Telehealth Providers Need to Know This About Medicare Enrollment
- By Terry Fletcher
- In CMS
- September 22, 2026
- No Comments
Providing telehealth services from home is not the same as having a home-based medical practice.
The COVID-19 public health emergency dramatically changed how healthcare was delivered. Physicians and other qualified healthcare professionals who had spent their careers working from medical offices suddenly found themselves seeing patients from spare bedrooms, home offices, and kitchen tables.
That emergency officially ended more than three years ago. But telehealth did not disappear with it. In fact, many of the changes made during the pandemic have become part of the permanent healthcare landscape.
But there is an important distinction that some providers and practices continue to overlook: The fact that Medicare allows you (the physician/provider) to furnish telehealth from home does not mean that Medicare treats a virtual-only home practice the same as a physical practice location.
The Centers for Medicare & Medicaid Services (CMS) recently made that distinction clear in its Medicare enrollment guidance.
The Question Providers Should Be Asking
The Center for Connected Health Policy (CCHP) recently addressed Medicare enrollment for telehealth practitioners, and highlighted a question that I believe every physician and practice administrator should understand:
Does the practitioner have an actual physical practice location, or is the practitioner’s home the only place from which the practice operates?
The answer has significant enrollment and privacy implications.
CCHP explains that CMS has made permanent the policy allowing a practitioner who furnishes Medicare telehealth services from home, but who also has a physical practice location, to enroll and bill from that physical practice location. In that situation, the practitioner generally does not have to add the home address to the Medicare enrollment.
That is a very different situation from that of a virtual-only practice.
Scenario One: You Have a Brick-and-Mortar Practice
Consider a cardiologist, internist, psychiatrist, or other practitioner who has an established office where patients are seen in person. The physician may work in the office three or four days per week and perform telehealth visits from home on another day.
Under CMS’ permanent policy, the physician does not have to enroll the residence as an additional Medicare practice location. The physician can remain enrolled and bill through the physical practice location.
The CCHP publication explains that the same general concept applies when an individual practitioner reassigns Medicare benefits to a group with a physical practice location. The practitioner submits the appropriate reassignment, and the group reports its physical practice locations, even if the practitioner conducts telehealth from another location.
This is one of the strongest practical reasons I see for maintaining a legitimate brick-and-mortar practice location.
You retain an identifiable professional location for your medical practice while preserving the flexibility to perform appropriate telehealth services from home. Also, many state Medicaid programs require a participating provider to have an in-person location when the patient requests a face-to-face encounter. You cannot “force” telehealth on patients in many states.
Scenario Two: Your Home Is Your Medical Practice
Suppose the practitioner has closed the medical office entirely. There is no clinic, medical suite, group practice location, or other physical practice location. The physician sees patients exclusively by telehealth from a home office.
CMS states that when a virtual-only telehealth practitioner’s only physical practice location is the practitioner’s home address, the home address must be reported as a practice location. If a practitioner’s home is their only actual practice location, Medicare enrollment needs to reflect that.
Therefore, practices should not solve the privacy problem by continuing to submit a former office, billing office, corporate address, P.O. box, or another address as though it were the practitioner’s active practice location. Enrollment and claim information must accurately correspond with the practitioner’s Medicare enrollment and the applicable claim-reporting rules.
Another consideration: Many cities have rules about using your home as a medical practice. They may mandate handicap parking, security fencing around a pool, and/or a certain floor plan for accessibility, even though patients may never come to your actual residence.
Also remember that place of service (POS) is determined by the applicable telehealth billing rules. POS 02 and POS 10 identify where the patient is located — not where the physician is. CMS defines POS 02 as telehealth when the patient is somewhere other than the their home and POS 10 is for telehealth when the patient is at home.
Privacy and Safety Implications
If a practitioner makes a residence the sole physical location of a medical practice, the home address becomes information that must be supplied to Medicare as a practice location. CMS recognizes the privacy and safety implications of this, and specifically provides a mechanism for clinicians to prevent their street addresses from appearing publicly on Medicare’s Care Compare profile.
The practitioner can identify the location in PECOS as “Home Office for Administrative/Telehealth Use Only” (or the applicable administrative/telehealth-only designation). CMS states that this suppresses the street address details from the clinician’s public profile. CMS also permits clinicians to contact the Quality Payment Program Service Center to request suppression of the street address and/or telephone number.
That protection is important, but providers should understand its limits. Suppressing an address from Care Compare does not mean the address disappears from Medicare’s enrollment records. CMS still needs the legitimate practice location for enrollment purposes. The suppression mechanism addresses public display; it does not transform the residence into a fictitious non-home location.
There are broader operational concerns beyond Care Compare. Practices should consider how addresses flow through payer enrollment systems, credentialing databases, clearinghouses, directories, correspondence, explanation of benefits processes, and other administrative systems. For a physician — particularly one who treats behavioral health patients, manages controlled substances, handles contentious patient relationships, or has experienced threats or harassment — unnecessary disclosure of a residential address is not a trivial concern.
Before Closing the Office, Ask These Questions
Before a physician decides that maintaining a physical office “doesn’t make sense anymore,” I would encourage the practice to consider:
- Do I want my residence to become my Medicare practice location?
- Have I properly updated PECOS if my former office is no longer an actual practice location?
- If my home must be enrolled, have I selected the proper administrative/telehealth-only designation to suppress the street address from Care Compare?
- Have I confirmed that my address is not appearing in other payer directories or public-facing databases?
- How do my commercial payers, Medicare Advantage plans, Medicaid program, malpractice carrier, state licensing board, and credentialing entities treat a home-only practice?
- Do I understand the difference between my Medicare enrollment location, claim service location information, and the telehealth POS codes?
- Am I comfortable with the privacy and personal security consequences of making my residence the only physical location associated with my medical practice?
CCHP also appropriately cautions that its discussion is specific to Original Medicare. Medicaid programs, Medicare Advantage organizations. Commercial insurers may impose their own enrollment, credentialing, billing, and practice-location requirements.
Sources:
https://www.cms.gov/files/document/understanding-telehealth-enrollment.pdf
https://www.cms.gov/files/document/telehealth-faq-updated-02-26-2026.pdf
https://www.cms.gov/medicare/quality/physician-compare-initiative/about-data
- Telehealth Providers Need to Know This About Medicare Enrollment - September 22, 2026
- Medicare Adds Coverage to Colorectal Cancer Screening NCD - September 8, 2026
- Telehealth 2025: The Final Rule - November 8, 2024
Leave a Reply