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IL · STATE RULES

Telehealth rules in Illinois

Illinois counts store-and-forward review as telehealth and sets no live-visit rule for a first non-controlled prescription, but every provider treating a patient located in Illinois needs an Illinois license or permit (225 ILCS 150/10). Four rules set Illinois apart from its neighbours: BIPA's signed release before any face or fingerprint scan, a ban on percentage fees for practice marketing or management, the WOPR Act's limits on AI in therapy, and harassment and implicit bias training at every renewal.

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First visit
Async allowed
Physician license
Illinois license; IMLC member
Controlled drugs
State CS license; e-Rx II–V
Nurse practitioners
Reduced practice

Rules checked September 2026 · 36 sources cited

ONLY IN ILLINOIS

What is different about Illinois

Each rule here is true of Illinois and of none of the states that border it. Beside each one: what the neighbours do instead.

  1. 01 · Practice

    No percentage fees for marketing or management

    Under 225 ILCS 60/22.2(f), an Illinois physician may not pay anyone a percentage of professional fees, revenue or profit for marketing or managing the practice, listing it in a network or negotiating its rates. Percentage pricing survives only for billing and collection under 22.2(d), with the practice controlling fees and deposits, and the Attorney General can enforce breaches through the Consumer Fraud Act.

    Source: 225 ILCS 60/22.2

    Across the border

    • Wisconsin

      Wisconsin's fee-splitting statute, Wis. Stat. 448.08(1m), bans giving or taking anything of value for referrals or for services not actually rendered; it names no rule against percentage management or marketing fees.

      Source: Wis. Stat. 448.08

    • Indiana

      Indiana's board rule 844 IAC 5-2-10 governs only fee division between practitioners, allowed with patient consent and in proportion to work done; no Indiana rule addresses percentage fees paid to a management company.

      Source: 844 IAC 5-2-10

    • Kentucky

      Kentucky's KRS 311.597 has no separate fee-splitting clause; it reaches fee arrangements only by treating departures from AMA ethics principles as unprofessional conduct, and sets no percentage-fee rule for managers.

      Source: KRS 311.597

    • Missouri

      Missouri's physician discipline statute, RSMo 334.100, contains no physician fee-splitting clause; its fee ground covers fees obtained by fraud, deception or misrepresentation, not percentage management contracts.

      Source: RSMo 334.100

    • Iowa

      Iowa's board rule 481 IAC 661.1 treats accepting remuneration for referring a patient in violation of law or medical ethics as misconduct; it sets no limit on percentage management or marketing fees.

      Source: 481 IAC 661.1

  2. 02 · Practice

    Face and fingerprint scans need a signed release

    The Biometric Information Privacy Act (740 ILCS 14/15) bars collecting a face-geometry scan, fingerprint or voiceprint without written notice of purpose and term and a signed written release, and requires a public retention policy with destruction within 3 years of last contact. Any person can sue for $1,000 per negligent or $5,000 per reckless violation (740 ILCS 14/20). Scans captured for HIPAA treatment, payment or operations are excluded.

    Source: 740 ILCS 14/15

    Across the border

    • Wisconsin

      Wisconsin has no biometric privacy statute; biometric data appears only in its breach-notice law, Wis. Stat. 134.98, which requires notice after unauthorized acquisition, not consent before collection.

      Source: Wis. Stat. 134.98

    • Indiana

      Indiana's Consumer Data Protection Act treats biometric data used to identify a person as sensitive data (IC 24-15-2-28), with enforcement by the attorney general and civil penalties up to $7,500 per violation.

      Source: IC 24-15-2-28

    • Kentucky

      Kentucky's Consumer Data Protection Act, in force since January 1, 2026, requires consent before processing biometric data as sensitive data, but the attorney general alone enforces it and consumers cannot sue.

      Source: Kentucky AG on KRS 367.3611

    • Missouri

      Missouri has no biometric privacy statute, and its breach-notice law, RSMo 407.1500, does not list biometric data among the personal information whose breach triggers notice.

      Source: RSMo 407.1500

    • Iowa

      Iowa Code chapter 715D covers biometric data as sensitive data but requires only clear notice and a chance to opt out, and gives the attorney general exclusive enforcement with no private right of action.

