Illinois State Telehealth Laws and Reimbursement Policies

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Information Provided ByCenter for Connected Health Policy

© Public Health Institute/ Center for
Connected Health Policy 2019: http://cchpca.org

Illinois Medicaid

Illinois
Medicaid Program: Illinois Medicaid

Program Administrator: Illinois Dept. of Healthcare and Family Services

Regional Telehealth Resource Center:

Upper Midwest Telehealth Resource Center
2901 Ohio Boulevard, Ste. 110

Terre Haute, IN 47803
(855) 283-3734 ext. 232
www.umtrc.org

STATE LAW/REGULATIONS MEDICAID PROGRAM

Definition of telemedicine/telehealth

“Telehealth” means the evaluation, diagnosis, or interpretation of electronically transmitted patient-specific data between a remote location and a licensed health care professional that generates interaction or treatment recommendations. “Telehealth” includes telemedicine and the delivery of health care services provided by way of an interactive telecommunications system, as defined in subsection (a) of Section 356z.22 of the Illinois Insurance 20 Code.

Telemedicine means the performance of any of the activities listed in Section 49, including, but not limited to, rendering written or oral opinions concerning diagnosis or treatment of a patient in Illinois by a person in a different location than the patient as a result of transmission of individual patient data by telephonic, electronic, or other means of communication. “Telemedicine” does not include the following:

(1) periodic consultations between a person licensed under this Act and a person outside the State of Illinois;

(2) a second opinion provided to a person licensed under this Act; and
(3) diagnosis or treatment services provided to a patient in Illinois following care or treatment originally provided to the patient in the state in which the provider is licensed to practice medicine; and

(4) health care services provided to an existing patient while the person licensed under this Act or patient is traveling.

Source: IL SB 1811 (2017).

The Medical Practice Act of 1987 defines ‘telemedicine’ as “the performance of diagnosing patients, prescribing drugs, maintaining a medical office, etc., including but not limited to rendering written or oral opinions concerning diagnosis or treatment of a patient in Illinois by a person located outside the State of Illinois as a

“Telemedicine” is the use of a telecommunication system to provide medical services for the purpose of evaluation and treatment when the patient is at one medical provider location and the rendering provider is at another location.

Source: IL Admin. Code, Title 89,140.403 (2012).

“Telehealth is defined as the use of a telecommunication system to provide medical services between places of lesser and greater medical capability and/or expertise, for the purpose of evaluation and treatment. Medical data exchanged can take the form of multiple formats: text, graphics, still images, audio and video. The information or data exchanged can occur in real time (synchronous) through interactive video or multimedia collaborative environments or in near real time (asynchronous) through “store and forward” applications.”

Source: IL Dept. of Healthcare and Family Svcs., Expansion of Telehealth Services, Informational Notice, Jan. 1, 2010. (Accessed Oct. 2017).

Source: IL Dept. of Healthcare and Family Svcs., Handbook for Practitioners. Ch. A-200 Policy and Procedures, p. 37, Handbook for Podiatrists, F-200, p. 27 (Oct. 2016) & Handbook for Encounter Clinic Services, pg. 17-18 (Aug. 2016). (Accessed Oct. 2017).

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STATE LAW/REGULATIONS MEDICAID PROGRAM

result of transmission of individual patient data by

telephonic, electronic, or other means of communication
from within this State.”

Source: IL Compiled Statutes, Chapter 225, 60/49.5 (2012).

The Administrative Code for the Department of

Healthcare and Family Services defines ‘telemedicine’
as “the use of a telecommunication system to provide
medical services for the purpose of evaluation and
treatment when the patient is at one medical provider
location and the rendering provider is at another
location.”

Source: IL Admin. Code, Title 89,140.403 (2012).

Under the Department of Public Health, telemedicine

means the provision of clinical services to patients by
physicians and practitioners from a distance via
electronic communications.

