Telemental Health: National Policy Considerations

Case management for chronic mental health issues such as substance use disorder by RNs is facilitated by telehealth. Guidelines and reimbursement for the delivery of this services are provided by institutions and funding agencies.

Resources

• Updated 2025: Telehealth for the Treatment of Serious Mental Illness and Substance Use Disorders

• Health and Human Services (HHS) and Drug Enforcement Agency (DEA) issued an announcement on the status of telehealth prescribing of controlled medications in January 2026. The announcement states that a temporary rule will take effect, allowing online psychiatry to prescribe controlled medications to new and existing clients on an ongoing basis without an in-person exam requirement, which has been extended through December 31, 2026. So, right now, this is the 4th temporary extension of the COVID-19 flexibilities.
• Proposed special registration system has not been implemented yet as of 2026.
• Medicare and Medicaid also extended their flexibilities for home-based care, including audio-only, until December 31, 2027. So, right now, it is the same, but there have been many proposals for non-mental health patients and telehealth that have not been implemented. Mental health care flexibilities have been extended until December 31, 2028, longer than non-mental health, which is salient to our population. https://telehealth.hhs.gov/providers/telehealth-policy/telehealth-policy-updates

• Licensure: RNs and APRNs should review their individual state requirements, as every state addresses the scope of practice based on licensure.
• Collaborative Practice Agreements: APRNs need to review their individual state requirements for collaborative practice.
• APRNs can deliver telehealth services in multiple states, depending on rules set by the states, federal polices, and interstate compacts.
• Providers must be appropriately licensed in the states where the patients are located.
• Providers must also have a DEA number in the state where the patients are located to prescribe controlled substances.

Resources

• Telehealth Licensing Requirements and Interstate Compacts
• National Council of State Boards of Nursing

• Coverage to care. Telehealth for providers to get reimbursed through the Centers for Medicare and Medicaid Services (CMS).
• Telehealth services are reimbursed for audio, audio/visual, and G-codes for brief interactions through email or text. Telehealth services will continue after the public health emergency for mental health patients only.
• The rules for Rural Health Centers, Federally Qualified Health Centers, Tribal health Centers, or Medicare/Medicaid may be different, as each state provides guidelines for reimbursement.
• Each state generally follows CMS guidelines, however states have flexibility to modify Medicaid rules for telehealth. Check state regulations through:
  • The National Telehealth Policy Resource Center
  • Telehealth.hhs.gov

Depending on your state’s prescribing guidelines, the DEA, and the Ryan Haight Online Pharmacy Consumer Protection Act of 2009, APRNs are able to prescribe medications, including controlled substances.

• Prior to the COVID-19 pandemic, at least one face-to-face evaluation of the patient was required to prescribe controlled substances.
• During the pandemic, this rule was suspended due to the Public Health Emergency. Congress has passed multiple extensions to keep these flexibilities in place.

APRNs must have a state license and a DEA number in the state where their patients are located in order to prescribe controlled substances in that state.

Resources

• Prescribing Controlled Substances Via Telehealth
• What is the Ryan Haight Act?

Evidence supports the use of telemental health as an effective way of delivering individual and to some degree, group therapy. Guidelines and reimbursement for the delivery of these services are provided by the institutions and funding agencies.

Resources

• Individual Teletherapy
• Group Teletherapy