      Source: Iowa Code 715D

  3. 03 · Advertising

    AI cannot act as the therapist

    The Wellness and Oversight for Psychological Resources Act (225 ILCS 155/20) bars offering or advertising therapy, including through AI, unless a licensed professional conducts it, and forbids letting AI make therapeutic decisions, talk with clients therapeutically or detect emotions. AI note-taking on a recorded session needs written notice and consent (155/15). IDFPR can fine up to $10,000 per violation.

    Source: 225 ILCS 155/20

    Across the border

    • Wisconsin

      Wisconsin has no AI therapy statute; its companion-chatbot bill, Assembly Bill 965, failed to pass in March 2026 under Senate Joint Resolution 1.

      Source: Wisconsin AB 965

    • Indiana

      Indiana has enacted no statute limiting AI-delivered therapy or how licensed therapists use AI tools in sessions, so no written consent rule for AI note-taking applies there.

    • Kentucky

      Kentucky's HB 455, which would have limited AI in therapy, passed the House 88-7 in February 2026 but stalled in the Senate, so no such rule is law.

      Source: Kentucky HB 455

    • Missouri

      Missouri's licensing law sets no limit on how licensed therapists use AI in sessions and requires no written consent before AI note-taking or transcription of a therapy session.

    • Iowa

      Iowa's SF 2417, applying from July 1, 2027, targets chatbot operators with disclosure duties and a bar on claiming to offer licensed psychology or behavioral health services; it does not regulate how licensed clinicians use AI.

      Source: Iowa SF 2417

  4. 04 · Licenses

    Harassment and bias training at every renewal

    Every IDFPR licensee must finish sexual harassment prevention training before each renewal (20 ILCS 2105/2105-15.5), and health care licensees need a one-hour implicit bias course each renewal period (2105-15.7). Illinois physicians renew every three years with 150 CME hours; the July 31, 2026 deadline for the current cycle was extended to August 31, 2026.

    Source: 20 ILCS 2105/2105-15.5

    Across the border

    • Wisconsin

      Wisconsin's Med 13 requires 30 CME hours every two years, with 2 hours on prescribing opioids and other controlled substances as the only mandated topic; no harassment or bias course applies.

      Source: Wis. Admin. Code Med 13

    • Indiana

      Indiana mandates no harassment or implicit bias course for physician renewal, and its two-hour opioid CE rule for controlled-substance registrants has expired, per the Professional Licensing Agency.

      Source: Indiana PLA controlled substance registration

    • Kentucky

      Kentucky's 201 KAR 9:310 requires 60 hours every three years, including 4.5 hours on KASPER, pain management and addiction for controlled-substance prescribers; it sets no harassment or bias course.

      Source: 201 KAR 9:310

    • Missouri

      Missouri's 20 CSR 2150-2.125 requires 50 CME hours every two years and names no mandatory topics, so no harassment or implicit bias course applies.

      Source: 20 CSR 2150-2.125

    • Iowa

      Iowa's 481 IAC 654 requires 40 category 1 hours every two years, with abuse-reporting, chronic pain and end-of-life topics for some physicians; it has no harassment or implicit bias requirement.

      Source: 481 IAC 654

PRACTICE RULES

How telehealth works in Illinois

Illinois regulates telehealth through the Telehealth Act (225 ILCS 150) and the Medical Practice Act, which Public Act 104-0796 extended through January 1, 2032. The clinical entity must be owned by Illinois physicians, and BIPA reaches identity checks that scan a face.

  1. 01

    Same standard as an office visit

    Under 225 ILCS 150/15, a provider may deliver telehealth within the scope of an Illinois license only when it meets the standards of care for in-person services, and the Telehealth Act widens no scope of practice. Illinois telehealth must also follow federal and Illinois privacy, security and confidentiality laws.

    Source: 225 ILCS 150/15

  2. 02

    Phone calls count; texts do not

    The Illinois Telehealth Act defines an interactive telecommunications system to include audio-video and audio-only landline or cellular calls, while fax, email and text messaging are excluded (225 ILCS 150/5). Store-and-forward review, remote monitoring, e-visits and virtual check-ins are all listed as telehealth services.

    Source: 225 ILCS 150/5

  3. 03

    Only physicians can own the practice

    Illinois keeps a strict corporate practice of medicine (CPOM) rule: under 805 ILCS 15/13 every officer, director and shareholder of a medical corporation must hold an Illinois physician license, and no shareholder may sign a voting trust or other agreement handing voting power to someone else. Friendly-PC stock arrangements should be reviewed by counsel against that clause.

