
A telehealth emergency protocol needs the patient's visit location and callback number at check-in, an emergency contact, clinical triggers, a way to reach the patient's local emergency center rather than the clinician's, a rule to stay connected until help arrives, and documentation. Colorado requires a written protocol of its out-of-state telehealth registrants.
Every telehealth practice will have the call eventually: a patient who loses consciousness on camera, describes crushing chest pain, or says they have a plan to end their life tonight. In an office, someone dials 911 and an ambulance comes to the address on the door. In telehealth, the clinician's 911 call goes to the clinician's local dispatch center, which may be in another state, and the patient's address on file may not be where the patient is. A protocol that is not written, practiced and loaded with the right information fails at exactly that moment.
Do any states require a written emergency protocol?
Colorado does, for out-of-state clinicians. Under C.R.S. § 12-30-124, added by SB24-141 (effective June 7, 2024), a registered out-of-state telehealth provider must "maintain a written emergency protocol that is appropriate to the applicable standard of care for Colorado," must "make a good faith effort to contact and coordinate with emergency services," and must "remain on a synchronous connection with the patient" until emergency services arrive or the situation is resolved in the provider's clinical judgment.
Other states get there through disclosure and follow-up rules:
- Louisiana Board of Medical Examiners rules require physicians to disclose, before telemedicine, how follow-up and emergency care work and the plan if the technology fails (La. Admin. Code tit. 46, pt. XLV, § 7507).
- Georgia Board rules require giving patients the treating clinician's name, credentials and emergency contact information, with clear follow-up instructions (Ga. Comp. R. & Regs. 360-3-.07).
- Mississippi Board rule says informed consent should include how to get follow-up care after an adverse reaction or equipment failure (30 Miss. Admin. Code pt. 2635, R. 5.3).
- Delaware requires the availability of a distant site provider or other coverage for follow-up care as part of every telehealth relationship (24 Del. C. § 6003(a)(6)), and Idaho requires the provider or a group colleague to be available for follow-up (Idaho Code § 54-5706).
Even where nothing is written, the standard of care is the in-person standard in nearly every state. A clinician who could not summon help because no one knew where the patient was is going to have a hard time with a board.
Why can't the clinician just call 911?
Because 911 routes by the caller's location, not the patient's. A clinician in Denver who dials 911 for a patient in Ohio reaches Denver dispatch, which then has to find and transfer to the right Ohio center. That costs minutes. The protocol should give the clinician a direct way to reach the patient's local public safety answering point, usually its 10-digit emergency line, looked up from the patient's location at the start of the visit, or have someone on site with the patient call 911 locally.
What should the protocol cover?
- Location at check-in. City, state and physical address for the visit, plus a callback number. Without it, nothing else works. See verifying where the patient is.
- An emergency contact who can be reached if the patient cannot, collected at intake and confirmed periodically.
- Triggers. Clinical red flags by service line: chest pain, stroke signs, anaphylaxis, severe bleeding, suicidal intent with a plan, threats to others, a child in danger.
- The call sequence. Who calls emergency services (clinician or a second staff member), how the patient's local center is reached, what to say, and who stays on the video.
- Stay connected. Keep the synchronous connection open until help arrives, as Colorado requires of its registrants. Assign a second staff member to make calls so the clinician can stay with the patient.
- Connection loss. If video drops, call the patient's phone at once; if no answer and risk is high, call the emergency contact and local services.
- Behavioral health. Scripts for suicide risk, including the 988 Suicide & Crisis Lifeline as a resource, and when to escalate to emergency services instead. Duty-to-warn and duty-to-protect rules vary by state; psychologists can start with White Glove PsyPact's duty to warn across state lines.
- Mandatory reporting. Child and elder abuse reporting follows the patient's state. Keep a reporting contact list per state.
- Documentation. Time of each call, who was reached, the outcome, and the clinician's note, completed the same day.
- After-action review within a week, with the medical director.
What about medication emergencies?
Programs that prescribe drugs with acute risks need service-line-specific plans. FDA's October 10, 2023 communication on compounded ketamine warned that at-home use without an onsite provider means no one is present to monitor sedation and dissociation. If a program allows at-home dosing, the protocol should say who must be present, what they are told to watch for, and when they call 911. See ketamine and telehealth. Weight-loss and hormone programs need clear instructions on symptoms that require same-day evaluation in person.
How do you make the protocol work in practice?
- Put it in the visit software. One button that shows the patient's visit location, the local emergency number, the emergency contact and the call script.
- Drill quarterly. Run a mock emergency with each clinical team, including a dropped connection and an out-of-state dispatch transfer. Time it.
- Train new clinicians before their first shift, not in their first month.
- Tell patients at intake that telehealth is not for emergencies and what to do if one happens between visits. Most consent laws expect this disclosure anyway; see consent form requirements.
- Review every real event. The protocol should change after the first one.
The protocol belongs in the day-one policy set described in the policies a telehealth practice needs, and it is part of our Telehealth Policies & Consent Kit ($1,950), with state-specific inserts for Colorado and the disclosure states. Your medical director and counsel should approve the final version. Nothing here is legal or clinical advice for a specific patient.
Common questions
- What happens if a telehealth clinician calls 911 for a remote patient?
- The call reaches the dispatch center for the clinician's location, not the patient's, and must then be transferred. Protocols should give the clinician the patient's local emergency center number, or have someone with the patient call 911 locally, while the clinician stays on the video.
- Which states require a telehealth emergency protocol?
- Colorado requires out-of-state telehealth registrants to keep a written emergency protocol and stay on a synchronous connection until emergency services arrive (C.R.S. § 12-30-124). Louisiana, Georgia and Mississippi require disclosures about emergency or follow-up care.
- Should a telehealth practice collect an emergency contact?
- Yes. If the patient becomes unresponsive or the connection drops during a high-risk visit, the emergency contact may be the fastest way to reach someone near the patient. Collect it at intake and confirm it periodically.
- How often should a telehealth practice run emergency drills?
- Quarterly is a practical cadence, with each clinical team running a mock emergency that includes a dropped connection and an out-of-state dispatch transfer. Train new clinicians before their first shift.
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