Preventing Burdensome Location Reporting Requirements on Telehealth Practitioners

The Alliance for Connected Care sent a letter, expressing concern with the omission of a continuation of telehealth location reporting flexibility for telehealth practitioners in the proposed CY2026 Physician Fee Schedule. Without prompt action by CMS, this important telehealth policy will end and dramatically increase administrative burden for both practitioners offering telehealth services while increasing costs for CMS.

The Alliance requested CMS leadership in ensuring that telehealth practitioners working from a home-based location are not mandated to report their private residence to the federal government for purposes of enrollment or billing. More specifically, we asked CMS to:

Extend permanently current telehealth flexibility that allows a practitioner to bill for telehealth services from a location at which the clinician is capable of offering in-person care to patients, even when the practitioner is practicing at a different location, such as the home. Without action from CMS, this flexibility will end on December 31, 2025.
For practitioners without a physical practice location, we request CMS work with stakeholders to develop an alternate method of determining location for the purposes of payment that does not mandate the reporting of a home address. One potential option would allow a business address to be reported for purposes of enrollment, and a geographic indicator such as a zip code to be reported for payment adjustment by geographic cost and wage index.
Work with the Drug Enforcement Administration to encourage a complementary solution for medical practitioners who report a practice location while prescribing a controlled substance. As you know, the DEA also requires a physical billing location for some telehealth visits – greater alignment across these program requirements would reduce administrative burden.

Read the full letter here or below: