Alliance for Connected Care’s advocacy in this space:
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The current enrollment structure is outdated and does not support providers new operational and privacy concerns faced in a digital age.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
CMS extended this waiver through December 31, 2023 in its PHE guidance. CMS has not yet indicated a plan for 2024.
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 2024 Physician Fee Schedule (PFS) in order to facilitate dialogue with the provider community. CMS did not include in the CY 2024 PFS.
With regard to enrollment forms, CMS released a bulletin notice to its Medicare Learning Network, which outlines the new 855I enrollment form which includes checkboxes to differentiate home, administrative, and clinic locations. CMS-855B, which is used for clinics and group practices, will be updated early 2024, and it can be expected to see the same checkbox on that form as well.