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Telehealth enrollment scenarios – extended address waiver through December 31
Last Modified: 3/28/2025
Location: FL, PR, USVI
Business: Part B
During the COVID-19 public health emergency (PHE), CMS allowed providers 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.
This waiver remains in effect through December 31, consistent with the calendar year (CY) 2025 Physician Fee Schedule (PFS) final rule. Once the waiver expires, all existing telehealth policies will apply, including those in section 10.3.1.4(E) of the Program Integrity Manual (PIM), chapter 10 (Inter-Jurisdictional Reassignments).
Note: Providers may choose to follow the policy in section 10.3.1.4(E) of the PIM (Inter-Jurisdictional Reassignments) to avoid having to alter their enrollments once the waiver has ended.
Telehealth providers will enroll based on their enrollment scenario.
Note: These telehealth enrollment scenarios also apply to teleradiology and telemedicine
Provider has a private practice - no reassignments exist
During the waiver:
• Dr. Smith has a private practice and provides telehealth from home in Maryland (MD)
• Dr. Smith submits an 855I to the MD MAC and lists the home address on the application
• Dr. Smith selects the practice location type as “Business Office for Administrative/Telehealth Use Only” or “Home Office for Administrative/Telehealth Use Only” to prevent the home address from being published on Care Compare
• Claims will be paid based on Dr. Smith’s home location
After the waiver expires:
• No changes to this scenario
Provider reassigns to a group in the same state - group has a physical location (brick and mortar office)
During the waiver:
• Dr. Smith provides telehealth from home in MD
• Dr. Smith reassigns to Jones Medical Group also in MD
• Dr. Smith submits an 855I to the MD MAC to reassign to Jones Medical (no location listed, all locations on the 855B)
• Jones submits an 855B to the MD MAC listing their physical location and does not list Dr. Smith’s home address as a practice location
• Claims will be paid as if Dr. Smith provided the service in person at the physical location
After the waiver expires:
• Jones submits an 855B to the MD MAC listing their physical location and does list Dr. Smith’s home address as a practice location
• Select the practice location type as “Business Office for Administrative/Telehealth Use Only” or “Home Office for Administrative/Telehealth Use Only” to prevent the home address from being published on Care Compare
Provider reassigns to a group out of state - group has a physical location
During the waiver:
• Dr. Smith provides telehealth from home in MD
• Dr. Smith reassigns to Jones Medical Group in FL
• Dr. Smith only needs to be licensed in his/her home state (MD) and not Florida (FL).
• Providers shall identify on the application or via a cover letter with the application, that it is a telehealth arrangement
• Jones Medical submits an 855B to the FL MAC listing the physical location and does not list Dr. Smith’s home address as a practice location
• Dr. Smith submits an 855I to the FL MAC to reassign to Jones Medical (no location listed, all locations on the 855B)
• Claims will be paid as if Dr. Smith provided the service in person at the physical location
After the waiver expires:
• The group must enroll in the MAC jurisdictions in which (1) it has its own practice location(s), and (2) the reassigning provider has his/her practice location
• Jones submits an additional 855B to the MD MAC (the state where Dr. Smith is located) and does list Dr. Smith’s home address as a practice location
• Select the practice location type as “Business Office for Administrative/Telehealth Use Only” or “Home Office for Administrative/Telehealth Use Only” to prevent the home address from being published on Care Compare
Provider reassigns to group with no physical location (virtual telehealth services only)
During the waiver:
• Dr. Smith provides telehealth from home in MD
• Dr. Smith reassigns to Jones Medical Group who does not have a physical location
• Jones Medical submits an 855B to the MD MAC listing Dr. Smith’s home address as its practice location
• Dr. Smith submits an 855I to the MD MAC to reassign to Jones Medical (no location listed, all locations on the 855B)
• Jones Medical selects the practice location type as “Home/Business Office for Administrative Use Only” to prevent Dr. Smith’s home address from being published on Care Compare
• Claims will be paid based on Dr. Smith’s home location
After the waiver expires:
• No changes to this scenario
First Coast Service Options (First Coast) strives to ensure that the information available on our provider website is accurate, detailed, and current. Therefore, this is a dynamic site and its content changes daily. It is best to access the site to ensure you have the most current information rather than printing articles or forms that may become obsolete without notice.
