This might be more of a semantical issues. We don't consider mychart messages "telehealth visits," so I wonder if that's the difference? That is, patients send the providers all kinds of mychart messages (which first go to the nurses who help to clarify and ask further questions before forwarding, if necessary) to report new symptoms to their provider, ask for an appointment, check on prescriptions, ask about billing and parking, and so forth. Whereas at our clinic, telehealth visits are considered a billable scheduled appointment, and those are conducted over the telephone or over ZOOM with our non-RN providers (APPs and MDs). The only RN visit we do here at this particular clinic are in-person visits for certain procedures and teachings within the RN scope. We don't have these compacts in California, so maybe the regulations are a little different in different states and with different institutions. If the nurses DID start scheduling telehealth visits with patients, however, the rules would be different, even in California.
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Ingrid Hawkinson
RN, MSN, AMB-BC
UCSF Otolaryngology
San Francisco CA
415-353-2148
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Original Message:
Sent: 05-19-2026 15:26
From: Heather Wilkinson
Subject: Communicating and Triages patients out of state
I have to agree with Roy. The facility I worked at required that nurses or medical assistants who did intakes for telehealth visits verify the patient was physically located in Colorado or we couldn't allow the telehealth visit to take place. While it's true those appointments were with MDs or APPs, it just makes sense that the same standard would apply to RNs.
I feel these situations are part of the point of having compact or multi-state licenses. There are a lot of facilities that are located very near to state borders and they provide care to patients in adjacent states, especially in rural areas where patients have to travel to a larger town for health services.
According to the Colorado Department of Regulatory Agencies, which oversees nurse and other professional licensure, the following is required:
"Colorado nursing telehealth laws require that any nurse treating a patient physically located in Colorado must hold an active, unencumbered Colorado nursing license or a multistate license under the Nurse Licensure Compact (NLC). Out-of-state nurses without a Colorado or NLC license can apply for a specific telehealth registration to provide remote care."
Here is some additional information I found to be interesting:
"If you are an out-of-state nurse obtaining the special Colorado telehealth registration, you are bound by the following rules:
No In-Person Care: You are strictly prohibited from opening a physical office or providing in-person health services in Colorado.
Patient Disclosures: You must explicitly notify the patient of your physical location and inform them that you do not have a physical presence in Colorado.
Emergency Protocols: You must maintain a written emergency protocol, know the emergency services in your patient's Colorado area, and stay on the line with the patient during an emergency until local help arrives."
Heather A. Wilkinson BSN, RN, AMB-BC
Original Message:
Sent: 5/18/2026 7:54:00 PM
From: Kristin Hawkinson
Subject: RE: Communicating and Triages patients out of state
Hi, Roy.
I'm not aware that there's a single California law saying a telephone triage nurse must verbally confirm "Are you in California?" on every call. It's more of an institutional policy issue under guidance of our risk management/compliance officers and not an explicit California statute, and I'm only sure of the guidelines I have been given by my institution. Video visits and especially prescribing are a different story - but our RNs don't prescribe or do video visits. If the situation is questionable then I can always check in with my compliance officers for further clarification.
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Ingrid Hawkinson
RN, MSN, AMB-BC
UCSF Otolaryngology
San Francisco CA
415-353-2148
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Original Message:
Sent: 05-15-2026 14:06
From: Roy Cornatzer
Subject: Communicating and Triages patients out of state
"Our nurses in California are allowed to engage in mychart messages and phone calls with established patients"
Are you sure? Jurisdiction for the delivery of nursing care is with the state where the patient is physically located.
There are no exceptions for "established patients" or messages verses telephone. If nursing care is being delivered, the nurse needs to have a license in the state where the patient is physically located.
If you can point me to a federal or state exception, I'd like to see it. See below- I've asked around. Same answer every time.
Original Message:
Sent: 5/14/2026 5:42:00 PM
From: Kristin Hawkinson
Subject: RE: Communicating and Triages patients out of state
Our nurses in California are allowed to engage in mychart messages and phone calls with established patients, regardless of their location, and we're not tasked with trying to determine where they're calling or writing from.
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Ingrid Hawkinson
RN, MSN, AMB-BC
UCSF Otolaryngology
San Francisco CA
415-353-2148