D.C. Telemedicine Laws: Licensure, Prescribing, Coverage

The District of Columbia requires a District license, or compact authority, for telehealth to a patient located in the District, with a narrow continuity-of-care allowance added in 2024. D.C. Code § 3-1201.05, enacted by the Health Occupations Revision General Amendment Act of 2024 (D.C. Law 25-191, effective July 19, 2024), is the general telehealth statute for every licensed profession. The Board of Medicine's telemedicine rule, 17 DCMR § 4618, adds physician duties, including consent. The Telehealth Reimbursement Act of 2013 requires coverage parity for commercial plans and Medicaid but sets no commercial rate.

Licensure: a District license, with a 120-day continuity window

D.C. Code § 3-1201.02(7)(A)(v) defines the practice of medicine to include a physician located outside the District rendering a documented medical opinion on, or treatment to, "a person within the District" through transmission of medical data "by electronic or other means." Section 3-1205.01 requires a District license "except as otherwise provided in this chapter," and 17 DCMR § 4618.1 applies that rule to telemedicine for "a patient located within the District of Columbia."

Under § 3-1201.05(e), which covers every profession, and except for compacts and reciprocity agreements preserved by subsection (f), a practitioner without a District license, registration, or certification "may not provide a telehealth service to a client or patient physically located in the District" unless the two have an existing practitioner-patient relationship and either the patient is temporarily present in the District, or the patient is a District resident and the services "do not exceed 120 days or a longer period of time as determined by the Mayor through rulemaking." New patients fall outside it.

Section 3-1205.02 lists other exemptions from the licensure requirement. Section 3-1201.05(e) names only compacts and reciprocity agreements as exceptions to its telehealth rule, so whether these older exemptions also cover telehealth is not settled. They include:

• emergency care;
• an individual licensed, registered, or certified in a state who, for a limited period of time, is called in professional consultation about a specific patient in the District, provided the care or consultation is "in affiliation with a comparable health professional" licensed in the District;
• a professional authorized to practice in a state adjoining the District who has no office in the District, registers with the appropriate board before practicing, and whose state grants District licensees the same privilege. Subsection (b) bars such a professional from seeing patients in a District licensee's office or otherwise circumventing the chapter.

The District is a full Interstate Medical Licensure Compact member under D.C. Law 22-109, effective June 5, 2018. It is a full PSYPACT member under D.C. Law 23-190, effective March 16, 2021, and a full Physical Therapy Compact member. Its Counseling Compact membership is pending, meaning enacted but not yet live. It is not in the Nurse Licensure Compact. See our cross-state licensing tracker.

Prescribing: evaluation first, then the PDMP and registration duties

Section 3-1201.05(b) lets a practitioner-patient relationship be established through telehealth under the appropriate standard of care, but lets the Mayor require, by rule, additional steps for specific professions, "including an initial in-person physical examination." We found no such rule. For physicians, 17 DCMR § 4618.3 requires a patient evaluation "to establish diagnoses and identify underlying conditions or contraindications" before treating or prescribing, except for interpretive services. Absent a prior in-person interaction, § 4618.4 says the physician "may use real-time telemedicine" to establish the relationship and perform the evaluation. A separate DC Health pharmacy rule points the other way for some encounters. Under 22-B DCMR § 1300.8, last amended effective December 22, 2006, "an internet based or telephone consultation or questionnaire evaluation is not adequate to establish a valid patient-practitioner relationship," except in a documented medical emergency, in an on-call or cross-coverage arrangement, or where care is rendered in consultation with another practitioner who has an ongoing relationship with the patient and has agreed to supervise the treatment. Under § 1300.7, a pharmacist may not dispense a prescription the pharmacist knows was issued without a valid relationship. The rule predates § 3-1201.05(b) and § 4618.4, and neither the rule nor DC Health guidance explains how they fit together; prescriptions based only on a telephone call or a questionnaire carry the clearest risk.

Section 3-1201.05(d) requires a telehealth prescriber to comply with the Prescription Drug Monitoring Program chapter and "all District or federal laws and rules related to prescription and controlled substances." Duties that follow include:

• PDMP registration. Under D.C. Code § 48-853.03b, practitioners permitted to prescribe controlled or other covered substances must register with the program; boards may not renew a license without proof.
• PDMP query. Under § 48-853.03c(a), a prescriber must query the District database "before initiating a new course of treatment or therapy for a patient in the District of Columbia that includes prescribing an opioid or benzodiazepine for more than 7 consecutive days, and every 90 days thereafter while the course of treatment or therapy continues." Subsection (c) lists five exceptions: hospice or palliative care; an inpatient hospital admission or discharge; a nursing home or residential care facility using a sole-source pharmacy; a database outage from technological or electrical failure or natural disaster; or an emergency or disaster preventing access, documented in the record.
• District controlled substance registration. D.C. Code § 48-903.02(a) requires registration by every person who dispenses a controlled substance "within the District of Columbia," § 48-901.02(7) defines dispensing to include prescribing, and § 48-903.02(e) requires a separate registration for each principal place of professional practice. DC Health's letter to registrants says anyone who "prescribes" controlled substances in the District must register, in addition to DEA registration. DC Health's application instructions list "Out-of-state practitioner" among the status changes that require a registrant to notify the Pharmaceutical Control Division and return the registration. We found no statute, rule, or DC Health guidance on whether a prescriber located outside the District needs, or can hold, a District registration to prescribe by telehealth to a patient in the District. Confirm with the Pharmaceutical Control Division before prescribing.

