Background
During the COVID-19 public health emergency, the Centers for Medicare and Medicaid Services (CMS) moved to allow practitioners to render telehealth services from their home without reporting their home address on their Medicare enrollment while continuing to bill from their currently enrolled location.
Prior to the COVID-19 waiver, CMS required providers to enter the address of the location where the service were furnished in Item 32. According to a response letter, CMS indicates:
“For a practitioner who works from home 100 percent of the time with no other office site, the home address is the address they should enter on the claim. We recognize that these practitioners may not wish to enter their home address, but there is no other appropriate alternate address to use.”
The current enrollment structure is outdated and does not support providers new operational and privacy concerns faced in a digital age. It is not practical, workable, or safe to require a provider to publicly report their home address as their practice location. Medicare providers should not be compelled to share their personal information, especially when it relates to their home addresses.
Developments to Date
In the Calendar Year (CY) 2025 Medicare Physician Fee Schedule final rule, CMS finalized, as proposed, through CY 2025, to continue to permit the distant site practitioner to use their currently enrolled practice location instead of their home address when providing telehealth services from their home. While the Alliance appreciates the extension through 2025, the ability to bill a currently enrolled location does not alleviate barriers for virtual-only practitioners without a physical practice location to report other than their homes. The Alliance led more than 150 stakeholder organizations in a letter requesting that CMS to work with stakeholders to develop an alternate method of determining location for the purposes of payment that does not require the reporting of a home address, such as through the convening of a roundtable or a similar effort, to ensure the experiences of virtual-only practitioners are considered.
CMS extended this waiver through December 31, 2024 in the Calendar Year (CY) 2024 Physician Fee Schedule final rule.
The Alliance has continued to met with CMS and requested CMS to include changes that would prevent the unnecessary reporting of provider home addresses (for both enrollment and billing) in the CY 2025 Physician Fee Schedule (PFS) in order to facilitate dialogue with the provider community.
CMS updated its 855I enrollment form which includes checkboxes to differentiate home, administrative, and clinic locations. It will be used to segment information. CMS-855B, which is used for clinics and group practices, will be updated, and it can be expected to see the same checkbox on that form as well.