Definition
Telehealth is a broad term encompassing the use of electronic information and telecommunications technologies to support and promote long-distance clinical healthcare, patient and professional health-related education, public health, and health administration — including but not limited to telemedicine (clinical services).
Comprehensive Definition
Telehealth is an umbrella term that encompasses a wide range of health services and activities delivered or supported through telecommunications technology. The Health Resources and Services Administration (HRSA) defines telehealth as "the use of electronic information and telecommunications technologies to support long-distance clinical health care, patient and professional health-related education, public health and health administration." This definition is intentionally broad and includes not only clinical care (telemedicine) but also non-clinical activities such as health education, administrative services, and public health surveillance.
The distinction between telehealth and telemedicine is important for regulatory and reimbursement purposes. Telemedicine refers specifically to the remote delivery of clinical medical services — diagnosis, treatment, and patient management — by licensed healthcare providers. Telehealth is the broader category that includes telemedicine plus non-clinical services. For example, a patient using a mobile app to track their blood pressure and receive educational content about hypertension management is engaging in telehealth but not telemedicine. A physician conducting a video visit to diagnose and treat a patient is practicing telemedicine (a subset of telehealth).
The clinical components of telehealth include synchronous telemedicine (real-time audio/video visits), asynchronous telemedicine (store-and-forward consultations), remote patient monitoring (RPM), remote therapeutic monitoring (RTM), and chronic care management (CCM) programs. The non-clinical components include health education and wellness programs, administrative telehealth (e.g., virtual care coordination, remote scheduling), and public health telehealth (e.g., disease surveillance, population health management).
Federal definitions of telehealth vary by agency and program. CMS uses the term "telehealth services" to refer to Medicare-covered telemedicine services under Section 1834(m) of the Social Security Act. HRSA uses the broader HRSA definition for its telehealth grant programs. The FCC uses "telehealth" broadly in the context of its Connected Care Pilot Program and E-Rate program. Operators must understand which federal definition applies to their specific program or reimbursement context.
The COVID-19 public health emergency (PHE) declared in March 2020 triggered an unprecedented expansion of telehealth coverage and regulatory flexibility. CMS waived originating site requirements for Medicare telehealth, allowed audio-only visits, expanded the list of covered telehealth services, and permitted prescribing of controlled substances via telemedicine without a prior in-person evaluation. Many of these flexibilities have been extended through legislation, but the regulatory landscape continues to evolve as Congress and CMS work to establish a permanent post-PHE telehealth framework.
Why It Matters
Telehealth represents one of the most significant structural shifts in healthcare delivery of the past two decades. For patients, telehealth removes geographic, transportation, and time barriers to care — enabling access to primary care, specialty care, behavioral health, and chronic disease management services regardless of where the patient lives. For providers and healthcare entrepreneurs, telehealth enables practice expansion, new revenue streams, and more efficient care delivery models.
For healthcare operators, understanding the distinction between telehealth and telemedicine is essential for navigating the regulatory and reimbursement landscape. Medicare and Medicaid reimbursement rules, state licensure requirements, and prescribing regulations apply specifically to clinical telemedicine services — not to all telehealth activities. Building a telehealth-enabled practice requires a clear understanding of which activities are clinical (and therefore subject to licensure, prescribing, and billing rules) and which are non-clinical (and therefore subject to different regulatory frameworks).
The post-PHE telehealth landscape is still being defined. Congress has extended many COVID-19 telehealth flexibilities through legislation, and CMS has proposed permanent expansions of Medicare telehealth coverage. Operators who build telehealth practices today must build compliance infrastructure that can adapt to ongoing regulatory changes — including potential changes to audio-only coverage, originating site requirements, and controlled substance prescribing rules.
Historical Background
The term "telehealth" emerged in the 1990s as a broader alternative to "telemedicine," reflecting the expanding scope of health services that could be delivered via telecommunications technology. The HRSA Office for the Advancement of Telehealth (OAT), established in 1997, has been a primary driver of federal telehealth policy and grant funding. The Telehealth Services Improvement Act of 2004 and subsequent legislation expanded Medicare telehealth coverage incrementally over the following decade.
The passage of the 21st Century Cures Act in 2016 included provisions to expand Medicare telehealth coverage and reduce regulatory barriers. The Bipartisan Budget Act of 2018 further expanded Medicare telehealth for certain chronic conditions. The COVID-19 PHE, declared in March 2020, triggered the most dramatic expansion of telehealth in history — CMS issued dozens of waivers and flexibilities that transformed telehealth from a niche service to a mainstream care delivery modality virtually overnight.
