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Can I Do Telemedicine From Abroad?

I get this question a lot, and I reply to it a lot. It’s not a straightforward answer, just like “Am I having a heart attack?” doesn’t often have a straightforward answer. Can US physicians practice telemedicine while abroad? Yes. As long as you’re not breaking specific rules.

You can do almost whatever you want if you are taking cash-pay patients, and it’s your own practice. It’s 100% legal to reside abroad as long as you have a US state medical license. And as long as your state allows you to be abroad while performing telehealth visits. I don’t know of any states which have gone so far as to forbid this. More on this later.

A great website with many helpful articles is Hippocratic Adventures. Just remember that information on such topics get quickly outdated – check out the comment sections for the most up-to-date information—or joint physician groups on FB or Linkedin.

Want to build your own virtual practice and live where you want and work when you want? Check out my DocDigital Online Course!

Working for Teladoc

The classic example is that you work as an independent contractor or employee for a telemedicine company. Say, Teladoc or Doctor on Demand. Their rules are clear – you cannot be abroad while doing telemedicine for them.

At least, that’s what my contract stated verbatim when I worked with them. My friend now works for Teladoc, and they are okay with her doing telemedicine abroad. I read her contract – it had nothing about where the physician should be physically located.

(1/2023 update: Teladoc now forbids performing telemedicine while residing abroad. She received a letter stating that no work can be performed while located abroad.)

But, if your employer allows it, you can practice telemedicine abroad.

There are plenty of telemedicine or telehealth companies that hire physicians and allow them to work from abroad. The tough part is finding them, and that’s best done by getting word out and reaching out to such companies on Linkedin.

Insurance Billing

Most insurance companies don’t have any clause forbidding you to reside abroad while doing telemedicine. At least from the disgustingly long contracts I have read.

If you are billing your own online telehealth practice, you can reach out to your insurance liaison and ask them to clarify it for you.

However, because CMS has created a clause about physicians residing in the US, it’s possible that insurance companies will follow suit.

CMS Billing

CMS, which is Medicare and Medicaid, and a few other public programs have passed regulations that require physicians to reside in the US when billing CMS.

I present to you an oversight report from April 2018. The report number is A-05-16-00058. Here, they report on a psychiatrist physician who billed for a patient visit while residing in Pakistan.

I have no idea what happened to that poor bastard, but I’m sure he got a denial letter, and knowing the CMS, they probably charged him with something fraudulent.

Social Security Says…

Following the breadcrumbs, section 1862(a)(4) of the Social Security Act and 42 CFR § 411.9(a) states the following mess:

Notwithstanding any other provision of this title, no payment may be made under part A or part B for any expenses incurred for items or services which are not provided within the United States (except for inpatient hospital services furnished outside the United States under the conditions described in section 1814(f) and, subject to such conditions, limitations, and requirements as are provided under or pursuant to this title, physicians’ services and ambulance services furnished an individual in conjunction with such inpatient hospital services but only for the period during which such inpatient hospital services were furnished).

Code of Federal Regulations Says…

And from 42 CFR § 411.9(a) from the code of federal regulation:

Except as specified in paragraph (b) of this section, Medicare does not pay for services furnished outside the United States. For purposes of this paragraph (a), the following rules apply:

(1) The United States includes the 50 States, the District of Columbia, Puerto Rico, the Virgin Islands, Guam, American Samoa, The Northern Mariana Islands, and for purposes of services rendered on board ship, the territorial waters adjoining the land areas of the United States.

(2) Services furnished on board ship are considered to have been furnished in United States territorial waters if they were furnished while the ship was in a port of one of the jurisdictions listed in paragraph (a)(1) of this section, or within 6 hours before arrival at, or 6 hours after departure from, such a port.

(3) A hospital that is not physically situated in one of the jurisdictions listed in paragraph (a)(1) of this section is considered to be outside the United States, even if it is owned or operated by the United States Government.

Your Own Online Practice

I suspect that private insurers will eventually follow Medicare, as they traditionally do. Eventually, Bluecross won’t let us bill when we do telemedicine abroad.

For this reason, it’s better to build your own online private practice. It sounds complicated, but for me, it’s the only way forward.

Running a virtual primary care practice is not at all like running a physical practice… in a good way.

