Vermont's Telehealth License and Telehealth Registration

Vermont built something no other state has quite copied: two telehealth credentials sized by patient count. Act 107 of 2022 added 26 V.S.A. chapter 56, effective July 1, 2023. It lets a clinician licensed elsewhere treat a small number of Vermont patients by telehealth without a full Vermont license. The caps are low enough that a national direct-to-consumer company will outgrow them in a week, and high enough to solve the most common continuity problem: a patient who moves to, or spends a season in, Vermont.

What are the two credentials?

• Telehealth registration (26 V.S.A. § 3054(b)). Up to 10 unique patients or clients, for no more than 120 consecutive days from the date it is issued. It cannot be renewed, and it can be reactivated only once every three years. The fee is the lesser of 50 percent of the profession's renewal fee or the application fee for a full license.
• Telehealth license (26 V.S.A. § 3054(a)). Up to 20 unique patients or clients located in Vermont during the two-year license term, renewable every two years. The fee is 75 percent of the profession's renewal fee.

The Vermont Board of Medical Practice explains the trade-off this way: the registration application is "very abbreviated" and is meant for starting quickly, while the telehealth license uses "the same process for a full license" and suits long-term practice with a limited number of patients. Fees for a registration can be credited toward a telehealth or full license if the holder applies within three years, and telehealth license fees can be credited toward a full license (§ 3054(d) and Board of Medical Practice guidance).

What can a holder not do?

Section 3053(b) is direct: either credential authorizes services "using telehealth only" and does not authorize the professional "to open an office in Vermont or to provide in-person health care services to patients or clients located in Vermont." Treating more patients than the cap, or treating without a credential, is unauthorized practice under 3 V.S.A. § 127 (§ 3053(c)).

Holders must also practice within Vermont's scope of practice for their profession and at the Vermont in-person standard of care (§ 3055), and they are subject to Vermont law on prescribing, informed consent, health information sharing, supervision and collaboration, and unprofessional conduct, including Vermont's telehealth statutes at 18 V.S.A. §§ 9361 and 9362 (§ 3058).

Who is eligible?

A clinician who holds an active, unencumbered license in good standing in another U.S. jurisdiction, with the same or a broader scope of practice than Vermont allows for that profession (§§ 3054, 3055). A clinician whose license has been revoked anywhere, or who is under a pending disciplinary investigation or action in any jurisdiction, is not eligible, and holders must report new discipline anywhere within five business days (§ 3057). Rules may also require a mandatory patient disclosure and, for the license, proof of malpractice coverage for out-of-state telehealth.

The Office of Professional Regulation adds one limit operators trip over: clinicians who live in Vermont are not eligible for the telehealth license or registration under the new rules and should look at full licensure, including OPR's Fast Track Endorsement for those licensed elsewhere for at least three years.

Which professions can use it today?

Here the split matters. Chapter 56 covers two regulators (§ 3051):

• Board of Medical Practice: physicians (MDs), physician assistants and podiatrists. According to the Vermont Department of Health's Board of Medical Practice guidance, the telehealth registration and telehealth license are available now, and the earlier temporary telehealth registrations have all expired.
• Office of Professional Regulation: 23 professions, including osteopathy, nursing (which covers APRNs), pharmacy, psychology and social work. OPR's page says the telehealth registration and license for its professions are "not in effect until rules are in place." Until then, under Act 4 of 2023, out-of-state OPR professionals use an Interim Telehealth Registration, which also bars in-person care. OPR circulated draft rules with a public comment period that closed August 4, 2026, and has said interim holders will get at least 90 days after the rules take effect to transition.

So an out-of-state MD or PA applies to the Board of Medical Practice for a capped credential, while an out-of-state DO or NP currently holds OPR's interim registration and will move to the capped system once OPR's rules are effective. Check OPR's page before filing; that date is the one most likely to change.

Is anyone exempt?

One narrow exemption: a professional licensed anywhere in the U.S. may consult with another health care professional about a Vermont patient without a Vermont credential, as long as the consultation is a review of records with no in-person or remote contact with the patient (§ 3059). A video visit with the patient is not covered.

How should a multi-state practice use Vermont's credentials?

• Continuity cases: a registration bridges a patient who moved to Vermont while the clinician applies for a telehealth or full license.
• Specialty follow-up: the Board's own example is a specialist who operated on a few Vermont patients and wants to see them by video afterward. A telehealth license fits.
• Direct-to-consumer at scale: neither credential works. Twenty patients over two years is a cap, not a starting point. Plan full licensure, or for physicians the Interstate Medical Licensure Compact, which White Glove IMLC covers in its telemedicine guide.
• Count unique patients per clinician. The cap belongs to the professional, so the practice needs a counter in the EHR that blocks scheduling a 21st Vermont patient.

The Vermont page in our telehealth law index collects the citations, and states with a telehealth registration compares Vermont's design with Florida's and Arizona's. Our Telehealth Registration Filing service ($395 per clinician, per state, plus state fees) prepares Vermont filings for physicians, NPs and PAs. This is research for your counsel, not legal advice.