As part of its recent round of FAQs related to COVID-19, CMS clarified that distant site practitioners may furnish Medicare telehealth services from their homes. However, these distant site providers, and the clinics/group practices to whom they reassign benefits, must update their Medicare enrollment with the provider’s home location. The FAQ reads:
Can the distant site practitioner furnish Medicare telehealth services from their home? Or do they have to be in a medical facility?
There are no payment restrictions on distant site practitioners furnishing Medicare telehealth services from their home. The practitioner is required to update their Medicare enrollment with the home location. The practitioner can add their home address to their Medicare enrollment file by reaching out to the Medicare Administrative Contractor in their jurisdiction through the provider enrollment hotline. It would be effective immediately so practitioners could continue providing care without a disruption. More details about this enrollment requirement can be found at 42 CFR 424.516.
If the physician or non-physician practitioner reassigns their benefits to a clinic/group practice, the clinic/group practice is required to update their Medicare enrollment with the individuals’ home location. The clinic/group practice can add the individual’s home address to their Medicare enrollment file by reaching out to the Medicare Administrative Contractor in their jurisdiction through the provider enrollment hotline.
The provider enrollment hotline details are also included in the FAQ, and the full FAQ can be found here.
Depending on how the COVID-19 public health emergency develops, keeping providers away from health care delivery locations but working may be needed to keep them healthy, and a physician who is in self-quarantine at home could continue to practice. Since there are no payment restrictions on distant site practitioners, other sites in addition to the provider’s home would also be eligible, also subject to the enrollment requirements for those locations for the provider and any clinics/groups accepting reassignment.
If you have any questions or would like any information on this topic, please contact:
- Chris Eades at (317) 977-1460 or ceades@hallrender.com;
- Scott Geboy at (414) 721-0451 or sgeboy@hallrender.com;
- Mike Batt at (317) 977-1417 or mbatt@hallrender.com;
- Regan Tankersley at (317) 977-1445 or rtankersley@hallrender.com;
- Abby Kaericher at (202) 780-2989 or akaericher@hallrender.com;
- Tara Kepler at (303) 802-1293 or tkepler@hallrender.com; or
- Your regular Hall Render attorney.
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