Digital Nomad Health

I have podcasts and YouTube videos dedicated to this topic. I don’t think it’s that difficult to build your own virtual practice and get the regulators off your back.

I did this so that I could live abroad. Not reside abroad permanently but have the option to travel.

Escaping the Micromanagement

You can do telemedicine abroad with your own private patients, and nobody will interfere with your practice.

Of course, if you’re not engaging in the practice of medicine, even better. Enter health coaching.

I do some health coaching, so I don’t have to worry about any state medical board.

Heart Health Coach

Should state medical boards adopt a similar regulation, you keep your interactions based on information sharing and clearly indicate that you aren’t engaging in a patient-doctor relationship.

An attorney can help you make your intentions clear.

For whatever prescribing or treatment you need to do from abroad, you can contract with a PA or NP. However, I prefer to keep things less complicated.

Malpractice Coverage

I contacted The Doctors Company to request malpractice quotes, and they said they weren’t interested in underwriting an all-virtual practice.

Don’t worry, plenty of other companies will.

The other factor to consider is that if you are a permanent resident abroad, you may not qualify for malpractice insurance in the US.

I am not a fan of living permanently abroad. I prefer to retain my US residency and pay my taxes here.

Local Laws When Practicing Abroad

Do you need a work permit to work in another country? Maybe. If you are an employee, you might need a work permit even when working for a company abroad.

Physicians can also work in non-clinical positions such as in research or the government. A third area is to practice clinically in the U.S. via telemedicine, which is what Bojarski does currently as a psychiatrist in private practiceopens in a new tab or window.

MedPage Today

Do you need a work permit in your foreign country when you’re running your own business? Depends.

I doubt the police will show up on my doorstep in Spain because I have a rental income property in California. Nor would they be handcuffing me because I own a roofing company that runs itself.

The main issue is taxes; that’s what most people care about. And the business pays taxes in the country in which it is formed.

Dr. Mo is a business. This handsome face you’re looking at is not Mohammad Ashori, MD but a business entity that pays taxes to California even if Mohammad Ashori resides in Sweden.

China, however, might be a different story.

In China, the Medical Practitioners Law generally refers to the “practice of medicine” as medical diagnosis, disease investigation, medical treatment and the issuance of corresponding medical documents by physicians. Rendering remote diagnoses normally constitutes practice of medicine in China and would be limited to locally licensed physicians and foreign physicians holding a Short-Term Foreign Practice License at approved hospitals. These requirements remain the same even under COVID-19 conditions. Physician-to-physician consultations, however, do not necessarily fall within the “practice of medicine” in China.

JDSupra

Data Privacy and HIPAA

If your practice is mostly based outside of the US, it’s important to have a competent attorney draw up appropriate patient agreements addressing data privacy and HIPAA.

Your patients have the right to know if their medical information crosses international borders.

Does doing telemedicine from abroad really put your patient’s data at risk? Unlikely.
Will your patients report you? Unlikely.
Could something happen that might make this information discoverable? Definitely.

More importantly, you don’t want the headache. It’s easy enough to build the kind of online medical practice that lets you sleep comfy at night.

Ethical Consideration

What I consider ethics and what a court considers ethics are light years apart.

Deborah Baker, JD believes that it’s okay to wield an emergency call from a psych patient when traveling across state lines but not as appropriate if it’s a routine virtual appointment.

Attorneys are the ones who convince judges and jurors. So, if you’re going to travel abroad, or even worse, across state lines, you’ll have to know local laws.

The DocDigital Online Course goes over such issues in nauseating detail. Enroll today and make me richer!

76 replies on “Can I Do Telemedicine From Abroad?”

I’ve heard about this being a problem from a Medicare/Medicaid perspective, but I’ve also heard there’s a DEA rule against prescribing controlled substances on foreign soil? However, I can’t seem to find any actual DEA rule when I research this. Also, is it clear if it matters if you are only temporarily visiting a foreign country while practicing rather than residing there? While still having a US address & permanent residence?

