Regulatory
CMS Confirms Its Pandemic-Era Telehealth Enrollment Flexibility Is Now Permanent, Letting Home-Based Clinicians Enroll and Bill From a Physical Practice Location
CMS guidance current as of mid-2026, and highlighted in the agency's August 20, 2026 Medicare Learning Network newsletter, confirms that clinicians who furnish Medicare telehealth from home but keep a physical practice location no longer have to report their home address to enroll. The flexibility does not extend to teleradiology, and state licensure rules still apply.
Quick answer
The Centers for Medicare and Medicaid Services has confirmed that a COVID-19 era Medicare enrollment flexibility is now permanent policy: a clinician who provides telehealth from home but keeps a physical practice location does not have to report the home address and can enroll and bill from the physical location as if the service were furnished in person. CMS highlighted the guidance in its August 20, 2026 Medicare Learning Network newsletter. The policy does not change state licensure obligations, and it does not apply to teleradiology.
Key takeaways
- →CMS states that the pandemic flexibility letting providers deliver Medicare telehealth from home without listing the home address on their enrollment is now permanent policy.
- →A clinician with a physical practice location can enroll and bill from that location as if the visit were in person, while a virtual-only clinician whose only location is home must report the home address as a practice location.
- →Clinicians are not required to enroll in each state where their patients live, but CMS defers to state law on telehealth licensure, so state licensing rules still apply.
- →Selecting the practice location type 'Business Office for Administrative/Telehealth Use Only' (or the Home Office equivalent) keeps a home address off the public Care Compare profile.
- →Teleradiology is treated differently: it is not eligible for the telehealth enrollment flexibility, and teleradiologists must enroll in the state where they perform the interpretation and list their actual location.
A Medicare enrollment change that began as a temporary COVID-19 accommodation is now settled policy. In a guidance document titled 'Understanding Telehealth and Teleradiology Enrollment,' revised in mid-2026 and highlighted in the agency's Medicare Learning Network (MLN) newsletter dated August 20, 2026, the Centers for Medicare and Medicaid Services (CMS) confirms that clinicians who furnish telehealth from home do not have to publish their home address on their Medicare enrollment, provided they have a physical practice location to bill from. The guidance walks through how to enroll correctly across common arrangements and draws a sharp line between telehealth, which qualifies, and teleradiology, which does not.
What CMS confirmed
According to the CMS guidance, during the COVID-19 public health emergency the agency allowed providers to deliver telehealth services from home without listing their home address on their Medicare enrollment. CMS now states plainly that 'this flexibility is now permanent policy.' The practical effect is that a clinician does not have to expose a home address to enroll and bill Medicare for telehealth, as long as the clinician has a separate physical practice location on file.
The document is enrollment guidance about where a provider is considered to practice for Medicare billing. It sits alongside, and does not replace, the broader questions of which telehealth services Medicare pays for and under what conditions, which are governed by statute, the physician fee schedule, and separate coverage rules.
Home address, physical location, and virtual-only clinicians
The guidance draws its central distinction around whether a clinician has a physical practice location:
- If you provide telehealth from home but have a physical practice location, CMS says you do not need to report your home address, and you can enroll and bill from the physical practice location as if the service were provided in person.
- If you provide virtual-only telehealth and your only physical practice location is your home, CMS says you must report the home address as a practice location.
- Either way, CMS says a clinician is not required to enroll in the state or states where the beneficiary resides.
For clinicians who do have to list a home address, CMS describes a privacy step. Selecting the practice location type as 'Business Office for Administrative/Telehealth Use Only' or 'Home Office for Administrative/Telehealth Use Only' on the CMS-855 keeps the home address from being published on the public Care Compare website. CMS also tells providers they can email QPP@cms.hhs.gov to have a home address suppressed while an enrollment application is still being processed.
How reassignments work across state lines
Much of the guidance is organized around reassignment, the arrangement in which an individual clinician assigns the right to bill to a group practice. CMS lays out several scenarios: a private practice with no reassignment, a reassignment to a group in the same state, a reassignment to a group in a different state, and a reassignment to a group that operates entirely virtually with no physical location.
In the cross-state example, a clinician working from home in one state reassigns to a group with a physical location in another state. CMS says the group lists its own physical practice locations and does not list the individual clinician's home address, and the Medicare Administrative Contractor processes the claims as if the service were furnished in person at the group's physical location. CMS adds that clinicians may continue to follow the existing Inter-Jurisdictional Reassignment policy in the Program Integrity Manual and do not need to convert existing enrollments to align with the permanent telehealth policy.