We found no District statute capping opioid days' supply and no District mandate for electronic prescribing of controlled substances. Medicare Part D separately requires at least 70 percent of Part D Schedule II–V prescriptions to be electronic under 42 CFR 423.160, subject to exceptions and waivers.

Federal law adds a separate layer for controlled substances. Under the temporary rule DEA and HHS published December 31, 2025 (90 FR 61301), which runs through December 31, 2026, a DEA-registered practitioner may prescribe Schedule II–V controlled substances after a real-time audio-video telemedicine encounter without a prior in-person evaluation, when the rule's other conditions are met; audio-only encounters qualify only for Schedule III–V narcotic medications approved by the FDA to treat opioid use disorder. See our guide to federal telehealth laws.

Consent: required of physicians and in Medicaid

Section 4618.2 holds physicians to in-person standards of care, including "obtaining and documenting patient consent, except when providing interpretive services," adequate records, and HIPAA and HITECH compliance. The rule also requires current technology capable of meeting the standard of care (§ 4618.7), adequate security (§ 4618.8), documenting all relevant communications, including email (§ 4618.9), and informing patients of "alternate forms of communication" for urgent matters (§ 4618.10). Chapter 46 governs physicians only. For every District-licensed profession, § 3-1201.05(c)(2) applies existing rules on identity verification, documentation, informed consent, confidentiality, privacy, and security to telehealth.

DC Medicaid adds its own requirement. Under 29 DCMR § 910.5(c), a beneficiary must give written or verbal consent to receive telemedicine in lieu of in-person care, and § 910.6(d) requires the provider to document it. DHCF guidance requires a detailed service note for verbal consent.

Medicaid: audio-only allowed, services listed

D.C. Code § 31-3863 requires Medicaid to "cover and reimburse for healthcare services appropriately delivered through telehealth if the same services would be covered when delivered in person." Under 29 DCMR § 910.2, as amended effective November 5, 2021, telemedicine means "two-way, real time interactive video-audio communication or audio-only communication." Distant-site reimbursement under § 910.11 covers only evaluation and management, consultations requested by an originating-site provider, behavioral health services, and speech therapy. Section 910.29 bars reimbursement for store-and-forward and remote patient monitoring, and § 910.21 bars it for incomplete services.

DHCF guidance applies across its programs, including managed care and the DC Health Care Alliance, and pays fee-for-service telemedicine "at the same rate as in-person consultations." Claims carry modifier GT for video-audio or 93 for audio-only.

Private insurance: coverage parity, no rate floor

D.C. Code § 31-3862(a) bars a health insurer offering a health benefits plan in the District from denying coverage "on the basis that the service is provided through telehealth if the same service would be covered when delivered in person." Subsection (b) requires the insurer to "reimburse the provider for the diagnosis, consultation, or treatment" delivered through telehealth, without setting a rate. Subsection (d) lets insurers impose deductibles, copayments, or coinsurance that do not exceed the in-person amount, and subsection (e) bars telehealth-only annual or lifetime dollar maximums.

Two allowances limit the mandate. Insurers need not reimburse telehealth services not covered under the plan, or providers who are not covered providers (§ 31-3862(c)). They may use utilization review to judge whether telehealth is appropriate, decided "in the same manner" as for in-person care (§ 31-3862(f)). The definition in § 31-3861(4) covers "interactive audio, video, or other electronic media" and excludes only email and fax. D.C. Law 23-149 removed the former audio-only exclusion, effective December 3, 2020. The statute has no sunset. See our reimbursement guide.

What to watch

First, D.C. Law 26-170 (B26-0356), effective August 20, 2026, rewrites § 31-3862.01 to cover remote monitoring of blood pressure and blood glucose during pregnancy and up to 12 months postpartum. It applies only once its fiscal effect is included in an approved budget, and the Code lists that section as not funded. Second, whether the Mayor uses § 3-1201.05 to lengthen the 120-day window or require an initial in-person exam for particular professions. Third, the registration process § 44-502.01 directs DC Health to create for virtual provider networks and virtual telehealth platforms operating in the District; new entities must register before operating. Fourth, when the Counseling Compact goes live. For background, see how state telemedicine laws work.