I don’t think it’s clear in regards to just traveling temporarily abroad versus being a resident abroad. The reality is that all of these things are open to interpretation by the law once you are on someone’s radar. Laws are, some say, intentionally written vague enough that more laws can be piggybacked on them and they can be fought in court. But if that’s too cynical of a perspective for the readers here I would say that the documents I have read haven’t made it clear but if you don’t want the headache then stay stateside when doing telehealth with 3rd party payers.
I haven’t come across anything with the DEA. I’ll keep an eye out for it.

what about using a VPN while abroad? I know it sound sketchy but how would an insurance actually find out that I am abroad? I’m only asking because I travel a lot, not because I live overseas. And when I travel I see patients online with my VPN.

I use a VPN and I don’t feel it’s sketchy. My location and what I transmit over wifi is my business and nobody else’s. Nobody but me has the right to know where I am located unless what I am doing is breaking a law. With that said there are many types of VPN and many levels of security when it comes to blocking your location. You ISP could be displayed, the time stamp from your laptop in the local time zone can leak, your unblocked IP address can leak without a kill switch, and the is the IPv6.
I am less worried about the insurance company or even CMS finding out. I am more worried about a physician who might think their location is secure because of a VPN and then tell a governing body that they weren’t overseas when they fact were overseas. Then an investigator confiscates your cell phone or subpoenos your mobile provider and tracks the towers you connected to which happened to be overseas and now you lied to some agent of the law. It gets messy.

The way to get around this is remote control using an application TeamViewer and of course there’s others out there leaving your actual cell phone or your laptop or desktop connecting with the secondary device using a VPN to those devices left at home in United States that way your actual phone that you work is actually in United States and have a secondary phone or device back in the United States that way you’re getting investigator looks at your device including mobile Tower the cell phone never left you connected it using remote control to that device then does the US work for whatever patient

There are many ways to spoof your location, IP address, and cell towers. The question is whether it’s worth it. We’re here trying to see patients and it seems that the gov’t is trying to prevent that.

I am not prescribing anything. I’m a pharmacist that just does Telehealth visits to discuss pts meds. It seems like that would be no issue because it’s all counseling and they wouldn’t even know where I was? I file taxes for that state just like I would if I was here.

Thanks for your transparency and thoroughness! I am appreciative of your website.

I’m finishing fellowship and considering moving abroad for a year with family. I’d like to do telework–wouldn’t need to do much to keep us afloat. I’m wondering whether you think it’s important to be up front with any potential employer about the prospect of working abroad. You mentioned that your GF didn’t have any exclusionary language in her contract. Did she disclose in her recruitment process that she’d be working from abroad? Is it possible to perhaps instead state that you’re not going to take Medicare/Medicaid patients? How much does having a US VPN make a difference?

I see the point of private practice in avoiding the headache, but I’m not sure it’ll be a permanent move. Don’t want to transition patients out of a practice in a year if we decide to move back to the US and I want FT work.

I am an United States citizen and I have been a teladoc provider for over 2 years. My family and I are planning to relocate to Ireland in January 2023. I am a family medicine trained MD and am seeking a job based in Ireland as a GP however I would ideally like to continue to work with teladoc on the side, similar to as I do now in the States, averaging 200 – 400 patients per month just to make ends meet. I have been reassured that my employer in Ireland will cover my medical indemnity insurance for that job, but I am still trying to find out if I need to do anything different while seeing US-based teladoc patients if I am living abroad in Ireland but retain my US licensure which allows me to see patients in Louisiana and Florida. Will I’ll be taxed differently? Will I have to seek out some other kind of medical indemnity even though I’ll be working remotely as an American citizen with American credentials and only treating American patients? Will things be any different at all from the telemedicine standpoint if I am physically living in Ireland? Any insight will be greatly appreciated.

Did you ever find answers to your questions about indemnity insurance? I have heard that this is a primary obstacle for clinicians that are residing abroad and treating patients in the US remotely. Were you able to find any companies that would offer this insurance to you?

Hi

I’m in the same situation kind of moving to Ireland form the USA and want to continue teladoc. Did you have any success with doing this?

Thanks

Would you happen to know if Psychiatric DNP’s are under similar legislation and able to practice telepsych remotely internationally? As long as the State allows for independent practice for the NP. Thanks for the information.

Let me know if you are able to do it. I am interested as well. Do you have your own practice? private pay?

Have any of you done this already? My family and I are thinking about moving abroad as well and as a pmhnp I work remote now.
Thank you!