    Source: 805 ILCS 15/13

  4. 04

    Where physicians may pool fees

    225 ILCS 60/22.2(c) lets Illinois physicians pool professional fees only inside entities whose owners are all Illinois licensees, organized as a medical corporation, professional service corporation, professional association or professional LLC, or inside licensed hospitals and their affiliates. Public Act 104-0796 kept this list when it renewed the Medical Practice Act.

    Source: 225 ILCS 60/22.2

  5. 05

    Selfie ID checks and BIPA

    BIPA's definitions exclude information captured from a patient in a health care setting or used for HIPAA treatment, payment or operations (740 ILCS 14/10), and photographs alone are not biometric identifiers. Whether a vendor's face-match at an Illinois checkout falls inside that exclusion is unsettled, so a brand scanning faces for identity should have counsel review before launch.

    Source: 740 ILCS 14/10

FIRST VISIT

Can a first visit happen without a live call in Illinois?

Yes

Yes. The Illinois Telehealth Act lists asynchronous store-and-forward review as a telehealth service and sets no live-visit requirement for a first non-controlled prescription, provided the care meets the in-person standard in 225 ILCS 150/15.

Section 49.5 of the Medical Practice Act defines telemedicine as rendering an opinion on an Illinois patient from data sent by telephonic, electronic or other means. Illinois adds no questionnaire ban, so the in-person standard of care is the test.

  1. 01

    Store-and-forward is telehealth

    225 ILCS 150/5 defines an asynchronous store and forward system as sending a patient's medical information to a distant provider without real-time interaction, and lists it among Illinois telehealth services. Neither the Telehealth Act nor the Medical Practice Act requires a live visit before a first non-controlled prescription.

    Source: 225 ILCS 150/5

  2. 02

    E-visits are for existing patients

    Illinois defines e-visits as patient-initiated portal messages and virtual check-ins as brief patient-initiated contacts, and both definitions in 225 ILCS 150/5 are limited to established patients, meaning patients whose protected health information has already been exchanged for their care.

    Source: 225 ILCS 150/5

  3. 03

    The async record must support the diagnosis

    Because 225 ILCS 150/15 ties Illinois telehealth to the standards of care for in-person services, an asynchronous intake must give the reviewing clinician enough history, photos or records to reach the diagnosis and treatment decision an office visit would support.

    Source: 225 ILCS 150/15

  4. 04

    Controlled drugs add Illinois duties

    For controlled substances, Illinois adds its own requirements on top of the federal Ryan Haight Act: an Illinois controlled substance license from IDFPR (720 ILCS 570/302), electronic transmission and PMP documentation. Federal DEA telemedicine flexibilities allowing prescribing without a prior in-person exam run through December 31, 2026.

    Source: 720 ILCS 570/302

PRESCRIBING

Prescriptions and controlled drugs in Illinois

Illinois prescribers work with the Illinois Prescription Monitoring Program (PMP, the state's prescription-monitoring database) and hold a state controlled substance license from IDFPR. Controlled prescriptions go out electronically under a mandate with its own low-volume exemption.

  1. 01

    Illinois controlled substance license

    720 ILCS 570/302 requires anyone who dispenses controlled substances in Illinois, including prescribers, to hold an IDFPR registration, the Illinois controlled substance license, alongside a DEA number. A separate Illinois registration is needed wherever drugs are stored, but not for every location from which a prescription is written.

    Source: 720 ILCS 570/302

  2. 02

    PMP check before opioids

    Every prescriber holding an Illinois controlled substance license must register with the Illinois PMP and document an attempt to check it in the chart before an initial prescription for a Schedule II narcotic such as an opioid (720 ILCS 570/314.5(c-5)). Oncology, palliative care and emergency department supplies of 7 days or less are exempt.

    Source: 720 ILCS 570/314.5

  3. 03

    Stimulants join the PMP check in 2027

    Public Act 104-512, effective January 1, 2027, widens the Illinois PMP duty to the first prescription of any Schedule II stimulant and to every prescription for a Schedule II opioid or Schedule IV benzodiazepine. Illinois brands treating ADHD, anxiety or insomnia need a chart-documented PMP attempt on those prescriptions.

    Source: 720 ILCS 570/314.5

  4. 04

    Electronic scripts for Schedule II–V

    720 ILCS 570/311.6 requires Illinois Schedule II–V prescriptions to be sent electronically. A prescriber certifying 150 or fewer controlled prescriptions a year is exempt through December 31, 2028, dropping to 50 from January 1, 2029; compound prescriptions with two or more compounds are exempt, and IDFPR enforcement before December 31, 2030 starts with a warning letter.

