Telehealth in Maryland (2025): What Changed, What It Means, and What to Watch
Last updated: September 19, 2025 • Author: M.I.N.D. Health and Wellness
This article is for informational purposes only and does not replace your plan documents or medical/legal advice. Policies evolve—always confirm your specific coverage.
1) What is telehealth?
“Telehealth” generally means receiving health care from a licensed provider using technology when you and your provider are in different places. That usually involves live video + audio (think: a secure Zoom-style visit), sometimes audio-only telephone when appropriate, and—depending on the program—aspects like remote patient monitoring or sending information asynchronously for review. In Maryland law, “telehealth” is defined in the Insurance Article and related statutes.
2) Parity 101: coverage parity vs. payment parity
Coverage parity means your plan covers a service if it’s done via telehealth when that same service is covered in person. Payment parity means the rate paid for a telehealth service is the same as the in-person rate (same basis/same rate) for that service, assuming it’s appropriately delivered via telehealth. Maryland’s 2025 law addresses both concepts for many plans.
3) Maryland’s 2025 law at a glance
What passed? The Preserve Telehealth Access Act of 2025 (SB 372 / HB 869) removed prior “sunset” dates and made telehealth access more permanent in Maryland.
- Audio-only telehealth (phone visits that deliver a covered, billable service) remains included in Maryland’s definition of telehealth beyond prior sunset dates.
- Insurers (including Medicaid and most commercial carriers regulated by the state) must reimburse telehealth services on the same basis and at the same rate as in-person services when appropriately delivered via telehealth.
- Effective date: Approved by the Governor as Chapter 481; effective in 2025.
The Maryland Health Care Commission (MHCC) supported continuing audio-only options (especially for behavioral health) and payment parity in its 2024 recommendations to the legislature, which preceded the new law.
Important: While Maryland’s law is strong, certain plan types (e.g., some self-insured employer plans governed by ERISA) may have different obligations. Always verify your specific plan. (See the “Caveats” section.)
4) How big insurers appear to be responding in Maryland
Below is a high-level summary based on what’s publicly posted or documented. Policies can lag behind new laws, and details vary by plan type. Use this as a starting point and confirm with your insurer and provider.
| Insurer | What public materials indicate | Watch-outs |
|---|---|---|
| CareFirst (BCBS in MD) | Provider alerts and prior guidance acknowledged state mandates for audio-only and parity when applicable. Earlier notices described paying appropriate audio-only calls at the same rate as in-person where mandated; Maryland’s 2025 Act removes sunsets and cements that mandate. | Manuals/web pages may lag; verify current coding (e.g., modifiers 95/GT, POS 02/10), and confirm whether your specific plan is fully-insured (subject to state law) vs. self-insured (often different rules). |
| Cigna | Cigna’s Virtual Care Reimbursement Policy states covered virtual services are reimbursed at 100% of face-to-face rates when all requirements are met; state/federal mandates and benefit design can supersede. This aligns with MD’s parity requirements for applicable plans. | Policy pages are national and may not reflect every state update instantly. Confirm audio-only requirements and any code-specific limits for behavioral vs. somatic care. |
| Aetna (incl. Aetna Better Health of MD) | Medicaid policy documents in Maryland outline synchronous video telehealth and certain audio-only allowances with required modifiers. Commercial plan pages are less specific publicly, but the MD law requires parity for applicable plans. | Check your plan: Medicaid vs. commercial have different manuals; audio-only allowances can be code- or scenario-specific. |
| UnitedHealthcare & others | Public MD-specific parity statements may be limited or in flux. Expect updates as carriers align manuals with the 2025 law; watch for provider bulletins. The statute itself is controlling for fully-insured MD plans. | Watch the fine print: fully-insured vs. self-insured, and code-level appropriateness (especially for audio-only in somatic care). |
Bottom line: For most Maryland-regulated commercial plans and Medicaid, parity (same basis/same rate) now applies to appropriately delivered telehealth—including audio-only. But your experience can still vary due to plan design, coding, and how quickly insurer systems update.