Source: IL Admin. Code, Title 77, Sec. 250.310

Live Video Reimbursement

Occupational therapy may be provided by telehealth as Illinois Medicaid will reimburse for live video under the
long as the standard of care is the same as in person following conditions:
care. A physician or other licensed health care

Source: IL Statute, 225 ILCS 75/2 . (Sunsets on Jan. 1, 2024). professional must be present with the patient at all
times with the patient at the originating site;
IL Medicaid shall not require that a physician or other The distant site provider must be a physician,
licensed health care professional be physically present physician assistant, podiatrist or advanced practice
in the same room as the patient for the entire time nurse who is licensed by Illinois or the state where
during which the patient is receiving telepsychiatry the patient is located;
services. The originating and distant site provider must not
be terminated, suspended or barred from the
Source: IL Code 305, Sec. 5-5.25. Department’s medical programs;
Medical data may be exchanged through a
(see Medicaid column) telecommunication system;
The interactive telecommunication system must, at
a minimum, have the capability of allowing the
consulting distant site provider to examine the
patient sufficiently to allow proper diagnosis of the
involved body system. The system must also be
capable of transmitting clearly audible heart tones
and lung sounds, as well as clear video images of
the patient and any diagnostic tools, such as
radiographs.
An encounter clinic serving as the distant site shall be
reimbursed as follows:
1. If the originating site is another encounter clinic,
the distant site encounter clinic shall receive no
reimbursement from the Department. The
originating site encounter clinic is responsible for
reimbursement to the distant site encounter clinic;
and

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STATE LAW/REGULATIONS MEDICAID PROGRAM

2. If the originating site is not an encounter clinic, the
distant site encounter clinic shall be reimbursed for
its medical encounter. The originating site
provider will receive a facility fee.
Source: IL Admin. Code Title 89, 140.403.
Eligible originating site providers include:
Physicians;
Podiatrists;
Local health departments;
Community mental health centers;
Outpatient hospitals;
Encounter Rate Clinics
Federally Qualified Health Centers (FQHC);
Rural Health Clinics (RHC)
Eligible distant site providers include:
Physicians;
PA;
Podiatrists;
Advanced practice nurses;
Encounter Rate Clinics
Federally Qualified Health Centers (FQHC);
Rural Health Clinics;
Source: IL Dept. of Healthcare and Family Svcs., Expansion of
Telehealth Services, Informational Notice, Jan. 1, 2010.
(Accessed Oct. 2017).
Source: IL Dept. of Healthcare and Family Svcs., Handbook for
Practitioners. Ch. A-200 Policy and Procedures, p. 38, Handbook
for Podiatrists, F-200, p. 27 (Oct. 2016). (Accessed Oct. 2017).
Distant Site providers may not seek reimbursement for
their services when the Originating Site is an encounter
clinic. The Originating Site encounter clinic is
responsible for reimbursement to the Distant Site
provider.
Non-enrolled providers rendering services as a Distant
Site provider shall not be eligible for reimbursement from
the department, but may be reimbursed by the
Originating Site provider.
Under the department’s telehealth policy, providers will
be paid as either an Originating Site or Distant Site.
Source: IL Dept. of Healthcare and Family Svcs., Expansion of
Telehealth Services, Informational Notice, Jan. 1, 2010.
(Accessed Oct. 2017).
Source: IL Dept. of Healthcare and Family Svcs. Handbook for
Practitioners. Ch. A-200 Policy and Procedures, p. 38, Handbook
for Podiatrists, F-200, p. 27 (Oct. 2016) & Handbook for
Encounter Clinic Services, pg. 17-18 (Aug. 2016). (Accessed Oct.
2017).
Psychiatric Services

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STATE LAW/REGULATIONS MEDICAID PROGRAM

With the exception of group psychotherapy, tele-psychiatry
is covered, if all of the conditions stated above are met.
Tele-psychiatry eligible originating site providers:
Physician;
Other licensed healthcare professional or other
licensed clinician;
Mental health professional;
Qualified mental health professional
Source: IL Dept. of Healthcare and Family Svcs., Expansion of
Telehealth Services, Informational Notice, Jan. 1, 2010.
(Accessed Oct. 2017).
Source: IL Dept. of Healthcare and Family Svcs., Handbook for
Practitioners. Ch. A-200 Policy and Procedures, p. 38, Handbook
for Podiatrists, F-200, p. 27 (Oct. 2016) & Handbook for Encounter
Clinic Services pg. 17-18 (Aug. 2016). (Accessed Oct. 2017).

