A frequently asked question on our physician communities is the question of whether you can practice telemedicine from abroad, and what opportunities exist to do so. Many times, doctors have family reasons to move out of the country for a period of time, such as a spouse that gets a job abroad or sick family members living abroad. Not wanting to give up their ability to practice medicine or the income associated with it, they wonder if they can find a telemedicine side or main gig that will allow them to do this. Below, we’ll cover the rules and other things that physicians should know about practicing telemedicine when not physically located in the United States.
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Practicing telemedicine from outside of the United States
The theoretical ability to practice medicine from anywhere through telemedicine opens up a world (literally) of opportunities for doctors looking to make a change or who have reasons to live outside of the United States. While it is possible, it’s important to know that it may not be as easy as it sounds, as there are several rules and regulations about practicing from abroad.
While it may sound silly to you that you’re allowed to practice telemedicine in your pajamas in your home, but not at a resort overseas, when you’re doing the exact same thing with the same knowledge base, it’s important to know that this is more complicated than it seems.
You are not allowed to bill Medicare (and many other insurances) for telemedicine from abroad
This is the most important thing to know when exploring these options. Physicians cannot bill Medicare if they are physically outside of the United States when they complete a telemedicine encounter with a patient.
The rules may be different for private insurance companies and Medicaid, but these are case by case rules that you will have to know prior to determining which patients you can see while abroad. For example, some insurance companies may permit billing from abroad, but you’ll have to check with each insurance company. Similarly, Medicaid is regulated on the state level, so some states may allow it.
Therefore, while it’s theoretically possible to have an insurance based telemedicine practice while living abroad, know that it will come with a lot of nuances and you’ll have to figure out beforehand if you’ll have enough volume in your insurance based telemedicine practice. You’ll also want to stay on top of regulations in each state and with each insurer in case these things change.
Most (but not all) telemedicine companies will not allow you to practice telemedicine from abroad
While every telemedicine company has its own rules, many insurance based telemedicine companies will not hire you for the reasons stated above with complications billing for your encounters when conducted from outside of the United States.
Of course, these days, there are many cash pay telemedicine companies popping up, which obviates that barrier, and these companies may be more okay with hiring you no matter where you’re working from. Additionally, as the number of telemedicine companies increases, there are more telemedicine companies where the target patient population is not Medicare patients. In these cases, assuming they have enough contracts with companies, individuals, or payors that do not care where the services are provided, they may be willing to hire you.
There may be other hurdles as well, issues accessing the electronic medical records system that they use through a VPN, such as requirements for a DEA (see below, but you can’t prescribe controlled substances), the hours they need not being compatible with your time zone, and malpractice requirements, just to name a few.
If you’re looking for these companies, it makes sense to start your search by looking for cash pay telemedicine companies. Another alternative may be to sign up for a telemedicine network that will source different telemedicine visits for you based on your situation. In these situations, you credential with the network and they will find visits for you across their partners that fit your state licenses, expertise, and in this case, where you live.
You can always start your own non-insurance based telemedicine company or health related business with its own rules
We love the quote that the best way to predict your future is to create it. If it’s not easy to practice in your niche via someone else, create your own telemedicine service that allows you to work within the confines of the rules. As long as you have a valid license to practice medicine in the states that you’re seeing patients in and those states allow you to be abroad when engaging in patient care, you may be able to do this.
The easiest situation where this seems feasible would be to have a cash pay practice. It may take some time to build this out and you may require some marketing, branding, and networking, but once you have a steady patient base, you could open up a steady referral stream.
Additionally, you don’t necessarily have to practice as a physician. Some physicians instead engage in “health coaching,” and create cash pay businesses in this realm, or do virtual education, etc. Since this isn’t telemedicine, it’s beyond the scope of this article, but important options to consider as well.
Check with your malpractice insurance to insure coverage
Every malpractice carrier will have different rules about coverage, so you’re going to want to make sure that yours is through a company that allows you to practice from abroad.
Learn more about malpractice coverage for physicians.
Related PSG Resource: We have partnered with doctor owned AutonomyMD to provide physicians access to an affordable, subscription based malpractice insurance. Physicians can be located anywhere for telemedicine, as long as they are licensed in the state where the patient is located. For $150/month on an annual contract, get a PSG special perk of 30 visits (up from 25) per month and a HIPAA compliant app to document visits. Start a micropractice and scale affordably. Sign-up through our partnership form to receive the exclusive PSG perk.
Know that you won’t be able to prescribe controlled substances with your DEA number while abroad
This applies to US based physicians who are traveling outside of the US on vacation too, so there’s probably no getting around this one.
Remember the practical concerns about EMR and VPN access, internet connections, and more when it comes to doing telemedicine abroad
In addition to the DEA issue above, also remember that there may be logistical issues when doing telemedicine abroad. You’ll want to be in a time zone that allows you to see patients at hours that are amenable to the schedule you want to have when living abroad. For example, if you’re not willing to work evenings or overnight, that may remove some regions from consideration.
Similarly, you’re going to need to base yourself out of a region that has a stable and strong internet connection.
Even assuming these things are fine, know that you will need to access the electronic health record system, and some EMRs will block access to foreign IP addresses. While VPNs can solve this, you still don’t want to get in trouble if you are violating any rules, so it’s important if you’re working with a company or contracting with a particular health system or organization to ensure that this is okay.
Also make sure that you abide by HIPAA and data privacy laws both where you’re living and in the United States, and have a lawyer review any wording that you’re using in relation to the services you provide if you create your own practice. Make sure you have appropriate technology. Lastly, make sure that you are familiar with the work visa and tax requirements when working abroad.
Get enough medical licenses to ensure volume
Knowing that insurance, state, or malpractice regulations may preclude you from seeing certain patient populations, you’re going to want to create as wide of a net as possible for potential patients. Get licensed in states that telemedicine companies tend to want, and ones that are friendly towards physicians working from abroad.
Learn more about multi state licensing for physicians.
Related PSG Perk: BlueShift Licensing offers concierge licensing assistance and does the majority of the work so you can focus on other aspects of your micropractice. The founder, Jen, is highly experienced and has helped so many physicians and companies get their licensing completed efficiently. They do licensing in all US states. Email Jen at jen@blueshiftlicensing.com to get started. Make sure to mention PSG for 10% off of licensing and credentialing related services through our advertising relationship!
Conclusion
Working abroad as a telemedicine physician providing services in the United States is complicated, but can be done. As with most things, when there’s a will, there’s a way, but it’ll require navigating many logistical issues in regards to billing, DEA, malpractice, taxes, privacy, VPNs, and more. You will want to check with the relevant parties to ensure that you’re doing everything by the books, because the last thing you want is to make plans to move abroad, only to find out that you can’t practice the way that you planned due to a technicality that you overlooked.
Additional resources for physicians interested in telemedicine
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