5) For patients: what to expect & questions to ask
- Expect parity for covered services on applicable Maryland plans: telehealth paid like in-person, with comparable cost-sharing. Confirm with your insurer for your specific visit type.
- Audio-only is permissible (when it delivers a billable covered service), which helps if you lack broadband or a device for video.
- Ask these 5 questions before your visit:
- Is my visit covered via telehealth (video or audio-only) under my plan?
- Will it be billed and reimbursed at the same rate as in-person?
- Which codes/modifiers will be used (e.g., 95/GT; POS 02/10)?
- Is my plan fully-insured (state-regulated) or self-insured (ERISA)?
- Are there specialty-specific restrictions (e.g., for somatic exams)?
- If something looks off on your EOB (e.g., lower allowed amount for a telehealth code, unexpected denial), contact your insurer and provider billing team. Reference Maryland’s 2025 law and request reprocessing if applicable.
6) For providers: coding, contracts & documentation tips
- Know your payers & plans. Parity applies broadly, but self-insured employer plans may differ. Align expectations and verify benefit design for common CPTs.
- Use correct POS & modifiers. Common patterns include POS 02/10 and modifier 95 or GT (varies by payer policy). Cigna notes parity when “all billing requirements are met.”
- Document telehealth appropriateness. Maryland’s statute keys on services “appropriately provided via telehealth,” including audio-only for covered scenarios. Behavioral health is often straightforward; somatic visits may require more nuance.
- Watch for manual updates. Expect phased bulletins/policy refreshes from major carriers as they harmonize with the 2025 Act. Keep a shortlist of sources to check quarterly.
7) Caveats: what’s still fluid (and why)
Even with a strong law, real-world execution varies:
- Implementation lag: Insurers update claims engines, edits, and manuals on cycles—denials/mis-pricing can happen until systems catch up.
- Self-insured plans: Some employer plans may not be subject to every state insurance mandate. Confirm plan type in HR documents (SPD/EOC).
- Service appropriateness: Audio-only is protected but not a fit for every clinical scenario; MHCC recommends broad access for behavioral health and conditional use for somatic care.
- Federal changes: Medicare rules (separate from this state law) influence market behavior. Always differentiate Medicare, Medicaid, and commercial policies.
8) Quick FAQ
Does Maryland now require insurers to pay telehealth at the same rate as in-person?
Yes—for Maryland-regulated plans and Medicaid, telehealth services must be reimbursed on the same basis and at the same rate as in-person when appropriately delivered, and audio-only is included; the 2025 Act removed prior sunsets. Always confirm your specific plan.
Is audio-only permanently allowed?
Yes. The definition of telehealth explicitly includes audio-only phone visits that deliver a billable, covered service—beyond earlier sunset dates.
Will my co-pay/coinsurance be the same for telehealth?
Generally yes when parity applies, but cost-sharing is driven by your plan design (deductibles, copays). Always check your EOC/EOB.
What if my insurer pays less for my telehealth visit?
Ask your provider’s billing team to review the claim coding (modifiers/POS) and cite Maryland’s 2025 law. If you’re on a fully-insured Maryland plan, you can also file a complaint with the Maryland Insurance Administration if needed.
9) Sources & further reading
- Maryland General Assembly – SB 372: Preserve Telehealth Access Act of 2025 (bill page & chaptered text).
- Maryland General Assembly – HB 869: Preserve Telehealth Access Act of 2025 (bill page).
- Maryland Insurance Article §15-139 (telehealth definition within Insurance Code).
- Maryland Health Care Commission – 2024 Telehealth Studies & Recommendations.
- Center for Connected Health Policy – Maryland state telehealth law tracker (updated 2025).
- Cigna – Virtual Care Reimbursement Policy (national policy indicating 100% parity when requirements met; plan/mandate caveats).
- CareFirst – prior provider alert referencing audio-only & parity under Maryland mandate.
- UnitedHealthcare – general telehealth coverage policy updates (state compliance pending).
Reminder: Information above reflects public sources as of the date at top and may change. Always verify with your specific insurer and plan documents.
