Reporting Practice Locations for Providers Who Deliver Telehealth From Home

Medicare has made a pandemic-era enrollment flexibility permanent, and the details matter for every telehealth provider who sees patients from a home office. The Centers for Medicare & Medicaid Services (CMS) confirmed in its July 2026 revision to its telehealth enrollment guidance that a provider who delivers telehealth from home, but also holds a separate physical practice location, does not have to put that home address on a CMS-855 enrollment application. The provider most exposed is the one with no office at all: if the home is the only physical practice location, CMS requires the home address to be reported, and reporting it incorrectly can turn a paperwork detail into enrollment-integrity exposure.

What CMS Requires on the Practice Location

CMS draws a bright line between the two situations. A provider who furnishes telehealth from home but maintains a separate physical practice location can enroll and bill from that location as if every visit happened in person; the home address does not belong on the enrollment application at all. A provider with no office, who works only from home, faces the opposite rule: the home address becomes the Medicare practice location and must be reported on the CMS-855I. The telehealth providers and telemedicine platforms Health Law Alliance represents nationwide generally fall into one of these two categories, and the category decides what the enrollment record has to say.

When the Home Address Must Be Reported

The reporting obligation follows the billing arrangement, not just the individual. A solo practitioner billing directly lists the home address on the CMS-855I. A practitioner who reassigns billing rights to a group with its own office lists nothing; the group's CMS-855B carries the practice locations instead. A practitioner who reassigns to a virtual-only telehealth company forces that company to list the practitioner's home address on its own CMS-855B. Each configuration also fixes which Medicare Administrative Contractor pays the claim: CMS ties the claim to the reported location, not to where the beneficiary sits, and a provider need not enroll in every state where a patient resides.

“If you provide telehealth services from your home, but have a physical practice location, you do not need to report your home address on your Medicare enrollment application,” CMS's telehealth enrollment guidance states.

The Privacy Designation That Protects the Address

When the home address does have to go on the application, CMS gives providers a way to keep it out of public view. The CMS-855 lets a provider designate the location as a Business Office for Administrative/Telehealth Use Only or Home Office for Administrative/Telehealth Use Only. Selecting one of those designations keeps the address off Medicare's public Care Compare directory, even though it still sits in the enrollment record available to the Medicare Administrative Contractor and to program-integrity reviewers. CMS also allows a provider to contact the agency directly, at QPP@cms.hhs.gov, to request suppression of the home address while an application is pending.

Why a Location Mismatch Becomes an Enrollment Risk

Billing from a location that does not match what the CMS-855 reports is exactly the kind of inconsistency a Unified Program Integrity Contractor reviews when it investigates a provider's enrollment and billing information, and an inaccurate practice location is itself the type of CMS-855 error that can trigger a revocation action. If the mismatch shows up as a pattern of claims billed as though furnished where the provider never actually worked, the exposure can escalate from an enrollment correction to a potential false claims act matter, with a resulting recoupment demand as well. Providers who reassign billing to a telehealth platform should also confirm the arrangement does not run afoul of the anti-kickback statute, since compensation tied to referral volume creates exposure independent of how the location is reported.

Practice-location accuracy is one piece of a larger telehealth compliance picture. Providers treating patients across state lines should confirm they have properly established the provider-patient relationship by telehealth, verify interstate telehealth licensure before treating a patient located in another state, and check how originating site rules affect the audit exposure of a claim.

Why Early Legal Counsel Is Critical

It is critical that telehealth providers promptly retain experienced healthcare defense counsel before correcting a practice-location error or responding to a CMS or Medicare Administrative Contractor inquiry about one. Early legal intervention can confirm which CMS-855 designation fits the provider's actual arrangement, correct the enrollment record before a reviewer flags it, and prevent a good-faith correction from being read as a misrepresentation. Delaying legal review can turn a reporting fix into a revocation proceeding.

Health Law Alliance's attorneys have overseen 2,000+ audits and handled 5,000+ matters, with 25+ years of experience.

How Health Law Alliance Can Help

Health Law Alliance represents telehealth providers, telemedicine platforms, and the physicians who reassign billing rights to them in Medicare enrollment matters nationwide. If a practice-location question has already drawn a Medicare Administrative Contractor inquiry or a UPIC records request, contact us for a free, confidential consultation before responding.