State licensure is a separate obligation
The enrollment flexibility is not a license to practice anywhere. CMS states that it 'defers to state law for telehealth licensure requirements' and instructs clinicians to comply with any additional state licensing rules. The guidance also notes that Medicare Administrative Contractors verify licensure only in the state where the provider is physically located, leaving each clinician responsible for meeting the licensing requirements of the states where their patients are located. In other words, not having to enroll in a patient's state for Medicare billing does not remove the separate question of whether the clinician is licensed to treat that patient.
Why teleradiology is carved out
The guidance treats teleradiology very differently from telehealth. CMS ties Medicare telehealth to Section 1834(m) of the Social Security Act, which addresses services that are ordinarily furnished in person but are instead delivered through two-way telecommunications technology. CMS says its longstanding interpretation is that services not ordinarily furnished in person, such as care management, remote monitoring, and remote interpretation of diagnostic tests, are not part of the statutory definition of Medicare telehealth.
Because teleradiology is a remote interpretation service rather than a visit that would ordinarily happen in person, CMS says it is not eligible for the telehealth enrollment flexibility. Teleradiologists must enroll in the state where they perform the interpretation and reporting, and must list their actual location, including a home address if that is where the work happens. CMS says a physical office cannot be substituted when it is not where the interpretation and reporting occur.
What this means for telehealth providers
For clinicians and telehealth groups that bill Medicare, the guidance mostly removes uncertainty rather than creating a new requirement. It confirms that a home-based clinician with a physical practice location can keep a home address private, that group practices absorb individual clinicians' home-based telehealth through normal reassignment, and that clinicians do not have to stack up Medicare enrollments in every state where patients live. It also signals that CMS views the home-address flexibility as durable, not tied to a future expiration.
The carve-outs matter just as much as the flexibility. Providers who lean on remote monitoring, care management, or teleradiology should not assume the telehealth enrollment rules apply to those lines, and every provider still has to satisfy state licensure independently of how Medicare enrollment is handled. This piece is general information, not legal advice. Clinicians and groups should confirm their own enrollment steps with their Medicare Administrative Contractor and read the CMS guidance directly before changing how they enroll or bill.
Frequently asked questions
Does a telehealth clinician have to put their home address on their Medicare enrollment?+
According to CMS, no, as long as the clinician has a physical practice location. In that case CMS says the clinician can enroll and bill from the physical location as if the service were furnished in person. A clinician whose only location is a home office must report the home address, but can mark the location type as administrative or telehealth use only to keep it off the public Care Compare profile.
Is this a new rule or a temporary pandemic policy?+
CMS describes the home-address flexibility as permanent policy. It began during the COVID-19 public health emergency and, per the guidance highlighted in the agency's August 20, 2026 Medicare Learning Network newsletter, is now the standing approach to telehealth enrollment rather than a temporary accommodation.
Does this mean a clinician can treat Medicare patients in any state?+
No. The flexibility is about Medicare enrollment and billing, not licensure. CMS says it defers to state law on telehealth licensure and that clinicians must comply with the licensing rules of the states where their patients are located. Not having to enroll in a patient's state does not remove the separate requirement to be properly licensed.
Do the same enrollment rules apply to teleradiology?+
No. CMS says teleradiology is a remote interpretation service that is not ordinarily furnished in person, so it does not qualify for the telehealth enrollment flexibility. Teleradiologists must enroll in the state where they perform the interpretation and must list their actual location, including a home address if that is where the work is done.
How does reassignment to a group practice work under the guidance?+
CMS describes scenarios where an individual clinician reassigns billing rights to a group. The group lists its own physical practice locations and, in most examples, does not list the individual's home address. The Medicare Administrative Contractor then processes claims as if the service were furnished at the group's physical location. CMS says existing enrollments do not need to be converted to match the permanent telehealth policy.
Where can providers read the official CMS guidance?+
CMS published the details in a document titled 'Understanding Telehealth and Teleradiology Enrollment,' which it linked from its Medicare Learning Network newsletter dated August 20, 2026. Providers can also consult their Medicare Administrative Contractor and the physician fee schedule for how Medicare distinguishes telehealth from other non-face-to-face services.