
Telehealth changed where care is delivered from. It did not change where care is deemed to occur.
The general rule
Care is treated as occurring where the patient is. So the license you need is generally one in the patient’s state, not the one you are physically in. A PA licensed in one state, sitting in that state, treating a patient across a border, is usually practicing in the patient’s state without a license.
The exceptions, and their limits
Some states allow limited cross-border consultation, brief follow-up with an established patient, or registration schemes short of full licensure. These are narrow, conditional, and differ state to state. They are not a general permission and they rarely cover ongoing primary care.
Why the compact does not solve this yet
It will help, eventually, and only between member states. It is not issuing privileges, so it authorizes nothing today — and it will never reach the states that have not enacted it. A multi-state telehealth practice will still need full licenses in the large non-member markets.
What follows
Telehealth practices are licensing operations whether or not they think of themselves that way. Count the states your patients are actually in, not the states your clinicians live in, and license against the first list.
Then remember that a license is not payer enrollment. Being lawfully able to treat a patient in another state says nothing about whether their plan will pay you for it.
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