Maryland Telehealth Regulations: 2026 Guide to Licensing, Prescribing, and Coverage

Telehealth Licensing Requirements

Who must be licensed

To provide telehealth to a patient located in Maryland, you must hold an active Maryland license from the Maryland Board of Physicians (MBP), unless a narrow statutory exception applies. MBP asserts jurisdiction if either the patient or the practitioner is physically in Maryland during the encounter, so Maryland rules attach even when you are the one located in-state. ([mbp.state.md.us](https://www.mbp.state.md.us/resource_information/faqs/resource_faqs_telehealth.aspx?utm_source=openai))

Scope and definitions that drive compliance

MBP defines “telehealth” to include both synchronous (real-time) and asynchronous interactions, but it expressly excludes services delivered solely by audio-only telephone, email, or fax. This definition frames what the Board treats as telehealth for compliance, documentation, and discipline.

Practicing across state lines and the IMLC

Maryland participates in the Interstate Medical Licensure Compact (IMLC), which expedites multi-state licensure. The compact does not replace Maryland licensure; it simply speeds the process. Because the practice of medicine occurs where the patient is located, you need the destination state’s license to treat patients there via telehealth. ([mbp.state.md.us](https://www.mbp.state.md.us/resource_information/res_pro/resource_Practitioner_compact.aspx?utm_source=openai))

Prescribing Medications via Telehealth

Telehealth prescribing guidelines you must follow

Before treating or issuing any prescription via telehealth, you must complete an appropriate patient evaluation (synchronous or asynchronous, depending on the case). You may not prescribe or treat based solely on a static online questionnaire. These are core Telehealth Prescribing Guidelines embedded in MBP rules.

Opiates for pain and other Maryland-specific limits

MBP prohibits prescribing Schedule II opiates for the treatment of pain via telehealth except in limited circumstances (for example, when the patient is in a qualifying health care facility, during a declared catastrophic health emergency, or when there is a bona fide, ongoing practitioner–patient relationship with a prior in‑person assessment by you or a group colleague).

Controlled substances and federal flexibilities through 2026

At the federal level, DEA and HHS have extended COVID‑19 telemedicine flexibilities for prescribing controlled substances through December 31, 2026. During this window, certain Schedule II–V medications may be prescribed via telemedicine without an initial in‑person visit if federal conditions are met. These federal rules operate in addition to Maryland’s requirements. ([telehealth.hhs.gov](https://telehealth.hhs.gov/providers/telehealth-policy/prescribing-controlled-substances-via-telehealth?utm_source=openai))

CDS registration, EPCS, and PDMP

To prescribe controlled substances in Maryland, you must hold a Maryland Controlled Dangerous Substances (CDS) registration (in addition to DEA registration). Maryland also requires electronic prescribing of controlled substances (EPCS) with specified exceptions, and prescribers are mandated to be registered with—and use—the state Prescription Drug Monitoring Program (PDMP) in defined circumstances. ([health.maryland.gov](https://health.maryland.gov/ocsa/Documents/Controlled%20Dangerous%20Substances%20%28CDS%29%20Frequently%20Asked%20Questions%20during%20COVID-19.pdf?utm_source=openai))

Medicaid Telehealth Reimbursement

What Maryland Medicaid covers in 2026

Maryland Medicaid reimburses for synchronous telehealth delivered by audio‑video and audio‑only modalities, and it supports asynchronous telehealth in defined use cases. Asynchronous coverage includes Remote Patient Monitoring (RPM) as defined in COMAR 10.09.96 and store‑and‑forward technologies when used for dermatology, ophthalmology, or radiology under program rules. ([health.maryland.gov](https://health.maryland.gov/mmcp/provider/Pages/telehealth.aspx))

Originating site, distant site, and geography

Medicaid imposes no geographic restrictions on telehealth. A patient’s originating site may be any secure location approved by the patient and provider, and all distant‑site provider types are eligible for reimbursement when other program rules are met. ([health.maryland.gov](https://health.maryland.gov/mmcp/provider/Pages/telehealth.aspx))

Policy guides and program updates

The Maryland Medicaid Telehealth Program Policy Guide (most recently updated May 2025) consolidates coverage, documentation, and billing requirements for synchronous telehealth and points to governing COMAR provisions, including 10.09.49. Recent updates also address the four‑walls policy—Maryland received CMS approval effective June 1, 2025, to waive the requirement for Outpatient Mental Health Centers so they may bill telehealth services when both practitioner and patient are offsite. ([health.maryland.gov](https://health.maryland.gov/mmcp/provider/Documents/telehealth/Maryland-Medicaid-Telehealth-Program-Policy-Guide-May%202025.docx.pdf?utm_source=openai))

Telehealth Standards of Practice

Same standard of care as in person

Maryland holds telehealth encounters to the same standard of care and documentation as in‑person visits. You are accountable for quality, appropriateness of modality, and medical record completeness. ([mbp.state.md.us](https://www.mbp.state.md.us/resource_information/faqs/resource_faqs_telehealth.aspx?utm_source=openai))

Telehealth informed consent

Before providing telehealth services (other than interpretive services), obtain and document oral or written Telehealth Informed Consent. Patients must be told the risks, benefits, and potential side effects of recommended treatments.

