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The current enrollment structure is outdated and does not support the operational and privacy concerns virtual-only telehealth providers face in a digital age. It is not practical, workable, or safe to require a virtual-only provider to publicly report their home address as their practice location. The Alliance continues to work with CMS on a path forward for virtual-only providers.
Developments to Date
The Alliance for Connected Care led a successful advocacy campaign that resulted in CMS making this flexibility permanent for providers with a physical practice location – protecting access for telehealth for patients and providers.
On November 14, 2025, CMS released updated telehealth FAQs, which makes permanent the policy:
Q15: Can distant site practitioners provide telehealth services from their home? Do practitioners need to report their home address on their Medicare enrollment application if they are providing telehealth services from home?
A15: Yes, practitioners can provide telehealth services from their home and in many cases do not need to report their home address. Practitioners who furnish telehealth services from their homes but have a physical practice location are not required to report their home address on their Medicare enrollment application. Practitioners can enroll and bill from their physical practice location as if they furnished the telehealth service in person. Virtual-only telehealth practitioners whose only physical practice location is their home address will need to enroll their home address as a practice location. The practitioner should mark the address as a “Home office for administrative/telehealth use only” location in their enrollment application to suppress the street address details from the practitioner’s profile page on the CMS Care Compare Website, a tool for Medicare beneficiaries to find and compare different Medicare providers. The practitioner may also email the Quality Payment Program service center at QPP@cms.hhs.gov to suppress the street address and/or phone number from the page.
On November 5, 2025, CMS did not renew this policy in the final Calendar Year (CY) 2026 Physician Fee Schedule. 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. Read our statement here.
In the 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.
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.
On September 1, 2023, CMS updated its 855I enrollment form which includes checkboxes to differentiate home, administrative, and clinic locations, which would segment information. CMS-855B, which is used for clinics and group practices, is also updated with the same checkbox on that form as well.