Store and Forward Reimbursement

(see Medicaid column) Illinois Medicaid will reimburse a provider at a distant site

when they “review the medical case without the patient
being present.”
Source: IL Administrative Code, Title 89 ,140.403 (2012).
The Illinois Medicaid definition encompasses store and
forward. “The information or data exchanged can occur
in real time (synchronous) through interactive video or
multimedia collaborative environments or in near real
time (asynchronous) through “store and forward”
applications.”
Source: IL Dept. of Healthcare and Family Svcs., Expansion of
Telehealth Services, Informational Notice, Jan. 1, 2010.
(Accessed Oct. 2017).
Source: IL Dept. of Healthcare and Family Svcs., Handbook for
Practitioners. Ch. A-200 Policy and Procedures, p. 38, Handbook
for Podiatrists, F-200, p. 27 (Oct. 2016) & Handbook for Encounter
Clinic Services pg. 17-18 (Aug. 2016) (Accessed Oct. 2017).

Remote Patient Monitoring Reimbursement

No reference found. IL Medicaid will cover home uterine monitoring with prior
approval and when patient meets specific criteria.
Source: IL Dept. of Healthcare and Family Services, Handbook for
Durable Medical Equipment, Chapter M-200, Policy and
Procedures for Medical Equipment and Supplies, p. 56 (Sept.
2015). (Accessed Oct. 2017).

Email/Phone/FAX

(see Medicaid column) No reimbursement for email.
No reimbursement for telephone.
No reimbursement for FAX.
Source: IL Dept. of Healthcare and Family Services, Handbook for
Practitioners Rendering Medical Services, Chapter A-200, Policy
and Procedures for Medical Services, p. 38, Handbook for

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STATE LAW/REGULATIONS MEDICAID PROGRAM

Podiatrists, F-200, p. 27 (Oct. 2016) & Source: IL Administrative
Code, Title 89 ,140.403 (2012). (Accessed Oct. 2017).

Online Prescribing

No reference found. No reference found.

Consent

No reference found. No reference found.

Location

Eligible originating site:
(see Medicaid column) Physician office;
Podiatrist office;
Local health departments;
Community mental health centers;
Outpatient hospitals;
Rural health clinics;
Encounter Rate Clinics
Federally Qualified Health Centers;
Source: IL Dept. of Healthcare and Family Svcs., Expansion of
Telehealth Services, Informational Notice, Jan. 1, 2010.
(Accessed Oct. 2017).

Cross-State Licensing

Illinois adopted legislation to join the Interstate Medical Licensure Compact.

Source: IL Public Act 099-0076 (2015).

Must have an IL medical license.

Source: IL SB 1811 (2017).

For medical services, the provider rendering the service at the distant site can be a physician, physician assistant, podiatrist or advanced practice nurse, who is licensed by the State of Illinois or by the state where the patient is located.

For psychiatric services, the provider rendering the service at the distant site must be a physician licensed by the State of Illinois, or by the state where the patient is located, who has completed an approved general psychiatry residency program or a child and adolescent psychiatry residency program.

Source: IL Handbook for Practitioners Rendering Medical Services, Chapter A-200, Policy and Procedures for Medical Services, p. 38, Handbook for Podiatrists, F-200, p. 27 (Oct. 2016)

& Handbook for Encounter Clinic Services pg. 17-18 (Aug. 2016). (Accessed Oct. 2017).

Private Payers

If an insurer provides coverage for telehealth services, No reference found.
then it shall not:
Require in-person contact occur between a
health care provider and a patient;
Require the health care provider to document a
barrier to an in-person consultation;
Require telehealth use when it is not
appropriate; or
Require the use of telehealth when the patient

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STATE LAW/REGULATIONS MEDICAID PROGRAM

chooses an in-person consultation

Source: SB 647 (2014) IL Insurance Code. Sec. 356z.22.

Site/Transmission Fee

No reference found. There is reimbursement for originating site facility fees.
Eligible facilities include:
Physician’s office;
Podiatrist’s office;
Local health departments;
Community mental health centers;
Outpatient hospitals;
Community Mental Health Providers
Originating site providers who receive reimbursement for
the patient’s room and board are not eligible for facility
fees.
Source: IL Handbook for Practitioners Rendering Medical
Services, Ch. A-200, Policy and Procedures for Medical Services,
p. 38 (Oct. 2016), Handbook for Podiatrists, F-200, p. 27 (Oct.
2016). (Accessed Oct. 2017).
Source (Community mental health providers): IL Dept. of
Healthcare and Family Svcs., Expansion of Telehealth Services,
Jan. 1, 2010. (Accessed Oct. 2017).

Miscellaneous

Comments:

Professional Board Telehealth-Specific Regulations

Medical Practice Act (Source: SB 1811 – 2017)

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