Practicing Telehealth Therapy in Illinois and Across State Lines
Updated: May 18, 2022
As we move into another year of COVID and its variants, social workers have learned to incorporate telehealth services into their practice with clients. With practitioners and clients alike becoming more mobile, clarity around telehealth practice across state lines have become essential in having continuity of care between patient and social worker.
Below is a compilation of commonly asked questions pertaining to whether telehealth services can be administered if the social worker or client leaves the state. Please note that this article only addresses questions for social workers who are licensed in Illinois; for those who are licensed elsewhere, you will need to check with that state’s regulatory board. For more information, scroll down to the “More Resources” section of this article.
This document does not apply to governmental workers who may have agreements that allow telehealth across state lines—please refer to federal agreements if you work for a federal agency. This document does not apply to current waivers regarding Medicaid.
I’M A SOCIAL WORKER LICENSED IN ILLINOIS. Can I use telehealth services to see my client if…
…my client is in Illinois?
Yes. A health care professional may engage in the practice of telehealth services in Illinois to the extent of their scope of practice as established in his or her respective licensing Act consistent with the standards of care for in-person services.
…I’m (temporarily) going to another state but my client remains in Illinois?
According to the Illinois Department of Financial & Professional Regulation (IDFPR), social workers who are licensed in Illinois may continue to see clients via telehealth if they, the practitioner, are visiting a different state. For further questions on what is and isn’t allowed by IDFPR with regards to practice, contact IDFPR.
…I’m in Illinois but my client is (temporarily) going to another state where I am not also licensed?
Depends. Each state is different regarding whether or not they allow social workers licensed in another state to see their clients who are physically in a state the social worker is not licensed in. Some states allow limited telehealth services to be provided, others require temporary licenses with the state. You must reach out to the licensing board of the state your client is visiting to determine that state’s requirements.
The Association of Social Work Boards (ASWB) has created a helpful COVID-19 resource page that provides a list of emergency provisions regarding social work licensure related to the COVID-19 public health emergency. While we cannot verify that all of the information on this page is correct, they do provide a helpful list of regulatory provisions by state. To access the page, go to: https://www.aswb.org/covid-19/. NOTE: This page is updated as they become aware of changes. If a state is not listed, it means there are no provisions specific to the public health emergency at this time. As with guides, we still recommend you double check with the licensing board of the state your client is visiting.
…my client remains in Illinois but I move to another state while retaining my Illinois license?
Yes. Illinois requires you to be licensed in the state where your client is physically located but it does not require you to be physically present in the state of Illinois to practice telehealth.
I’M A SOCIAL WORKER LICENSED IN ANOTHER STATE. Can I use telehealth services to see my client…
…if they are temporarily/permanently coming to Illinois?
NEW! While out-of-state social workers cannot yet utilize telehealth services to see clients temporarily visiting Illinois, they may do so beginning January 1, 2023, thanks to the governor signing House Bill 4797 into law on May 13, 2022. Beginning January 1, 2023, the law will allow for a short-term visitor to Illinois to continue telehealth services with their home state therapist so long as they: 1) have a pre-existing therapeutic relationship with a therapist; 2) their therapist is licensed to practice social work in their home state; and 3) they cap the total sessions allowed in a year to 15 sessions with no more than 5 sessions occurring in any month. The bill also allows for non-resident college students to continue to see their social worker from their home state so long as they have a pre-existing therapeutic relationship with that social worker and that the student is currently enrolled in an Illinois college or university.
…if they are permanently coming to Illinois?
No. In Illinois, only social workers who are licensed in Illinois may see residents who permanently reside in Illinois. To find out how to transfer your license to Illinois through the endorsement process, click here.
OTHER RELATED QUESTIONS
Does Illinois have telehealth pay parity?
Yes. An individual or group policy of accident or health insurance shall reimburse an in-network health care professional or facility, including a health care professional or facility in a tiered network, for telehealth services provided through an interactive telecommunications system on the same basis in the same manner that would apply to the services if the services had been delivered via an in-person encounter by an in-network or tiered network health care professional or facility.
This applies only to those services provided by telehealth that may otherwise be billed as an in-person service.
What limits are placed on health insurance companies in Illinois?
An individual or group policy of accident or health insurance shall not:
require that in-person contact occur between a health care professional and a patient before the provision of a telehealth service;
require patients, health care professionals, or facilities to prove or document a hardship or access barrier to an in-person consultation for coverage and reimbursement of telehealth services, e-visits, or virtual check-ins;
require the use of telehealth services, e-visits, or virtual check-ins when the health care professional has determined that it is not appropriate;
require the use of telehealth services when a patient chooses an in-person consultation;
require a health care professional to be physically present in the same room as the patient at the originating site, unless deemed medically necessary by the health care professional providing the telehealth service;
create geographic or facility restrictions or requirements for telehealth services, e-visits, or virtual check-ins;
require health care professionals or facilities to offer or provide telehealth services, e-visits, or virtual check-ins;
require patients to use telehealth services, e-visits, or virtual check-ins, or require patients to use a separate panel of health care professionals or facilities to receive telehealth service, e-visit, or virtual check-in coverage and reimbursement; or
impose upon telehealth services, e-visits, or virtual check-ins utilization review requirements that are unnecessary, duplicative, or unwarranted or impose any treatment limitations, prior authorization, documentation, or recordkeeping requirements that are more stringent than the requirements applicable to the same health care service when rendered in-person, except procedure code modifiers may be required to document telehealth.
For additional resources on telehealth, click the links below:
NASW-Illinois Chapter members can post their questions to our telehealth thread in the NASW Illinois community in MyNASW. Click here to post your question and have it addressed by chapter stuff.