75% of Providers Get This Medicare Telehealth Question Wrong. Does Your Practice?

By Elena Pak, Credentialing Department, WCH

Here’s a number that should make every practice manager sit up: when the Center for Connected Health Policy recently polled its readers on a basic Medicare telehealth enrollment question, only 25% answered correctly. Three out of four respondents got it wrong.

The question wasn’t a trick. It was this: does a provider have to report their home address on their Medicare enrollment application just because they’re seeing patients from home?

Most people assumed yes. The real answer is more nuanced — and the nuance is exactly where practices lose money, trigger unnecessary revalidation headaches, and occasionally expose a provider’s home address to the public without meaning to.

The Rule Everyone Half-Remembers

CMS made permanent a policy that lets a practitioner who furnishes Medicare telehealth from home — but who also has a physical practice location — enroll and bill from that physical location, as if the visit had happened there in person. The home address doesn’t need to go on the enrollment application at all.

CMS laid this out in its Understanding Telehealth Enrollment guide, released in June 2026 and revised on July 23, 2026. It’s a good document. It’s also the kind of document that sits in a compliance folder unread until an audit or a rejected claim forces someone to open it.

Here’s the part that trips people up: the rule isn’t “does the provider work from home.” It’s “what is the provider’s relationship to a physical location, and what kind of remote service is this.” Get that framing wrong, and you can end up either over-disclosing a home address that didn’t need to be reported, or under-reporting a location that did.

Telehealth vs. “Everything Else That Happens Remotely”

CMS draws a hard line between two categories, and conflating them is the single most common mistake:

Medicare telehealth covers services that are normally delivered in person but are instead delivered live, two-way, by video or audio — office visits, psychotherapy, consultations. This is the category with the home-address flexibility.

Everything else delivered remotely — remote patient monitoring, care management, and critically, teleradiology — was never “ordinarily furnished in person” to begin with, so it doesn’t fall under the same telehealth statute (Section 1834(m) of the Social Security Act). Different rules apply, and they’re stricter.

A teleradiologist reading scans from a home office in Maryland for facilities in six other states doesn’t necessarily get the same home-address treatment a telehealth psychiatrist gets. For enrollment purposes, the relevant physical location of the service still matters, and the applicable enrollment requirements can require that actual service location to be reported. The one break they do get: they don’t have to enroll separately in every state where a scan originated.

If your practice has both telehealth visits and any form of remote diagnostic interpretation running through it, this distinction isn’t academic. It’s the difference between a clean enrollment file and a mismatched one that a Medicare Administrative Contractor (MAC) flags months later.

Four Scenarios, Four Different Answers

1. Solo practitioner, telehealth from home, has an office. Bill from the office address. Home address stays off the application.

2. Practitioner reassigns benefits to a group with a physical location. Same outcome — the individual reassigns through PECOS or Form CMS-855I, the group reports its location on Form CMS-855B, and the home address never enters the picture just because telehealth happened.

3. Practitioner works from home in State A, reassigns to a group in State B. The reassignment goes to the MAC covering the group’s state, clearly marked as a telehealth arrangement. The group’s physical address is what gets used for claims processing — not the practitioner’s kitchen table in another state. And no, the practitioner does not need to separately enroll in every state a telehealth patient happens to be sitting in.

4. Virtual-only practitioner or group, no physical location anywhere. This is where the home address does have to be reported — because there’s genuinely nothing else to report. CMS offers a workaround here: designate the location as “Business Office for Administrative/Telehealth Use Only” or “Home Office for Administrative/Telehealth Use Only.” Choosing the right designation is what keeps that address off Medicare Care Compare’s public listing. Miss that step, and a provider’s home address becomes searchable by anyone.

The Trap Hiding Inside the Good News

Here’s the part practices consistently misunderstand, and it’s the one that creates real exposure: Medicare enrollment rules and state licensure rules are not the same system, and one does not substitute for the other.

