Adding Telehealth to an Independent Primary Care Practice

An independent primary care practice should add telehealth by moving specific visit types, not by launching a separate telehealth service: medication and chronic disease follow-ups by video, results discussions, behavioral health check-ins, audio-only visits for patients without video, portal-based evaluations, and remote monitoring with care management for the chronic disease panel. Keep anything that needs hands, instruments or a procedure in person. Then fix the four operational pieces that decide whether it works: scheduling, the patient's location, documentation, and billing by payer.

This is operational guidance. Billing codes and claims belong with your biller; our billing sister company is White Glove Medical Billing.

Which visits should move first?

• Chronic disease follow-ups where the patient can provide home readings: hypertension with a home cuff, diabetes with glucose data, thyroid with recent labs.
• Medication management for stable patients.
• Results reviews after labs or imaging.
• Behavioral health follow-ups for depression and anxiety managed in primary care.
• Acute minor problems that are well suited to video, under a triage protocol that sends the rest to an in-person slot.

Keep in person: annual wellness exams that need a physical exam, new complaints needing an exam, procedures, vaccines, and anything the triage protocol flags.

What does Medicare pay for, and until when?

Under the Consolidated Appropriations Act, 2026 (§ 6209), Medicare's telehealth flexibilities run through December 31, 2027: patients can be seen at home, with no geographic restriction, and the expanded list of practitioners can bill. Audio-only telehealth is also allowed through December 31, 2027. For mental health services, the in-person requirement is deferred to January 1, 2028. FQHCs and RHCs can serve as distant sites through December 31, 2027. After those dates, unless Congress acts again, most Medicare telehealth reverts to the statutory rules in section 1834(m) of the Social Security Act, which limit originating sites largely to rural facilities. See the Medicare telehealth hub and planning for the end of the flexibilities.

Separate from Medicare telehealth services, Medicare pays for communication-based services such as virtual check-ins and online digital evaluations, and for care management and remote monitoring, which are not subject to the same originating-site rules. Those are the services that tend to survive a change in the telehealth flexibilities.

Two other federal changes affect a practice that adds telehealth:

• Virtual direct supervision. The CY2026 physician fee schedule final rule (90 FR 49266) allows the supervising practitioner's presence for direct supervision to be met by real-time audio and video (not audio-only) for services other than those with a 010 or 090 global surgery period. That helps incident-to billing when the physician is off site. See virtual direct supervision in 2026.
• New modifiers in 2027. Under § 6209(g) of the Consolidated Appropriations Act, 2026, Medicare telehealth claims tied to certain virtual platform arrangements, and incident-to telehealth services, need a modifier starting January 1, 2027. CMS proposed modifiers BB and BC in its CY2027 proposed rule (91 FR 43842). See choosing a telehealth platform.

Can you see patients who are out of state?

Licensure follows the patient's location at the time of the visit. A patient who winters in another state, a college student away at school, or a patient on a business trip is, for that visit, in the other state. Options:

• Some states have exceptions for follow-up care of an existing patient. The Center for Connected Health Policy's Fall 2025 summary counts 38 states plus DC and Puerto Rico with some form of licensure exception. Conditions vary widely. See licensure exceptions for follow-up care.
• Some states offer a telehealth registration for out-of-state clinicians, such as Florida's under Fla. Stat. § 456.47(4).
• Otherwise, a license in that state, which may be worth it for a state where many patients spend part of the year. Licensing help: White Glove Medical.
• Or schedule the visit for when the patient is home.

Whatever the policy, ask and record the patient's location at the start of every telehealth visit. See verifying where the patient is.

Which operational changes make it work?

Scheduling

• Define which visit types can be booked as telehealth and by whom.
• Block telehealth sessions in the schedule rather than mixing them between in-person visits, which keeps both on time.
• Send the link, technical check and consent with the appointment reminder.

Rooming, virtually

• A medical assistant starts the visit: confirms identity and location, reconciles medications, collects home readings, and checks the connection.
• A fallback: if video fails, convert to audio-only where allowed and document it, or reschedule.

Documentation

• Modality used (video or audio-only), patient location, clinician location, who else participated, and consent.
• Any limits of the remote exam and the plan if they matter.

Billing by payer

• A grid of each major payer's telehealth policy: covered services, modality, place of service and modifier rules, and payment level. CCHP counts 24 states plus Puerto Rico with explicit payment parity laws for private payers; others vary. See payment parity laws.

Should the practice add remote monitoring and care management?

For a practice with a large chronic disease panel, often yes, and these services do not depend on Medicare's telehealth flexibilities. Remote patient monitoring (RPM) and chronic care management can be billed together when time is not counted twice. Watch the CY2027 proposed rule: CMS proposed an initiating visit requirement and that RPM clinical staff be direct employees of the practice, which favors practices that run RPM with their own nurses. See setting up an RPM program and the direct employee proposal.

What policies does a primary care practice need?

A shorter list than a telehealth-only company, but not none: consent, patient location and identity, emergency procedures for remote visits, modality rules, and a review of the website and portal for tracking technology. See the policies a telehealth practice needs.

A first-90-days plan

1. Pick three visit types to move and write the triage rule for each.
2. Confirm the platform has a BAA and records modality and location.
3. Build the payer grid for your top five payers.
4. Train the medical assistants on virtual rooming.
5. Launch with one or two clinicians, review a sample of charts after two weeks, then expand.
6. Decide on RPM and care management after the CY2027 final rule.
7. Put December 31, 2027 on the calendar with a plan for Medicare patients seen at home.

Our Medicare 2027 Cliff Plan ($1,450) models which of your Medicare telehealth visits depend on the flexibilities, and our Policies & Consent Kit ($1,950) covers the policy set. See pricing.