Connecticut’s Revised Telehealth Law

During the final hours of the Connecticut legislative session, the state Senate passed House Bill 5198, solidifying changes to the state’s telehealth law, sending the bill to the Governor for signature. This bill adopts some of the temporary pandemic-era changes to the telehealth law, such as permitting audio-only telehealth and prohibiting insurers from paying less for telehealth than in-person services.

Telehealth has become an essential aspect of healthcare delivery, prompting states like Connecticut to make certain pandemic-era changes permanent.

Key Changes to the Telehealth Law at Conn. Gen. Stat. §19a-906 (Revised Law)

  • The Revised Law now permits audio-only telehealth, which the prior version of the statute specifically excluded.
  • Insurers must maintain payment parity between telehealth and in-person services.
  • The Revised Law expands the definition of telehealth providers to include all licensed healthcare providers under Chapter 20 of the general statutes.
  • Out-of-state provider flexibilities have been significantly reduced. Only mental health providers licensed in another state and adequately insured may offer telehealth services in Connecticut after registering with the Department of Public Health (DPH) and completing the licensure application process. See discussion below.
  • Patients may opt to pay providers directly at a mutually agreed upon amount for telehealth services, regardless of coverage. See discussion below.
  • Telehealth services can be delivered by a Connecticut-licensed provider from any location to a patient in any location subject to applicable state and federal laws, including state licensing laws. See discussion below.

Out-of-State Providers

Previously, temporary pandemic laws allowed most out-of-state providers to offer telehealth services in Connecticut under the DPH Commissioner authorization.  That is no longer the case.

Likely due to the demand for mental health services in Connecticut, the Revised Law permits specific out-of-state mental health providers to register with DPH to offer telehealth services in Connecticut until June 30, 2025. Registrants must apply for licensure within 60 days of registration and complete credentialing related to the application within 60 days of applying for licensure.  DPH must process all licensure applications within 45 days.

This provision is effective for one year, with DPH reporting outcomes to the Legislature, likely informing future revisions.

Payment for Telehealth Services

The pandemic-era temporary laws, while laudably trying to protect patients from being overcharged for telehealth services, did not explicitly allow patients to pay privately for care.  Fortunately, the Legislature addressed that oversight in the Revised Law.

Additionally, the Revised Law provides more detail on providers’ obligations related to coverage determinations and communicating costs.  Many providers will already be in compliance with some of these requirements as they are similar to those under the federal Good Faith Estimate law that took effect in January 2022.  Below is the approach that providers need to take:

  • Determine if the patient has insurance coverage for the telehealth service;
    • The Good Faith Estimate law already requires this step.
  • If the patient has coverage, determine if the patient wants to use available coverage or if the patient wants to pay out-of-pocket for the service.
    • The Good Faith Estimate Law does not require this directly, but if a patient decides to pay out of pocket, the Good Faith Estimate law requires the delivery of a good faith estimate.
    • If the patient wishes to use coverage for the telehealth service, the provider must accept the amount the insurer reimburses plus any coinsurance, copayment or deductible that the patient may owe.
    • If the patient does not want to use their coverage, the patient must explicitly elect to pay the provider directly and the provider and patient must mutually agree on the cost.
  • If the patient has no coverage, the provider can charge only:
    • The amount Medicare would pay for the telehealth service;
    • An amount mutually agreed to by the patient and provider; or
    • An amount determined by a sliding fee scale or other method if state or federal law requires the provider to offer such financial assistance.
  • Disclose the cost to the patient.
    • The Good Faith Estimate law requires this for all self-pay or uninsured patients.
    • The Good Faith Estimate law does not currently require good faith estimates for patients using insurance. Consider notifying the patient generally that their cost will be any applicable coinsurance, copayment or deductible.  Provide such details if possible; if not, instruct the patient to contact their insurer for details.

Service Delivery Location

The Revised Law allows providers to deliver telehealth services from any location to patients in any location, provided they comply with applicable laws. Importantly, most states do not permit providers to deliver telehealth services to patients in that state unless they are licensed there.  In other words, before a Connecticut-licensed provider can provide telehealth services to a patient located in another state, the provider must research the rules in that other state to determine its licensure requirements.


While the Revised Law adopts many of the provisions in the temporary pandemic laws, it is important to understand the above differences and to implement appropriate compliance mechanisms.  Finally, remember that the Revised Law is the state’s law on telehealth and that other payer-level telehealth requirements may apply, like those under Medicaid.