payable under the Medicare Physician Fee Schedule when furnished via telehealth.

CMS-1751-F-List of Telehealth Services_Updated 1Nov2021_B

Telemedicine CPT Codes

Unique CPT codes do not exist specifically for telemedicine or telehealth. Instead a modifier is applied to existing codes.

  • For interactive audio and video sessions, place a GT modifier in front of the CPT codes you typically use for in person services.
  • For services provided via an asynchronous telecommunication system, simply add a GQ modifier in front of the CPT codes you typically use for in person services.

Telehealth Parity

There is a parity law requiring private payers and state employee health plans to reimburse as they would an in-person session.

See Insurance Code Statute 15-139


State Policy Overview

  • Medicaid
  • Private Payers
  • Parity