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Telehealth enrollment scenarios

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 has been made permanent policy. 

Telehealth providers will enroll based on their enrollment scenario below. Providers are not required to enroll in every state where the beneficiary resides. They are required to enroll in the state where they are physically located or where the group is physically located. Co-working locations that offer rentable office space are acceptable practice locations for enrollment purposes.

Note: Teleradiology is a different model of care from telehealth and has its own set policies. CMS will issue subsequent guidance regarding teleradiology enrollment.
 

Provider has a private practice - no reassignments exist

  • 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 

Provider reassigns to a group in the same state - group has a physical location (brick and mortar office)

  • 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 

Provider reassigns to a group out of state - group has a physical location

  • Dr. Smith provides telehealth from home in MD where s/he is licensed
  • Dr. Smith reassigns to Jones Medical Group in FL
    • Providers shall identify it is a telehealth arrangement on the application or via a cover letter with the application and include the state in which the provider resides. Providers are not required to report the state the patients are located. If a letter is not submitted and the application is not clear, we may request additional information.
    • MACs shall defer to state law for any additional licensure requirements. It’s the provider’s responsibility to ensure they are compliant with any additional state licensure laws. 
  • 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
  • Note: Providers may choose to follow the policy in Medicare Program Integrity Manual, Pub. 100-08, Chapter 10 – Medicare Enrollment, Section 10.3.1.4(E), "Inter-Jurisdictional Reassignments" and are not required to convert their current enrollments to align with this permanent telehealth policy (MACs shall allow these submissions)

Provider reassigns to group with no physical location (virtual telehealth services only)

  • 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 “Business Office for Administrative / Telehealth Use Only” or “Home Office for Administrative / Telehealth 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
  • Note: This scenario is consistent with the Medicare Program Integrity Manual, Pub. 100-08, Chapter 10 – Medicare Enrollment, Section 10.3.1.4(E), "Inter-Jurisdictional Reassignments"