For Oklahoma providers, administrators, and health systems

How Oklahoma Defines Telehealth

People often use telehealth, telemedicine, telecare, virtual care, and digital care interchangeably. Oklahoma statute does not, and the distinction affects licensing, compliance, and how services get reimbursed.

Telemedicine and Telehealth (Oklahoma Telemedicine Act)

"Telemedicine" or "telehealth" means technology-enabled health and care management and delivery systems that extend capacity and access, which includes Synchronous Mechanisms such as audiovisual interaction between a patient and a health care professional, asynchronous mechanisms such as store and forward transfers, remote patient monitoring, and other electronic means that support clinical health care such as patient education. Oklahoma Telemedicine Act

Telehealth (Oklahoma Health Care Authority/ Medicaid)

Telehealth is the use of interactive audio, video or other electronic media for the purpose of diagnosis, consultation or treatment that occurs in real time and when the member is actively participating during the transmission. Telehealth service is not an expansion of SoonerCare but a different way to offer quality health care access to SoonerCare members. Oklahoma Health Care Authority.

A Moving Target

Digital health is the newest term reflecting how telehealth keeps absorbing new components, from remote patient monitoring to remote therapeutic monitoring, healthcare apps to AI integration. TAO tracks how the definitions and utilization shift and what each change means for Oklahoma providers.

Starting or Expanding a Telehealth Program

A new telehealth program means sorting licensing, telemedicine reimbursement, technology, and provider buy-in at the same time. TAO members get regulatory guidance, technical assistance, and a line to the Oklahoma organizations that have already done it.

Telehealth Reimbursement

What gets covered depends on the service, the payer, and how the visit is delivered. Rules differ across private insurers, SoonerCare, and Medicare, and they’ve shifted repeatedly since the COVID-19 public health emergency ended. TAO members get reimbursement updates as they happen, plus technical assistance when the guidance doesn’t cover their situation.

Oklahoma Medicaid Telehealth Policy Summary

SoonerCare, Oklahoma's Medicaid program, reimburses for live video telehealth, and recently added reimbursement for an originating site facility fee in certain circumstances. Store-and-Forward and Remote Patient Monitoring must be compensable by the Oklahoma Health Care Authority (OHCA) in order to be reimbursed. Continuous Glucose Monitoring (CGM) and Extended Ambulatory Cardiac Monitoring are covered under certain circumstances. OK Medicaid also added a list of codes reimbursable through audio-only after 5/11/23 and allows for reporting of audio-only modifiers FQ and 93. Regulations also clarify audio-only requirements and allow FQHCs to bill for audio-only through the FFS rate.
Medicare Billing & Coding

The original Medicare policy includes payment parity for a specific set of providers, when patients are in a location as approved by the CMS, and only for a specific list of telehealth codes.

Medicare policies for telehealth continue to evolve. Waivers were passed legislatively during the COVID pandemic to expand eligible providers, patient locations, modalities, and eligible codes. Some of the telehealth flexibilities have been made permanent post-COVID while others are temporary. For example, patients can be seen in their home for behavioral/mental health services (permanent addition) and for non-behavioral/mental health services through December 31, 2027.

More information can be found at Telehealth.HHS.gov and CMS.gov/medicare/coverage/telehealth
Commercial Insurer Parity for Oklahoma Providers

Services Parity: An insurer shall not exclude a service for coverage solely because the service is provided through telemedicine and is not provided through in-person consultation or contact between a health care professional and a patient when such services are appropriately provided through telemedicine.

Payment Parity: An insurer shall reimburse the treating health care professional or the consulting health care professional for the diagnosis, consultation or treatment of the patient delivered through telemedicine services on the same basis and at least at the rate of reimbursement that the insurer is responsible for coverage for the provision of the same, or substantially similar, services through in-person consultation or contact. OK Statute. Title 36, Sec. 6803.

Learning Center

Getting started with Telehealth

Health Resources and Services Administration (HRSA) Visit https://telehealth.hhs.gov/providers/getting-started
Medicare Reimbursement

Health and Human Services (HHS) https://telehealth.hhs.gov/providers/billing-and-reimbursement

Centers for Medicare & Medicaid Services (CMS) List of Telehealth Services eligible for reimbursement. https://www.cms.gov/medicare/coverage/telehealth/list-services

Medicare Billing for Telehealth Encounters Introductory Guide 2024 https://www.cchpca.org/2024/09/2024BillingGuide4FINAL.pdf
Legislation and Research

Center for Telehealth and E-Health Law a 501(C)3 research institute dedicated to addressing the legal and regulatory dimensions of digital health. CTeL https://www.ctel.org/

Center for Connected Health Policy CCHP is a nonprofit, nonpartisan organization that provides telehealth policy expertise, resources and webinars at state and national levels. https://www.cchpca.org/
Telehealth Consultation, Resources (Federally Funded)

National Consortium of Telehealth Resource Centers. A collaboration of federally funded telehealth resource centers who provide information on telehealth across the nation. https://telehealthresourcecenter.org/

Pulse Telehealth Resource Center: A federally funded telehealth resource center who serves Oklahoma, Missouri, and Kansas. https://pulsetrc.org/