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The American Telehealth Association is looking for clarification from the Centers for Medicare and Medicare Services on telehealth billing practices in the physician fee schedule final rule released last week.
A large health system told the ATA that the documentation burden in the rule would cost the health system $1 million a year, according to Alexis Apple, head of Federal Government Relations, ATA Action, and director of Federal Affairs for the ATA.
Because of the financial ramifications of the final rule, the health system is prepared to bring all telehealth providers who work part-time at home back to the hospital to conduct virtual care visits.
"The administrative burden is so tremendous for hospital systems," Apple said. "It will cost them $1 million."
The ATA wants clarification on the final rule's mandate that physicians list their location, including home address, for billing purposes when conducting telehealth calls. Currently, physicians are able to list their office address for billing purposes when they do telehealth from home. That ability expires on Dec. 31.
WHY THIS MATTERS
Starting Jan. 1, 2026, CMS will require telehealth practitioners to put down their home address if they’re providing the service from that location. CMS has said that it would suppress the home address to protect privacy, according to Apple.
The 2026 Medicare Physician Fee Schedule Final Rule will require practitioners to separately enroll and bill for each location from which they deliver telehealth. But the directive of listing separate billing sites is a costly administrative burden for hospitals as there could be numerous billing sites, and all must be verified, according to Apple.
The hospital would have to go through the compliance of checking the addresses of hundreds of different locations a year, she said.
"Anywhere where they practice from," Apple said, "they have to put it on the form."
Physicians want to keep their home addresses out of billing paperwork due to concerns of privacy and security, according to comments received by CMS prior to the release of the final rule on Oct. 31.
CMS said of the comments in the more than 2,000-page final rule: "Interested parties voiced concerns about the safety and privacy of health professionals who work from home and furnish telehealth services."
The ATA has concerns about the rule as it applies to physicians who work from home part-time, and also for those physicians who work full-time from home as virtual care providers. The rule doesn't separately address physicians employed full-time by a telehealth company not associated with a specific hospital system, Apple said.
Though CMS has said it would block addresses from being seen, physicians still feel there could still be a way for individuals to get the information on where they live, Apple said.
"We're trying to get clarification from CMS," Apple said. "We hope to hear next week. We have less than 60 days to figure this out. We need clarification."
THE LARGER TREND
During the COVID-19 pandemic, when telehealth flexibilities were enacted, CMS allowed providers to list their affiliated practice address on the billing form. That flexibility was extended through Dec. 31, 2025.
For Medicare beneficiaries, telehealth flexibilities allowing them to be on a telehealth call from home expired on Sept. 30, coinciding with the government shutdown on Oct. 1. Telehealth in Medicare is now back to pre-pandemic requirements of being located in a specific clinic in a rural area.
Since the end of the public health emergency, Congress has continued to extend telehealth flexibilities and must act again for Medicare beneficiaries to keep telehealth from home.
"We do expect them to act on it," Apple said. This could be by making telehealth flexibilities permanent or by voting for another extension in a continuing resolution. Either awaits the end of the government shutdown, which is now in its second month.
Some providers are continuing to provide telehealth care to Medicare beneficiaries in the hope CMS will reimburse them once Congress acts, according to Apple.
ON THE RECORD
The ATA said by statement: "We are encouraged by CMS' continued recognition of telehealth as a vital component of care delivery and are pleased to see many positive steps included in the final 2026 Medicare Physician Fee Schedule, including expanded coverage, streamlined processes, and permanent adoption of key flexibilities," said Kyle Zebley, executive director of ATA Action and senior vice president, public policy of the ATA. "However, we have ongoing concerns that the issue of provider location and home address reporting has not yet been fully resolved, a change that could significantly impact providers across the country when the current flexibility expires on Dec. 31."
Email the writer: SMorse@himss.org