Medicare Telehealth Enrollment: What the New Location Reporting Rules Mean for Providers

What Are the Medicare Telehealth Enrollment Location Requirements?

As of August 2026, CMS has clarified how telehealth and teleradiology providers must report their practice locations on Medicare enrollment applications. Providers who deliver virtual care from home while maintaining a physical practice location generally do not need to report their home address. However, providers who operate entirely through telehealth with no other physical location must report their home address on their CMS-855 application and use a specific practice location designation to keep it from appearing publicly on Care Compare.

• Who this affects: Any physician, nurse practitioner, or other eligible clinician who delivers Medicare telehealth services from a home office or remote location.
• Key rule: Virtual-only providers must list their home address on their enrollment application and select the “Home Office for Administrative/Telehealth Use Only” designation in PECOS to suppress the street address from public display.
• Cross-state reassignment: Providers who reassign benefits to a medical group in a different state only need to be licensed in the state where they are physically located while delivering services, not every state where their patients reside.

What CMS Updated in August 2026

On August 21, 2026, CMS published updated telehealth and teleradiology enrollment scenarios through the First Coast Solutions Medicare portal, followed by additional guidance posted on August 23 through CMS’s national channels. The guidance consolidates and clarifies enrollment requirements that have evolved significantly since the COVID-19 public health emergency waivers were made permanent.

During the pandemic, CMS allowed telehealth providers to render services from home without reporting their home address on Medicare enrollment. Providers could bill from their currently enrolled practice location regardless of where they were physically sitting. That temporary flexibility has now been replaced with permanent policy that carries specific reporting obligations.

The core question the updated guidance answers is: when does a provider need to list a home address on their Medicare enrollment application, and how can they keep that address private?

The answer depends on whether the provider has a physical practice location separate from their home. CMS divides telehealth providers into two categories with different enrollment requirements for each.

Do Telehealth Providers Need to Report a Home Address?

CMS distinguishes between two enrollment scenarios for telehealth providers:

Scenario 1: Provider has a physical practice location. Providers who maintain any office, clinic, or other physical practice site do not need to report their home address on their Medicare enrollment. They deliver telehealth from home but their enrollment remains tied to their physical practice location. Claims are billed as if the service was rendered at the enrolled practice location.

Scenario 2: Provider operates entirely through telehealth. Virtual-only providers whose sole practice location is their home must report their home address on their CMS-855 enrollment application. This is a hard requirement. CMS does not allow providers to use a P.O. box, a virtual office address, or a coworking space address as a substitute for their actual practice location.

In our enrollment work, we see providers run into trouble when they try to avoid listing a home address by using a commercial mail service or a shared workspace. CMS treats the location where the provider is physically present while delivering services as the practice location. If that is a home office, it must be reported.

Telehealth Enrollment Scenarios at a Glance

The table below summarizes how CMS handles enrollment and billing for the most common telehealth configurations:

The cross-state reassignment scenario is particularly relevant for group practices expanding their telehealth reach. A provider in Maryland who reassigns benefits to a group in Florida only needs to hold a Maryland license. The provider does not need Florida licensure, and the group does not need to list the provider’s Maryland home address on the group’s CMS-855B.

How to Protect Your Home Address on Care Compare

Virtual-only providers have a legitimate privacy concern: they do not want their home address published on CMS’s public Care Compare directory. CMS addressed this directly in the updated guidance with three protective steps:

1. Select the correct practice location type in PECOS. When adding your home address as a practice location, choose either “Business Office for Administrative/Telehealth Use Only” or “Home Office for Administrative/Telehealth Use Only.” This designation tells CMS to suppress the street address from your profile on Care Compare.
2. Request additional suppression if needed. Providers can email QPP@cms.hhs.gov to request that the street address, phone number, or other identifying information be suppressed from their Care Compare profile. This is a separate step from the PECOS location type selection.
3. Verify the suppression is working. After completing enrollment, check your provider profile on Medicare.gov’s Care Compare tool to confirm your home address is not publicly displayed. If it appears, contact CMS to have it corrected.

We handle this process for providers going through enrollment with us. Setting the correct location designation at the time of initial application is far easier than trying to correct a publicly displayed home address after the fact.

What About Teleradiology Enrollment?

The August 2026 guidance also clarified a frequently confused point about teleradiology. CMS confirms that teleradiology, the remote interpretation of diagnostic imaging, is not classified as a Medicare telehealth service. This matters because teleradiology does not receive the same enrollment flexibilities as telehealth.

Telehealth services are governed by Section 1834(m) of the Social Security Act, which defines services ordinarily furnished in person that are instead delivered via two-way telecommunications. Teleradiology involves interpretation of images that were never intended to be read in person at the patient’s location. Because the service is inherently remote, it falls outside the statutory telehealth definition.

The practical enrollment consequence: a teleradiologist must be enrolled in the state where they are physically present while reading the images, not the state where the imaging facility or patient is located. A radiologist sitting in Texas reading scans from a Florida hospital needs Texas enrollment. This is different from the telehealth rules, where a provider reassigned to a group can bill from the group’s state.

Providers who handle both telehealth consultations and teleradiology need to understand that the enrollment rules differ. Mixing up the two can result in claims filed under the wrong CMS-855 reassignment structure.

Common Enrollment Mistakes for Telehealth Practices

The transition from emergency waivers to permanent telehealth enrollment policy has created confusion. Here are the mistakes we see most often:

• Assuming the pandemic waiver still applies. The temporary provision allowing providers to bill from their enrolled location regardless of where they physically sat has been replaced by permanent rules with specific location reporting requirements. Providers who have not updated their enrollment since the pandemic may be out of compliance.
• Using a virtual office address. CMS requires the address where services are actually delivered. A Regus suite or WeWork membership does not satisfy the practice location requirement unless the provider is physically present there while delivering care.
• Failing to enroll in the correct state. Virtual-only providers must be enrolled in the state where they are physically located. Moving from California to Arizona without updating your Medicare enrollment creates a compliance gap.
• Skipping the Care Compare suppression step. Selecting the correct location type in PECOS is the first layer of privacy protection, but providers should also verify their Care Compare profile and request additional suppression through QPP@cms.hhs.gov if needed.
• Not understanding the telehealth flexibility expiration dates. Several Medicare telehealth flexibilities, including expanded service lists and geographic waivers, are authorized through December 31, 2027. Providers should track these dates because enrollment requirements may change again when the flexibilities expire or are renewed.

In-House vs. Outsourced Enrollment for Telehealth

Managing telehealth enrollment internally works well for single-state, single-provider practices with a stable physical office. The PECOS system is accessible, and the location reporting requirements are straightforward when there is one practice address.

Complexity increases quickly with multi-state operations, provider reassignments across state lines, mixed telehealth and teleradiology services, or group practices adding virtual-only clinicians. Each of these scenarios involves different CMS-855 forms, different state licensing verifications, and different location reporting configurations.

Across the practices we support with enrollment, the most common point of failure is not the initial application. It is the ongoing maintenance. Providers relocate. Reassignment structures change. State licensing requirements evolve. Each change triggers an enrollment update that must be filed within 30 to 90 days depending on the change type.

Frequently Asked Questions

Next Steps

Review your current Medicare enrollment to confirm your practice location is reported correctly under the updated guidance. If you operate a virtual-only practice, verify that your PECOS profile uses the correct location designation.

For more on Medicare enrollment applications, see our CMS-855 application guide. If you need to update a reassignment structure for a telehealth provider, our CMS-855R reassignment guide covers the process.