ALLIANCE STATEMENT

NOVEMBER 3, 2025

The Alliance for Connected Care is disappointed that the Centers for Medicare and Medicaid Services (CMS) announced changes that will make it more difficult for a Medicare-enrolled practitioner to offer telehealth services from an alternative location. CMS plans to change billing rules, enabled by the Trump Administration in 2020, that allowed clinicians to be more available to their patients through telehealth when they are not in the office – such as after-hours telehealth visits from their homes.

For the past five years, CMS has allowed a telehealth practitioner to report and bill using their currently enrolled practice location even when offering a telehealth service from their home or another location. This policy helped reduce administrative complexity in Medicare billing and strengthened continuity of care by allowing patients to continue seeing their existing practitioners.

CMS did not renew this policy in the final CY2026 Physician Fee Schedule (page 172). If this change goes into effect in January 2026, many telehealth visits offered by practitioners from locations other than their enrolled billing location will end.  Those who continue providing such care would need to separately enroll and bill for each location from which they deliver telehealth services. This is administratively difficult and will dramatically increase regulatory burden on both these practitioners and organizations with payment systems that are not designed to accommodate this reality.

While we appreciate CMS action to mitigate concerns about the release of clinicians’ home addresses, we believe privacy and clinician safety risks of unintended disclosure remain. Additionally, we believe the significant operational burden created by this policy has unfortunately been largely overlooked.

In a survey of Alliance members, it was estimated that this change will result in up to a fortyfold increase in the number of billing addresses tracked and reported to CMS by a health system. Multiple health systems estimated the resulting operational costs of this change at approximately $1 million in labor. CMS itself would also have significant operational costs related to the processing of additional documentation that would be submitted to the agency.

The Alliance shares CMS Administrator Oz’s vision for reducing administrative burden and empowering clinicians to focus on what matters most – caring for the patients they serve. We strongly support efforts to streamline regulations, simplify documentation requirements, and modernize federal policies that no longer reflect how care is delivered in today’s connected environment.  This change is the antithesis of that vision and should be immediately corrected through sub-regulatory guidance.

For more on the Alliance’s work to advance access to comprehensive telehealth care, please visit https://connectwithcare.org/provider-location/.