Telehealth Stakeholders Ask CMS to Eliminate Address Reporting Burden

October 24, 2023 - Numerous industry groups and healthcare stakeholders are requesting the Centers for Medicare and Medicaid Services (CMS) to continue allowing healthcare providers to conduct telehealth services from their homes without reporting their home addresses.

Following the onset of the COVID-19 pandemic, CMS issued several temporary regulatory waivers to remove barriers to hospitals and health systems’ implementation and use of telehealth services. One waiver allowed healthcare providers to conduct telehealth services from their homes without reporting their addresses on Medicare enrollment or claims forms.

However, CMS stated in a Frequently Asked Questions document that the waiver will end on December 31.

According to letters from the American Hospital Association (AHA), the Alliance for Connected Care, and the American Telemedicine Association (ATA), requiring healthcare providers to report their home addresses could pose potential privacy and security risks.

Privacy and security are paramount for healthcare workers because of the recent increase in violence against them, the AHA letter noted.

The letter cited a recent AHA report highlighting the extent of the problem. The report states that 44 percent of nurses reported experiencing physical violence and 68 percent verbal abuse during the COVID-19 pandemic. Additionally, 10.4 in 10,000 healthcare workers experienced nonfatal workplace violence in 2018, up from 6.14 in 10,000 workers in 2011, according to the Bureau of Labor Statistics.

“Requiring providers to report their home addresses in a manner that may be posted publicly exposes our workforce to unnecessary and inappropriate risk,” wrote Ashley Thompson, senior vice president of public policy analysis and development at AHA, in the letter. “They cannot provide attentive care in such an environment.”

Thus, the AHA urged CMS to make the home address reporting flexibility permanent or “implement a mechanism to automatically mask the home address from any public sites and directories.”

The AHA letter further noted that requiring providers to report their home addresses may disincentivize telehealth adoption, limiting the ability to retain workers in hybrid working environments. Not only that but tracking and reporting changes in home addresses would also add to the administrative burden facing workers and organizations.

Another letter, convened by the ATA and Alliance for Connected Care, echoed the AHA’s opposition to the home address reporting requirement, stating that it would endanger physicians when violence against healthcare professionals has risen.

The letter notes that this reporting policy was unclear even before the pandemic. In response to requests for clarification, CMS had stated that practitioners should enter “where they typically practice” on claim forms, which should be their home address if that is where they usually practice. But, this information has not been specified in any statute, regulation, or sub-regulatory guidance.

With more than 110 signers, including Northwell Health, Bicycle Health, and UPMC, the letter urges CMS to permanently allow healthcare practitioners to bill for telehealth from a “location at which the clinician is capable of offering in-person care to patients, even when the practitioner is practicing in a different location such as the home.”

Further, the letter asks CMS to work with practitioners without a physical practice location to develop an alternate method of determining a location that is not the home address for payment purposes.

“Strong, relationship-based patient care requires that we move beyond location-based care to allow a practitioner to offer the same telehealth services from home, from a clinic, from an academic office, or from any other clinically appropriate location — allowing them to meet patient needs when they happen — without incurring burdensome additional documentation requirements,” the letter stated.