Telehealth Compliance Checklist Template

Telehealth is the only documentation in medicine with a statutory expiry date, and the current one is December 31, 2027. This checklist is built for the practice rather than the encounter. Section A is an audit table of the eight elements every telehealth note should contain — patient location, clinician location and licensure, modality, consent and identity, others present, limitations of the remote exam, correct place of service, and the payer-appropriate modifier — for ticking through an audit sample. A review-cadence field suggests quarterly review, and again before January 1, 2028.

Section B walks through what changes on January 1, 2028, with an "affects us" decision per row: geography reverts to rural facilities except for behavioral health; physical therapists, occupational therapists, speech-language pathologists and audiologists can no longer furnish Medicare telehealth; audio-only narrows to behavioral health, and only where the clinician is capable of audio-video and the patient is not capable of it or does not consent; the behavioral health in-person requirement takes effect; and RHC/FQHC billing of non-behavioral services under G2025 ends. It also flags two changes that already took effect on January 1, 2026 and are easy to miss because they loosened rather than tightened: telehealth frequency limits were permanently removed for subsequent inpatient, nursing facility and critical care consultations, and direct supervision may now be met through real-time audio-video. Optimized for use with Sully.ai's AI medical scribe, it helps streamline note-taking and improve clinical efficiency.