So I am planning on working a remote psychiatric position and residing outside of the US. It sounds like as long as I do not bill Medicaid and Medicare there are no real issues with this. Is that understanding correct? Or for you who are using another VPN are you billing Medicaid and Medicare as well?

The VPN won’t affect your billing abilities. If you are audited and asked where you were located when billing CMS they would do their due diligence to find your actual location. There is hardly any money to be made through CMS so the risk doesn’t seem worth it.
The topic remains complicated because some attorneys argue that it’s your residency status while others say it’s simply your location.

Before buying your “Starting a Virtual Private Practice” course on Teachable, I just wanted to be sure, can a foreign Psychiatrist that was certified overseas and has never been in the U.S. nor has any state licenses provide telepsychiatry to U.S. citizens?
Also, how would they provide prescriptions to such citizens, pharmacies wouldn’t just dispense a prescription written by a foreign Psychiatrist.
If you may, I’d love to hear your input on such obstacles because I really want to enroll in that course.

Any US citizen can pay money to a foreign psychiatrist for treatment but you couldn’t prescribe medication to someone in the US without a state license.
It’s not really an obstacle in that regard, it’s just basic state licensure. If you don’t have the license you can’t prescribe here. But you can offer mental health treatment without prescriptions. I am not sure if my course is the right fit for you since it’s geared towards US physicians.

Can you work as Collaborative Physician from outside of US, no direct patient care involved, only supervision of NPs aand PAs? Thank you!!

The thing with these kind of questions is that there is a lot of “it depends”. I know that’s not as sexy as a one-line answer but it would depend on who is the payer. Who is the employer? Are there US based malpractice contracts which you have to consider? Do you need to be physically present based on your state medical board in the same state or within a certain driving distance?
For example, I have considered running a practice with just an NP/PA whom I supervise from a distance. In such a case I would prefer an NP because they can be more independent in my state. I don’t see any issues with it as long as my malpractice carrier and my business insurance is aware of my location. I also would attempt to remain a resident of the US by traveling there regularly and avoiding being in another country long enough that I would be a tax resident abroad. This isn’t as big of a deal but there are reasons why this makes the most sense for me.

For the purpose of the medical service provided, the location is where the patient is, not where the doctor is. That’s why you have to be licensed in the state where the patient resides. Why isn’t this clear to everyone else?

Thank you for sharing your thoughts I believe you are referring in regards to 3rd party payers, correct? Your statement here highlights why this is a bit of a complex matter. Many states allow patients to continue to get care or get a second opinion about their care from a physician not licensed in the origination state (which is what you might be referring to).
Sadly, healthcare has gotten quite complex and hard for physicians and patients both to navigate.
Fortunately, healthcare has gotten quite complex and many loopholes now exist that offer physicians the opportunity to practice the kind of medicine they’ve imagined.

I am a FM physician living abroad temporarily but hold an active medical license in 3 states. Can I start a virtual private practice? If so should I contact my home medical licensing body to get approval?
Any companies that help set up a virtual platform?

You don’t need approval from any licensing state to start a virtual practice.
Many companies help with setting up a virtual practice but it depends on the kind of help you’re looking for. Marketing? Hiring staff? Legal documents? Registering the business? The actual telemedicine part? I think most physicians are often eager to find a website name and start the platform so for that I would recommend going with a company like Akute Health which I’ve reviewed on my YouTube channel. Or you can go with something more complex such as atlas.md

I am a NP locally employed by an MD in California. my future career path will require me to travel a lot mostly abroad and would want to continue my employment but purely telehealth. Our payers are mostly third party payers we dont have medicaid patients.
Who do I need to talk to see the feasibility of this setup? I will maintain a local address in the US and will be visiting regularly. I will be treating the same patients i am treating now. I will be maintaining my licensure. The only change is the geographic location outside the country when I call patients.

You would likely need to reach out to your human resources department. They will tell you what the legalities are and what their rules and regulations are regarding you being abroad.

1-What about Canada? Does it matter which country? You’ll be paying US taxes anyways.
2- how would someone find out (or even investigate) if you’re working for a telemedicine company (1099) but live abroad?
3- does it matter whether you keep your US residence or not?