Federal Regulations
HRSA defines telehealth at 42 U.S.C. § 254c-14 and administers telehealth grant programs through the Office for the Advancement of Telehealth. Medicare telehealth coverage is governed by Section 1834(m) of the Social Security Act and implementing regulations at 42 CFR § 410.78. The Consolidated Appropriations Act, 2023 extended many COVID-19 Medicare telehealth flexibilities through December 31, 2024.
The FCC administers the Connected Care Pilot Program and the Healthcare Connect Fund, which provide funding for telehealth infrastructure. The FCC's E-Rate program supports broadband connectivity for schools and libraries, which indirectly supports telehealth access. The FTC Act and state consumer protection laws apply to telehealth marketing and advertising.
HIPAA applies to all telehealth providers that are covered entities, requiring HIPAA-compliant platforms, Business Associate Agreements with technology vendors, and appropriate privacy and security safeguards. The ONC's information blocking rules (45 CFR Part 171) apply to telehealth providers that are healthcare providers under the ONC definition.
State Considerations
State telehealth laws and regulations vary significantly. Most states have enacted telehealth-specific statutes or regulations that govern the establishment of a provider-patient relationship via telehealth, prescribing standards, and documentation requirements. State medical boards, nursing boards, and other licensing authorities set the standards for telehealth practice within their respective scopes.
State insurance coverage mandates for telehealth are among the most variable aspects of the telehealth regulatory landscape. As of 2025, the majority of states have enacted telehealth coverage parity laws, but the scope of these mandates varies widely — some require parity only for synchronous video visits, while others include asynchronous, audio-only, and RPM services. Operators must review the telehealth coverage mandates in each state where they operate.
State Medicaid programs set their own telehealth coverage rules subject to CMS approval. Medicaid telehealth coverage has expanded significantly since the COVID-19 PHE, but coverage rules vary by state and service type. Operators billing Medicaid for telehealth services must verify coverage rules with each state Medicaid program.
Common Mistakes
- Conflating telehealth and telemedicine — using the terms interchangeably when the distinction matters for regulatory compliance, billing, and licensure purposes.
- Assuming that all telehealth activities require a medical license — non-clinical telehealth activities (health education, wellness coaching, administrative services) may not require clinical licensure but are subject to other regulatory requirements.
- Failing to monitor post-PHE regulatory changes — many COVID-19 telehealth flexibilities have expiration dates or are subject to ongoing rulemaking, and operators must stay current.
- Not verifying state-specific telehealth coverage mandates before billing commercial insurers for telehealth services — coverage rules vary significantly by state and insurer.
- Building telehealth infrastructure on consumer-grade technology without HIPAA-compliant configurations and Business Associate Agreements.
- Overlooking the FCC's Connected Care Pilot Program and other federal funding opportunities that can offset the cost of telehealth infrastructure.
Operator Insight
I work with a lot of healthcare entrepreneurs who come to me wanting to "launch a telehealth practice" without a clear understanding of what that means from a regulatory and operational standpoint. The first question I always ask is: what services are you delivering, and to whom? The answer determines everything — which licenses you need, which billing codes apply, which prescribing rules govern your practice, and which technology platforms are appropriate. The telehealth landscape post-COVID is genuinely exciting for healthcare entrepreneurs. The expansion of Medicare and Medicaid telehealth coverage, the growth of direct-to-consumer telehealth, and the increasing acceptance of virtual care by patients and payers have created real opportunities for building scalable healthcare businesses. But the regulatory complexity has also increased — there are more rules to navigate, more state-specific requirements to track, and more compliance obligations to manage. My advice to operators is to invest in a clear regulatory map before you invest in technology. Know which states you will operate in, which services you will deliver, which providers you will employ or contract with, and which payers you will bill. Build your compliance infrastructure around that map, and then select technology that supports your compliance requirements — not the other way around.
— AJ Pakpour, Healthcare Practice Startup & Strategy Expert
In Practice
A behavioral health startup launches a telehealth platform offering therapy, psychiatry, and wellness coaching services. The clinical services (therapy and psychiatry) are structured as telemedicine — delivered by licensed providers via synchronous video visits, billed to insurance using appropriate CPT codes, and subject to state licensure and HIPAA requirements. The wellness coaching services are structured as non-clinical telehealth — delivered by certified coaches, not billed to insurance, and not subject to medical licensure requirements. The platform uses a HIPAA-compliant video platform with a signed BAA for all clinical encounters, and a separate consumer-grade platform for wellness coaching sessions. A large primary care group expands its telehealth program to include RPM for patients with hypertension and diabetes. The RPM program is structured as a clinical telehealth service — patients receive connected blood pressure cuffs and glucometers, data is transmitted to the practice's EHR, and care managers review data and escalate to physicians as needed. The practice bills Medicare for RPM services using CPT codes 99453, 99454, 99457, and 99458, and implements a compliance program to ensure that billing documentation meets Medicare requirements.
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References
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Recommended Professional References
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