Audio-only telehealth occupies an odd middle ground in policy conversations. It is not video telehealth, and it is not quite a traditional phone call either — it sits in its own regulatory category that has been treated inconsistently across payers and time periods.
Why audio-only is treated differently
Video-based telehealth has generally been the default assumption in telehealth policy, with audio-only visits historically viewed as a more limited substitute, largely because audio-only encounters lack the visual component that some regulators consider important for certain types of evaluation. This has meant that audio-only coverage has often lagged behind video coverage in scope, even during periods when telehealth flexibilities broadly expanded.
The federal baseline under Medicare
Medicare has extended coverage for audio-only telehealth services for a defined, though periodically revisited, set of circumstances, particularly for certain behavioral health services and for patients who lack the technology or capability for video visits. This audio-only coverage has generally been narrower than video-based telehealth coverage, and its continuation has depended on periodic extensions rather than being a fully permanent fixture of the program.
Audio-only telehealth coverage has expanded significantly, but it remains narrower and less settled than video-based coverage.
Variation across payers and states
Outside of Medicare, audio-only coverage varies considerably. Medicaid programs, which are administered at the state level, differ in which audio-only services they cover and under what conditions, and commercial payers set their own policies that may or may not track federal Medicare guidance. A service reimbursed for an audio-only visit under one payer may not be reimbursed the same way under another.
Licensure implications remain unchanged
Regardless of modality, the licensure logic for audio-only visits generally mirrors that of video telehealth: the physician typically needs to be licensed in the state where the patient is located at the time of the call, not just where the physician is based. Modality does not usually change the underlying licensure requirement, even though it affects reimbursement and coverage.
Audio-only telehealth policy has shifted multiple times in recent years and continues to be revisited by regulators. Requirements vary by state and change over time — always confirm current requirements directly with the relevant state board or agency before making a compliance decision.