1. what about what regarding Canada?
2. I suspect if the telemedicine reported you to the state medical board for breaking their contract and logging in from a foreign IP address or you get sued and the state medical board finds out that you were abroad
3. it does

Any idea if it is kosher to practice telehealth from abroad with regards to how other countries look at this? I am a US physician and will be seeing patients in states I am currently licensed in. I will be billing private insurance. What I’m wondering is, could I move to say, Portugal or Vietnam and keep doing this. OR, would those governments require me to obtain a medical license in that specific country even if I’m seeing patients virtually back in the US.

It’s a good theoretical question. Currently, most countries, or no country that I know of, have any kind of rules or regulations for performing medicine virtually for patients that are not in their district. For that reason, the only trouble you would be looking at is if the insurance companies you are servicing aren’t happy with you seeing these patients while abroad. Or if your malpractice insurance doesn’t want you to be abroad while doing this. Other than that I don’t think you’re going to run into any issues with any countries for at least five years.

Good morning! Would this apply to axillary services – nursing working remotely? Thank you!

As far as I know the content should be accurate and relevant to physicians. As far as other healthcare workers I am not sure how the rules and regulations are evolving for nurses. I think communities on Reddit might be a good place to ask.

Curious about how living abroad and continuing to see patients in the states is effected when it comes to taxes. If I am required to pay in the country I reside in will that not stop the insurance companies from compensating me for services?

I practice out of netowrk which means I don’t bill any insurance company, I bill the patient directly.
Taxes have more to do with your country of residence and that’s often an emotionally charged conversation as well as a political one. I’ve dedicated podcasts episodes, blog posts, and youtube videos to the topic.

Hi Dr. Mo,
Suppose a pharmacist or optometrist wanted to do remote care as well. Would the same rules apply, meaning would they also be able to practice remotely? Furthermore, if one is practicing medicine as an American doctor/physician while living in Turkey or Spain, would one need to obtain a work visa or work permit for the country they are residing in?

I suspect the question you’re asking is best reserved for an attorney. Most countries don’t allow you to work in their country if you don’t have a work permit and few will let you work there if you aren’t paying taxes there. However, as always with financial matters, there are loopholes and the details matter. You can run your own business in the US while traveling abroad in Turkey – nobody will care nor stop you. However, in the online work people like to pick virtual fights and stand their ground that the way the law is written you’re not allowed to work while abroad. Yet a law that isn’t enforced, such as motorcyclists blasting through a residential neighborhood with their loud exhaust, isn’t really a law, it’s just reserved for when someone has a beef to pick with you. So, an attorney is your best friend here when asking a legal question. Alternatively, if you are asking if people across the world are living in different places and making their money in another location, yes, since the 1980s that’s been the case.

Great post! I don’t think this has been addressed yet but say a patient uses a US-based online platform however located at an overseas military base…..

Because many of these medications are compounded/ mail order a patient can seek care in Japan for example with an American FPO/APO.

My question is where does the patient “reside” in this case? It would seem American soil with a US zip code etc. I can’t find a military regulation specifically addressing this either

I’ve heard this question in the past. It seems like it would be considered US soil as long as the patient is located in that particular location. But I’m sure there are subtleties which are beyond the scope of my understanding and in the realms of an international attorney.

Hello Dr. Mo

I am a NP in CA and considering a telemedicine position that is a 1099. Are you familiar with the DEA guidelines in registration for remote work?

Historically I’ve worked in clinics as a W2 employee with DEA registration being straightforward.

Dr. Mo,
I work for a telehealth company while living abroad. They are aware of this. And state this is no problem. I don’t prescribe controlled substances and don’t bill medicare or medicaid. My company states their malpractice will cover me. I have someone helping me with taxes in both countries. Is there anything you think I have missed, or should worry about?

If your company knows you’re abroad and you are being covered the only other thing I’d consider is if you are a resident abroad and not of your US state. I don’t think it’s a major issue but there is always a chance that the malpractice company can say that they don’t cover someone who is a resident of a foreign country. The only way to know for sure is to ask the underwriter to ensure that you are covered in case of malpractice. You can find your own coverage for additional security through companies which have an appetite for international coverage like SVMIC.

Dr Russel, May I know the telehealth company you are employed? I am an NP hoping to do telemedicine while living abroad. TIA.