Not needing to enroll in every patient’s state for Medicare billing purposes says nothing about whether the practitioner is legally authorized to treat a patient sitting in that state. CMS defers entirely to state law on that question. A MAC may verify the practitioner’s license in the state where the practitioner is physically located as part of the enrollment process, but that does not resolve licensure requirements in every state where patients are located. It is the practitioner’s job, not CMS’s, to separately confirm licensure in every state where a patient is located, and those requirements vary enormously by state and by profession.

In other words: a practice can have a flawless Medicare enrollment file and still be running an unlicensed encounter in another state without realizing it. That’s not a billing problem. That’s a much bigger problem.

Why This Keeps Catching Practices Off Guard

None of this is because providers are careless. It’s because Medicare enrollment, state licensure, group reassignment paperwork, and public-facing address disclosure all live in different systems, updated on different timelines, and reviewed by different people inside most practices — if they’re reviewed at all. A billing team fixes the PECOS entry. A compliance officer, if there is one, tracks licensure. Nobody is necessarily cross-checking whether the telehealth-specific exceptions were applied correctly to both.

That’s exactly the kind of gap that can contribute to a returned claim, a revalidation delay, or — worse — a provider finding their home address listed on a public CMS directory because the wrong box got checked eighteen months ago.

What to Check Right Now

• Is each remote service actually “Medicare telehealth,” or is it remote monitoring, care management, or teleradiology in disguise? The enrollment rules are not interchangeable.
• Does the practitioner or group have a physical location that can legitimately anchor the enrollment, or is this a virtual-only setup that requires a home or administrative address?
• If reassigning benefits to a group in another state, has the arrangement been explicitly flagged as telehealth on the application?
• If a home address has to appear anywhere, has the correct “Administrative/Telehealth Use Only” designation been selected to keep it off public listings?
• Has licensure — separately from enrollment — actually been confirmed in every state where patients are located, including any reliance on interstate licensure compacts?

If you can answer all five without hesitation, you’re ahead of 75% of the field. If you can’t, that’s not a reason to panic — it’s a reason to get the enrollment file reviewed before a MAC finds the mismatch for you.

Where WCH Fits In

That review is exactly the kind of work WCH’s provider enrollment and credentialing team handles every day: auditing PECOS files, correcting group reassignments, sorting out multi-state telehealth arrangements, and making sure a provider’s home address only appears where it legally has to and never where it doesn’t. If your telehealth billing setup hasn’t been checked against CMS’s 2026 guidance yet, that’s a conversation worth having with WCH before the next revalidation cycle — not after a claim gets kicked back.

One More Thing Coming Your Way

The next hot topic on deck: prescribing controlled substances via telemedicine, and whether the pandemic-era flexibilities are still alive. Test yourself now — the answer might not be what you assume:

Which of the following best describes the current federal rules for prescribing controlled substances through telemedicine?

A) A practitioner must always conduct an in-person evaluation first.
B) Temporary flexibilities allow DEA-registered practitioners to prescribe Schedule II–V controlled substances via audio-video telemedicine without a prior in-person evaluation, through December 31, 2026, subject to requirements.
C) The flexibilities already expired at the end of 2025.
D) Only Schedule III–V substances qualify for the exception.

If your practice prescribes controlled substances via telemedicine and you’re not confident in the answer, that’s worth flagging to WCH’s compliance team now — not in January, when the deadline conversation gets a lot more urgent.

Sources:

• Centers for Medicare & Medicaid Services. Understanding Telehealth Enrollment, released June 2026, revised July 23, 2026.
• Social Security Act, Section 1834(m) — statutory definition of Medicare telehealth services.
• Center for Connected Health Policy (CCHP), National Telehealth Resource Center on Policy — monthly Technical Assistance Spotlight newsletter.
• CMS Provider Enrollment, Chain and Ownership System (PECOS); Forms CMS-855I and CMS-855B.