    Source: 720 ILCS 570/311.6

  5. 05

    NP limits on opioids and benzodiazepines

    Full-practice APRNs in Illinois may prescribe Schedule II–V drugs, but Schedule II opioids only in a physician consultation relationship recorded in the PMP and only by oral, topical or transdermal route, and benzodiazepines for up to a 120-day supply before a physician consult is required (225 ILCS 65/65-43).

    Source: 225 ILCS 65/65-43

Federal rules apply on top of every state's. Prescribing controlled substances by telehealth without an in-person visit runs on DEA flexibilities currently extended through December 31, 2026, with a permanent rule still pending.

LICENSES

Who can treat patients in Illinois

Illinois requires its own license or permit for any provider treating a patient located in Illinois, and IDFPR issues compact licenses through the IMLC (Interstate Medical Licensure Compact). Illinois nurse practitioners reach full practice only after 4,000 collaborative hours.

  1. 01

    Illinois license for Illinois patients

    225 ILCS 150/10 requires any health care professional treating a patient located in Illinois by telehealth to be licensed or authorized in Illinois, and 225 ILCS 60/49.5 subjects unlicensed telemedicine to the Medical Practice Act's penalties. Holders of an Illinois temporary permit for health care may treat by telehealth under a sponsoring-entity agreement.

    Source: 225 ILCS 150/10

  2. 02

    Four narrow exceptions

    Section 49.5 excludes from Illinois telemedicine periodic consultations with an Illinois licensee, second opinions given to an Illinois licensee, follow-up care for a patient first treated in the provider's licensing state, and care for an existing patient while the patient or licensee is traveling. None covers a new Illinois patient.

    Source: 225 ILCS 60/49.5

  3. 03

    Compact letters through IDFPR

    Illinois is an IMLC member: IDFPR's compact office processes Letters of Qualification for physicians whose principal license is in Illinois, with an Illinois State Police and FBI fingerprint check. A license gained through the compact is a full Illinois license, subject to the Illinois renewal cycle and training rules.

    Source: IDFPR compact quick reference

  4. 04

    NP full practice after 4,000 hours

    An Illinois APRN may drop the written collaborative agreement only after filing a notarized attestation of at least 4,000 clinical hours in collaboration with a physician and 250 hours of continuing education after national certification (225 ILCS 65/65-43). AANP classes Illinois as a reduced practice state.

    Source: 225 ILCS 65/65-43

  5. 05

    Mandated topics on a six-year clock

    Beyond the harassment and bias courses each cycle, Illinois physicians owe 1 hour each of safe opioid prescribing, cultural competency and dementia training every six years inside the 150-hour total, and at least 60 of the 150 hours must be formal Category 1 CME, per the Illinois State Medical Society.

    Source: ISMS license requirements

ADVERTISING

Marketing to patients in Illinois

Illinois limits what a physician ad may say under 225 ILCS 60/26 and polices marketing money through the fee-splitting statute. AI therapy offers and face-scanning ad tools carry their own Illinois penalties.

  1. 01

    Titles in every ad

    225 ILCS 60/26(4) requires every advertisement for services regulated by the Illinois Medical Practice Act to show the licensee's title as it appears on the license or the initials the Act authorizes, so a brand ad naming an Illinois physician carries that credential.

    Source: 225 ILCS 60/26

  2. 02

    No quality or price comparisons

    Section 26 makes it unlawful for an Illinois licensee to claim superior quality of care or to advertise fee comparisons with other licensees, and bars guarantees of success and statements that play on the vanity or fears of the public, a standard weight-loss, hair and skin creative must respect.

    Source: 225 ILCS 60/26

  3. 03

    Price ads need a fee caveat

    Illinois physician ads may list usual and customary fees for routine services only with notice that fees may be adjusted due to complications or unforeseen circumstances (225 ILCS 60/26(1)(c)). Section 26(1) still reads as a closed list of permitted ad content: name, title, hours, specialty, fees and practice announcements.

    Source: 225 ILCS 60/26

  4. 04

    No AI therapist claims

    Under 225 ILCS 155/20, no individual or company may advertise or offer therapy or psychotherapy in Illinois, including through Internet-based AI, unless a licensed professional conducts it. IDFPR investigates and may fine up to $10,000 per violation after a hearing (225 ILCS 155/30). The Act's clinician rules cover therapists, counselors, psychologists and psychiatric APRNs, not physicians.

