One of the most commonly skipped steps in telehealth workflow is also one of the most important from a compliance standpoint: verifying and documenting where the patient is physically located at the start of every session. It takes less than thirty seconds and it protects your license, your documentation, and your billing in ways that matter significantly if you are ever audited.
Why Patient Location Is Not Optional
In telehealth, care is legally considered to occur where the patient is located, not where the provider is located. That means the patient’s physical location at the time of the session determines which state’s licensing requirements apply to the visit. If you are licensed in one state and your patient is sitting in another state when they connect, you may be practicing without a license in that second state, regardless of how long they have been your patient or where they normally live.
This is a real compliance risk, not a theoretical one. Patients travel, spend extended time at second homes, attend college in other states, or work remotely from different locations than their home address. A patient whose records show a home address in your licensed state may be connecting from a different state on any given day.
Documenting location at the start of every session creates a record that demonstrates your awareness of where care was delivered. If a licensing board, payer, or auditor ever questions your cross-state practice, that documentation is your evidence of compliance.
When to Ask and How to Ask It
Make patient location verification the first thing that happens after you admit the patient from the virtual waiting room and greet them. Keep it brief and matter-of-fact:
“Before we get started, can you confirm where you are located today?”
That is it. You do not need to explain the licensing rationale to every patient. Most will answer without giving it a second thought. For patients who ask why you are asking, a simple explanation works well: “We ask for everyone’s location at the start of each virtual visit to make sure we are following the right care guidelines for where you are.”
What to Document
Record the patient’s location in your session note as part of your standard documentation. Include:
- The city and state where the patient was located at the time of the session
- The date and time of the session
- A note that location was verbally confirmed
Some practices add a location field to their pre-visit intake forms sent through SecureVideo’s e-documents, asking patients to confirm their current location before the appointment. This creates a written record before the session begins and can prompt patients to disclose if they are traveling before you discover it mid-visit.
What to Do When the Location Is a Problem
If a patient confirms they are in a state where you are not licensed, you have a clinical and ethical decision to make. For most visits, the right answer is to conduct the session if it is a follow-up for an established patient in a non-emergency situation, document the location, and work on obtaining licensure in that state if the patient will regularly be there. For new patients in unlicensed states, the correct response is to decline the session and refer the patient to a provider licensed in their state.
For behavioral health providers managing patients in acute distress who happen to be in an unlicensed state, the calculus is different. A patient in crisis should not be turned away because of a location issue. Document the clinical necessity, complete the session, and consult with your licensing board and malpractice carrier promptly.
Build It Into the Standard Workflow
The simplest way to make patient location verification consistent is to put it on your session opening checklist alongside identity verification and consent confirmation. Every session, every patient, every time. The thirty seconds it takes is a small investment against a risk that can have serious professional consequences.
SecureVideo’s HIPAA-compliant platform provides the secure, auditable session environment that supports your compliance documentation across every visit. Learn more about SecureVideo or start a free trial today.