CMS Extends Telehealth Flexibilities to Protect Physician Privacy
By Alisa Pierce

Following staunch advocacy by the Texas Medical Association, the Centers for Medicare & Medicaid Services (CMS) will not require physicians to list their home address as a practice location on Medicare enrollment forms for another year when providing telehealth services, safeguarding their privacy and safety. 

During the COVID-19 pandemic, CMS allowed physicians to offer telehealth services from their homes without reporting their home address on their Medicare enrollment. However, that flexibility was set to expire Dec. 31. 

Even though CMS did not propose a change in its 2024 Medicare Physician Fee Schedule proposal, citing  safety and administrative concerns, TMA asked CMS in its September comment letter to protect telehealth practitioners by adjusting Medicare enrollment requirements so they did not have to list their home addresses on enrollment forms.  

TMA staff explained that if such flexibilities were rescinded, a significant number of practices would need to change their billing protocols, coordinate with a Medicare administrative contractor, or possibly be subject to site inspections, adding to physicians’ already lengthy list of administrative responsibilities. 

“TMA implores CMS to … allow physicians to conduct visits as needed from locations other than their primary practice setting without having to add their home address to their Medicare enrollment form. This allows physicians to extend the hours they are available to patients without concern that their address will be made public or their Medicare enrollment form is updated,” the comment letter stated. 

Heeding TMA’s concerns, CMS included a provision in the 2024 Medicare Physician Fee Schedule final rule that allows physicians to continue to bill from the location of their practice without listing their home addresses. 

“We will continue to permit the distance site practitioner to use their currently enrolled practice location instead of their home address when providing telehealth services from their home,” CMS stated in its FAQ.  

CMS also asked physicians for guidance in future rulemaking. 

“We will also consider this issue further for future rulemaking and … request further information from interested parties to better understand the scope of considerations involved with including a practitioner’s home address as an enrolled practice location when that address is the distant site location where they furnish Medicare telehealth services,” the agency stated. 

For more information on post-pandemic CMS waivers and flexibilities, see CMS’ fact sheet.  

For help with telehealth rules and regulations, visit TMA’s comprehensive telemedicine page

Last Updated On

November 27, 2023

Originally Published On

November 27, 2023

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Alisa Pierce

Alisa Pierce is a reporter for Texas Medicine. After graduating from Texas State University, she worked in local news, covering state politics, public health, and education. Alongside her news writing, Alisa covered up-and-coming artists in Central Texas and abroad as a music journalist. As a Texas native, she enjoys capturing the landscape on her film camera while hiking her way across the Lonestar State.

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