The Centers for Medicare & Medicaid Services (“CMS”) recently confirmed that certain Medicare enrollment flexibilities for practitioners providing telehealth services from their homes are now permanent.

What Providers Need to Know

Under the new permanent policy, practitioners who provide Medicare telehealth services from home, but who have a separate physical practice location do not need to report their home address on their Medicare enrollment application. Instead, they can enroll and bill from the physical practice location as though the telehealth service had been furnished there in person.

The rules differ for virtual-only arrangements. If a practitioner only provides telehealth services virtually and the practitioner’s home is the only physical practice location, the practitioner must report the home address as a Medicare practice location. Similarly, a virtual-only group with no physical practice location is required to list the practitioner’s home address as its practice location. When a home address must be reported as a practice location, practitioners should select the practice location type as “Business Office for Administrative/Telehealth Use Only” or “Home Office for Administrative/Telehealth Use Only.” This designation keeps the home address from being published on Care Compare.

CMS also clarified that practitioners are not required to enroll in Medicare in each state where their telehealth patients are located. However, CMS continues to defer to state law regarding telehealth licensure, and practitioners remain responsible for complying with applicable state licensing requirements.

Not All Remote Services Qualify

The permanent flexibility applies specifically to services that qualify as Medicare telehealth services: services ordinarily furnished in person but instead provided through two-way telecommunications technology. Services that are not ordinarily furnished in person (e.g., remote interpretation of diagnostic tests) are not considered Medicare telehealth services for purposes of this policy. CMS specifically addresses teleradiology as such a service. Because interpretation of radiological images is not ordinarily furnished in person, CMS policy considers teleradiology a remote service rather than a Medicare telehealth service. Accordingly, teleradiologists are not eligible for the telehealth flexibilities described in CMS policies. Teleradiologists must list their actual location when providing services, including home addresses when applicable – a physical office cannot be substituted if it is not the location where the interpretation and reporting occur.

Key Takeaways

CMS policy allows for continued Medicare enrollment flexibility for telehealth services. In light of this policy, providers and group practices using remote practitioners should review their arrangements with telehealth practitioners and Medicare enrollment arrangements, including:

Reviewing whether services qualify for the permanent telehealth flexibility.

Evaluating whether practitioners working from home are associated with an enrolled practice location.

Confirming that virtual-only arrangements appropriately report required home practice locations.

Selecting “Business Office for Administrative/Telehealth Use Only” or “Home Office for Administrative/Telehealth Use Only” as the practice location type when a home address must be reported so that the home address is not published on Care Compare.

The post Update on Medicare Enrollment Flexibilities for Telehealth Services appeared first on Thompson Coburn LLP.

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