I’m a nurse midwife, and I’m looking for a telehealth position that would allow me to be in Mexico while working. I came across this post while searching – thanks for the great info here! If anyone knows of a company that is in the scope of women’s health, reproductive healthcare, fertility, etc., that allows providers to be abroad, please let me know!

Hi Dr. Mo,
I looked for the specific CMS guidelines about practicing Telepsychiatry while living abroad, the only thing I found is related to the billing Medicare with the incident that you mentioned in your post. I don’t bill Medicare, I bill State Medicaid only. I am looking for the specific guidelines about State Medicaid in WI, IL, and OH. Do you know where I can find it ? Thanks

As far as I understand it’s Medicare under CMS but haven’t seen anything specific for Medicaid.
https://mhealthintelligence.com/news/doctors-outside-us-cannot-bill-medicare-for-telehealth-court-confirms
The guideline documents are available from your state under their Medicaid program and found under “Resources” or “Provider Resources”.
The easiest thing is to have them send you their billing and poly and procedure documents which can be found online but usually is buried deep in shit.
A better use of your time is to hire an attorney or enrollment specialist for 1 hour of their time and pick their brain about this topic.

Dr. Mo,

I am an FM physician who wants to travel for a year moving from country to country staying no longer than a month at each location then move back to the US at the end of the year. I plan to be licensed in about 3-4 states and ideally would work PRN 20-30 hours per week for a telehealth company based in the US servicing US patients on my own schedule. Is this something that is doable regulation-wise? Are there any telehealth companies that definitely allow this that you know of (looks like Teladoc isn’t one of them anymore)? Thanks so much!

Hi Alex, the article above should be a great resource for you and the other articles I’ve written on the topic and some of my YT and podcast episodes are also great resources. Quite excited for you to take this journey so I hope you get your income figured out.

Hi Dr. Mo,
Would you mind sharing how you started a private practice while abroad? I am in a Headache fellowship currently and will move abroad once I finish, but would like to continue seeing Headache patients from the US as there are a lot of places where there are no Headache physicians. I’m just not sure how to get to the patients. My husband is an REI (infertility/ObGyn) and in a similar situation.

Excited you are thinking of pursuing this. I have a few articles on this site and the YT channel and podcast where I talk about how to start a virtual practice and even a health coaching practice. Those are good keywords to use on this site and my other channels to find that relevant information. If you need legal help there are various legal articles and links to good lawyers on my articles. Headache is one of those perfect niche topics that lends itself beautifully for a remote clinical business model.
If you’re thinking of dealing with insurance and CMS you will likely get a lot of volume of patients but have a terrible administrative burden and headache. If you are thinking of contracting directly with the patient in a direct pay model you will be able to cater your marketing to the exact price point you like.

Hi Dr. Mo,

I am a licensed specialist in Canada. Can I provide virtual care to Americans while I reside in Canada, without a US license? I don’t believe malpractice insurance will be an issue.

I can provide virtual medical care to someone in Canada because neither the US or Canada have rules in place to regulate my care. However, if something bad happens the US licensing board can hold me accountable for the kind of care I provided and I wouldn’t be able to order tests or prescribe medications to someone in Canada.

I work for a CMH clinic as a 1099 independent contractor (not my own clinic). I get paid hourly salary by the CMH, not based on what billing code generates. I see Medicaid/Medicare. My contract does not say anything about “working abroad”. Can I still see these patients ?

Can you still see these patients from abroad, is that the question? You are contracted with CMS if you are seeing CMS patients – what does CMS say about billing them for patients while you’re not located in the USA? You are also contracted with individual insurance companies – what do they say about billing them while you aren’t residing on US territory? The next question to ask yourself, are you covered by your malpractice entity if you are residing overseas while seeing patients in the US.

The question is- if I see the Medicare/Medicaid patients and sign my notes from abroad. But the “actual billing” is being conducted/sent to insurance by the CMS from USA territory. It is not DIRECT billing from me to Medicare/Medicaid as it would be for a private practice.

Would this be OK from Medicare standpoint? My state is OK for Medicaid.

In this case you are conducting a patient-doctor visit while you are abroad. Where and how you bill later wouldn’t affect the Medicare regulations.

GREAT question and even better thought behind it! I thought the same but CMS leaves NO loopholes!

