Medicaid and Telehealth in Pennsylvania: Which Pandemic Rules Survived

Pennsylvania's Medicaid program locked in some of its emergency telehealth flexibilities — but others quietly expired. Here is where things stand.

What the Emergency Unlocked

When COVID-19 arrived in Pennsylvania in early 2020, the state's Medicaid⁴ program moved fast. The Department of Human Services ↗ issued emergency authorization for a broad expansion of covered telehealth¹ services, waiving restrictions on originating site⁶s, opening up audio-only visits, and extending virtual care into behavioral health, primary care, and chronic disease management at a scale the state had never attempted. For many enrollees — particularly those in rural counties and those managing serious mental illness — it was the first time telemedicine felt genuinely accessible rather than theoretical.

The core logic was simple: if the state's roughly 3.7 million Medicaid beneficiaries could not safely visit a clinic, the clinic would have to come to them remotely. Pennsylvania's Department of Human Services leaned on federal guidance from the Centers for Medicare and Medicaid Services, which itself granted states sweeping flexibility to reimburse telehealth visits at rates comparable to in-person care. The rural care gap⁵, long documented in places like Centre County and the communities surrounding Lewistown Hospital, suddenly had a temporary workaround — one that providers and patients alike came to depend on quickly.

What Survived, and What Didn't

The end of the federal public health emergency in May 2023 forced a reckoning. Not all flexibilities were equal, and Pennsylvania had to decide which ones to codify, which to extend under state authority, and which to let lapse.

Several key provisions did survive. Behavioral health counseling³ delivered via telehealth — including substance-use treatment services — was made permanent for Pennsylvania Medicaid enrollees. That matters: behavioral health had been one of the clearest success stories of the pandemic expansion, with providers reporting that remote access reduced no-show rates and helped connect patients who faced transportation barriers or stigma around walking into a facility. The Department of Human Services confirmed that these services would continue to be reimbursed for both video and audio-only formats, a significant accommodation for patients without reliable broadband access.

Federally Qualified Health Centers retained the ability to bill for telehealth visits as an encounter, rather than being pushed back to the narrower billing rules that existed before the emergency. That protection mattered disproportionately for community-based facilities serving West Philadelphia, North Philadelphia, and lower-income pockets of Bucks County and Allentown — places where Medicaid enrollment is high and in-person infrastructure is often strained.

What did not survive cleanly was the unrestricted flexibility around originating sites for some specialist visits, and some of the broader waivers for remote monitoring equipment reimbursement. Pennsylvania's Medicaid program reverted to tighter rules around where a patient must be located when receiving certain services, limiting the anything-from-anywhere model that had briefly become the norm. Providers in rural areas, including those affiliated with Trinity Health facilities, noted that certain specialist telehealth consultations became harder to bill following the rollback.

The Broadband Problem Underneath It All

Any honest accounting of Pennsylvania's Medicaid telehealth landscape has to include the broadband barrier². Audio-only visits were preserved in part because the state's own data made clear that a video-first requirement would effectively exclude a significant portion of Medicaid enrollees — particularly older adults and those in rural townships where high-speed internet remains inconsistent.

Any honest accounting of Pennsylvania's Medicaid telehealth landscape has to include the broadband barrier.

AARP Pennsylvania ↗ and advocacy groups tied to the Pennsylvania State Grange have each flagged the gap: telehealth parity on paper means little if the infrastructure to use it does not exist. The state has made broadband investment a stated priority, but closing the gap between policy and connectivity is measured in years, not months.

Navigators and enrollment assisters have also noted that many Medicaid beneficiaries still do not know which services are available virtually. The coverage exists. Awareness remains the weaker link.

1. Early 2020Pennsylvania DHS issues emergency telehealth authorization under COVID-19.
2. 2020–2023Broad Medicaid telehealth flexibilities in effect under federal PHE.
3. May 2023Federal public health emergency ends; state-by-state retention decisions begin.
4. Post-2023Pennsylvania locks in behavioral health telehealth; rolls back some specialist flexibilities.

The Upshot

Pennsylvania's Medicaid telehealth story after the pandemic emergency is one of partial consolidation — real gains preserved in behavioral health and federally qualified health settings, meaningful rollbacks in others. The state locked in more than it gave back, which is a fair summary of where most states landed. But the patchwork nature of what remained leaves both providers and patients navigating a system that is more expansive than 2019 and less consistent than 2021.

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