Identity, location, privacy, and Secure Data Transmission Compliance

MBP rules require you to verify patient identity, confirm the patient’s location and setting at each synchronous visit, identify everyone present, and protect PHI by securely transmitting clinical data (for example, through encryption) to prevent unauthorized access. These steps operationalize Synchronous Telehealth Standards and Secure Data Transmission Compliance.

Geographic and Site Requirements

Where the patient is determines licensure

Because Maryland treats the encounter as occurring where the patient is located, you must hold Maryland licensure to care for patients physically in Maryland, and MBP jurisdiction applies if either party is in Maryland during the visit.

Medicaid’s site rules

For Medicaid, the patient may receive telehealth from any secure location, including the home, and the distant site can be wherever you deliver care so long as program requirements are met. Maryland Medicaid explicitly states there are no geographic restrictions for telehealth services. ([health.maryland.gov](https://health.maryland.gov/mmcp/provider/Pages/telehealth.aspx))

Patient Evaluation Protocols

Establishing the clinical basis for care

Before treating or prescribing, conduct an appropriate evaluation—synchronous or asynchronous—tailored to the patient’s presentation. When clinically appropriate, arrange in‑person follow‑up or another suitable telehealth modality.

Prohibition on questionnaire‑only care

You may not diagnose, treat, or prescribe solely on the basis of a static online questionnaire. Maryland expects a real clinical evaluation and adequate documentation to support your decisions.

Telehealth Technology Modalities

Synchronous modalities

For licensing and discipline, MBP’s definition of telehealth includes real‑time care but excludes audio‑only phone calls from the term “telehealth.” However, for Medicaid reimbursement, synchronous telehealth expressly includes both audio‑video and audio‑only when program criteria are satisfied. Align your clinical workflow with both frameworks. ([health.maryland.gov](https://health.maryland.gov/mmcp/provider/Pages/telehealth.aspx))

Asynchronous care and Store‑and‑Forward Telemedicine

MBP recognizes asynchronous telehealth, and Medicaid covers specific asynchronous use cases. Store‑and‑forward is reimbursable when used in the delivery of dermatology, ophthalmology, or radiology services under program rules, while other asynchronous services may be addressed in program‑specific guidance. ([health.maryland.gov](https://health.maryland.gov/mmcp/provider/Pages/telehealth.aspx))

Remote Patient Monitoring

Maryland Medicaid supports Remote Patient Monitoring under dedicated program authority (COMAR 10.09.96), with coverage parameters and eligible conditions detailed in Medicaid policy materials. Incorporate RPM data into the record and maintain security consistent with MBP privacy requirements. ([health.maryland.gov](https://health.maryland.gov/mmcp/provider/Pages/telehealth.aspx))

Summary

In 2026, Maryland telehealth hinges on two pillars: MBP rules that define and govern safe, compliant practice, and Medicaid policies that determine when and how services are reimbursed. If you verify licensure, complete informed consent, secure data, perform appropriate evaluations, and align your modality and billing with Medicaid guidance, you will meet Maryland’s core telehealth expectations. ([health.maryland.gov](https://health.maryland.gov/mmcp/provider/Pages/telehealth.aspx))

FAQs

What licensing is required to provide telehealth in Maryland?

You must hold a Maryland license from the Maryland Board of Physicians to treat a patient located in Maryland, and MBP jurisdiction applies if either the patient or you are physically in Maryland during the encounter. The Interstate Medical Licensure Compact can expedite multi‑state licensure but does not replace Maryland licensure. ([mbp.state.md.us](https://www.mbp.state.md.us/resource_information/res_pro/resource_Practitioner_compact.aspx?utm_source=openai))

How does Maryland Medicaid reimburse telehealth services?

Maryland Medicaid reimburses synchronous audio‑video and audio‑only visits, and it covers defined asynchronous services, including RPM and store‑and‑forward for dermatology, ophthalmology, or radiology. There are no geographic restrictions; the originating site may be any secure location. Consult the Medicaid Telehealth Program Policy Guide for current billing details. ([health.maryland.gov](https://health.maryland.gov/mmcp/provider/Pages/telehealth.aspx))

What are the standards of practice for telehealth providers in Maryland?

The standard of care and documentation requirements mirror in‑person care. You must verify identity, confirm patient location and who is present, obtain Telehealth Informed Consent, protect PHI with secure transmission, and ensure your modality is clinically appropriate. You may not treat or prescribe based solely on a static online questionnaire. ([mbp.state.md.us](https://www.mbp.state.md.us/resource_information/faqs/resource_faqs_telehealth.aspx?utm_source=openai))

Can controlled substances be prescribed via telehealth in Maryland?

Yes—subject to both federal and state rules. Federally, DEA/HHS telemedicine flexibilities for prescribing controlled medications are extended through December 31, 2026. In Maryland, you need a state CDS registration, must comply with the EPCS mandate and PDMP use requirements, and MBP restricts prescribing Schedule II opiates for pain via telehealth except in narrow, specified circumstances. ([telehealth.hhs.gov](https://telehealth.hhs.gov/providers/telehealth-policy/prescribing-controlled-substances-via-telehealth?utm_source=openai))