“The VPN won’t affect your billing abilities. If you are audited and asked where you were located when billing CMS they would do their due diligence to find your actual location. There is hardly any money to be made through CMS so the risk doesn’t seem worth it.
The topic remains complicated because some attorneys argue that it’s your residency status while others say it’s simply your location.”

You made this comment earlier in the posts. Have we gotten any updates from attorneys/law whether its “residency status” or simply “your location” on medicare/medicaid patients ?

Hi Dr. Mo,

I am starting my telehealth practice and have learned much from your websites and videos. I have a question: You use PayPal for billing rather than accepting credit cards. Is there a reason for that?

Thank you,

Dr. P

Thank you for the kind words. We just finished the “technology” week in my online course and discussed this in detail. There are many payment gateways you can accept as long as you can protect the patient’s health information. Now, if you are running a cash-based practice you don’t have to comply by HIPAA which many physicians don’t know. Of course, you should do everything possible to exceed HIPAA standards but that’s not hard to do. So, I take Paypal out of convenience and have it in my patient agreement so they know what information is or isn’t being collected on them. When you say “accept a credit card” – you always are using some payment gateway to collect that credit card so unless you have a BAA agreement with that entity the data is still at risk – meaning, that company could use it to market based on the data they collected. So consider that regardless of what kind of payment you access.

https://www.paubox.com/blog/stripe-hipaa-compliant

Dr. Mo, you run an amazing service for the international healthcare community and you are very much appreciated. We thank you.

Very kind of you, thank you. If you think of topics you want to read more about let me know here because I have a draft list of 490 articles, it’s good to know which to publish and which to hold back.

Excellent article. Thank you very much. I’m a new Zealand trained doctor who is moving overseas and planning to offer telemehealth gp appointments through a new Zealand based telehealth company.

I had issues trying to ask the Australian registration authority what was required in this instance. They don’t really have a guideline that covers overseas doctors offering services to overseas patients.

I’ve now also started looking at doing the same from Mexico but there is literally nothing available online. Do you have any idea whether the Mexican medical registration authority requires you to be a registered doctor in Mexico to offer telehealth to people back in your own home country?

As of 2023, most countries don’t have any regulation when it comes to a foreign citizen practicing medicine on their soil virtually with their own patients. I suspect this will change over the next 4-5 years at which point people will find loopholes and those loopholes will then close over the next 5 years. So at least for the next decade it’s likely that you can legally practice medicine while abroad. I’ve written a lot of articles on this and I would also recommend checking out the podcast and YT channel for more guidance on this. To answer your question you need to ask yourself what constitutes the practice of medicine in the country/state you’re in.

Can I see clients via telehealth (mental health) in another state if I am licensed and insured and employed in that state while residing in another state where I do not hold a license?

Some states have enacted policies that allow healthcare providers to practice telehealth across state lines if they meet certain criteria, such as holding a valid license in both states.When the patient and provider are located in different states, it’s called interstate telehealth. This can be more complex from a regulatory standpoint, as both states’ laws may need to be considered. It depends not only on the state you’re in but also the payer (insurance vs CMS). It’s important to understand definition of origination state vs destination state, the state where the patient is physically located during the telehealth appointment vs the state where the healthcare provider is physically located during the telehealth appointment, conversely.

Hello,
I have a license to practice homeopathic medicine from India, and now i am in europe. Is it possible for me to consult my indian clients or to the people even in Europe through telemedicine ?? Please clarify

Hey, what an informative blog. Thanks for doing this. I’m a psychologist and I run a group practice with a physical location in the US. I already basically run it remotely from only a few miles a way, and I see all my patients remotely from my home. My plan is to move to Italy and continue to run my business from there. Would I be able to continue to see my patients through private insurance if my malpractice carrier is cool with it? If not my backup plan would be to remotely see only self-pay clients who are in my home license state. Does this sound reasonable? The other thing I’m confused about is keeping a permanent address in the US. Would likely need to sell my home to make the move happen. How are people keeping their permanent US residence?

Fabulous. Exciting to be able to work remotely. The answer to your question is nuanced but there is lots of great content on this site and in the previous 75 comments that might be of value to you. The YT channel and podcast also address these topics which you can find at the top of this page. Excited for your plans to be in Italy – something I’m considering in the future myself.

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