    Source: 225 ILCS 155/30

  5. 05

    Face-scan ad tools

    Ad tools that scan face geometry, such as virtual try-on or skin-analysis filters shown to Illinois users, collect biometric identifiers under 740 ILCS 14/10 and need BIPA's written notice and signed release before capture. A marketing scan is not HIPAA treatment, payment or operations, so the health care exclusion is unlikely to cover it.

    Source: 740 ILCS 14/10

TESSIC HEALTH IN ILLINOIS

How Tessic Health's providers cover Illinois

Tessic Health's providers treating Illinois patients hold Illinois licenses and work inside a physician-owned Illinois professional entity under the brand's MSO. Their Illinois routine follows the controlled-substance, PMP and BIPA rules above.

  1. 01

    Illinois-licensed providers only

    Every Tessic Health provider who treats a patient located in Illinois holds an Illinois license, obtained directly or through the IMLC, as 225 ILCS 60/49.5 and the Telehealth Act require, and is credentialed under the brand that owns the Illinois patient relationship and records.

  2. 02

    PMP attempt logged in the chart

    Tessic Health prescribers holding an Illinois controlled substance license are registered with the Illinois PMP and record a PMP access attempt in the chart before any first Schedule II narcotic prescription, extending the check to Schedule II stimulants and Schedule IV benzodiazepines on January 1, 2027.

  3. 03

    Electronic controlled prescriptions

    Controlled-substance prescriptions for Illinois patients go out through Tessic Health's EPCS workflow to meet 720 ILCS 570/311.6, with pharmacy fulfillment at 0% markup and cold-chain shipping when an Illinois patient's medication needs it.

  4. 04

    Physician owners, no revenue-share fees

    The friendly PC serving Illinois patients is owned entirely by Illinois-licensed physicians under 805 ILCS 15/13, and the management company's fees are not set as a percentage of Illinois professional fees for marketing or management, which 225 ILCS 60/22.2(f) forbids.

  5. 05

    Signed release before any face scan

    When an Illinois patient's identity check uses a face-geometry match, Tessic Health's intake collects BIPA's written notice and signed release first under a published retention schedule. If a mental-health brand's Illinois clinicians use AI tools, that use stays within administrative and note support, with the written consent 225 ILCS 155/15 requires.

COMMON QUESTIONS

Questions about telehealth in Illinois

  • Yes, in almost every case. 225 ILCS 150/10 requires a provider treating a patient located in Illinois to be licensed or authorized in Illinois, and section 49.5 of the Medical Practice Act exempts only consultations with Illinois licensees, second opinions, follow-up after care in the provider's own state and care for traveling existing patients.

  • Only for billing and collection. 225 ILCS 60/22.2(d) allows fair-market percentage fees for billing and collection when the practice controls fees and deposits, but 22.2(f) bars percentage payments for marketing or managing the practice, and the Illinois Attorney General can enforce that as consumer fraud.

  • It can. A face-geometry match is a biometric identifier under 740 ILCS 14/10 and needs a signed written release before capture, though scans used for HIPAA treatment, payment or operations are excluded; how that exclusion applies to a telehealth vendor's ID check in Illinois is unsettled, so counsel should review the flow.

  • No. The WOPR Act (225 ILCS 155/20) bars offering therapy through AI unless a licensed professional conducts it, and bars AI from therapeutic communication, treatment decisions and emotion detection. AI may handle scheduling, billing and consented note-taking, and IDFPR can fine up to $10,000 per violation.

  • Yes. 720 ILCS 570/311.6 requires electronic transmission of Illinois Schedule II–V prescriptions, with exemptions for prescribers certifying 150 or fewer a year through December 31, 2028 (50 from January 1, 2029), compound prescriptions with two or more compounds, and temporary technology failures.

  • Yes, after 4,000 clinical hours and 250 CE hours. Once an APRN files that attestation under 225 ILCS 65/65-43, no collaborative agreement is needed, but Schedule II opioids still require a physician consultation relationship recorded in the Illinois PMP.

SOURCES

Rules checked September 2026 · 36 sources cited. A planning summary, not legal advice. Statutes, board rules and enforcement priorities change; a brand's own counsel should review its model and marketing before launch.

OTHER STATES

Rules in other states

Each state page is researched from that state's own statutes and board rules.

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