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December 2023    Volume 4 Issue 11
Health Law Connections

How to Keep Arrangements with Telehealth and Remote Practitioners Compliant by Understanding CMS Enrollment and Claims Submission Requirements

This Feature Article is brought to you by AHLA's Academic Medical Centers and Teaching Hospitals Practice Group.
  • December 01, 2023
  • Allison Cohen , Baker Donelson Bearman Caldwell & Berkowitz PC
  • Gayle Lee , Association of American Medical Colleges

In the Calendar Year 2024 Medicare physician fee schedule final rule, the Centers for Medicare & Medicaid Services (CMS) extended until December 31, 2024, a flexibility allowing practitioners who furnish telehealth services from their homes to continue to bill from their currently enrolled locations instead of being required to report their home addresses on enrollment and claim forms. This delay was largely in response to privacy and safety concerns associated with reporting home addresses of remote practitioners. Stakeholders also raised concerns related to the administrative burden of changing billing practices, adding home addresses to the Medicare enrollment file, and coordinating with the appropriate Medicare Administrative Contracts (MACs). Interested parties stated that such a policy would likely discourage practitioners from providing telehealth services, ultimately reducing patient access. CMS indicated that the agency would continue to consider this issue in future rulemaking and requested further information from stakeholders to better understand the scope of the 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.


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