We celebrated the extension of Telehealth through next year. During the legislative process and our advocacy efforts, the understanding was that Telehealth flexibilities would continue as they had in previous years. However, a significant change was made that has caught many organizations and practitioners by surprise.
For the past several years, CMS allowed physicians and other practitioners to provide Telehealth services from their homes while billing under their group’s practice address. That flexibility ended on January 1, 2026.
Effective January 1, 2026, physicians and other practitioners must separately enroll each location from which they provide Telehealth services. According to CMS, “virtual-only telehealth practitioners whose only physical practice location is their home address will need to enroll their home address as a practice location.”
This means that:
- If you are currently billing for Telehealth services provided from your home while using your group’s practice address, you should discontinue this practice unless your home location has been appropriately enrolled.
- If you provide Telehealth services in multiple states, you may face significant enrollment and update backlogs, particularly if you intend to enroll multiple practice locations for each physician and other practitioners within your organization.
We encourage all practices to review their Telehealth billing and enrollment processes to ensure compliance with the updated CMS requirements.
https://www.cms.gov/files/document/telehealth-faq-updated-02-26-2026.pdf
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This change seems to have been easy to miss during the broader telehealth extension discussions, especially since the prior flexibility had been in place for several years. The requirement to enroll each individual location, including a home address for virtual-only practitioners, could create real administrative strain for practices that operate across multiple states or have several clinicians billing from home. It will be important for groups to audit how they are currently billing telehealth services and confirm that every location used is properly enrolled before the January 1, 2026 deadline.
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The change to require home addresses to be enrolled as practice locations starting January 1, 2026, seems like a significant administrative burden, especially for virtual-only practitioners and those practicing across multiple states. It’s easy to see how this could create enrollment backlogs and compliance risks for practices that were operating under the previous flexibility.
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This is a significant regulatory change that many practitioners may have overlooked. The requirement to enroll home addresses as practice locations adds an administrative burden, especially for providers offering telehealth across multiple states. It’s important for practices to review their billing processes now to avoid compliance issues.
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This is a significant policy shift that many practitioners weren’t prepared for. The requirement to enroll each home address as a practice location creates a substantial administrative burden, especially for multi-state telehealth providers who now face potentially massive enrollment backlogs. Organizations that have been billing under their group address while clinicians work from home need to act quickly to review their processes and ensure compliance before they face billing disruptions or audit risks.
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This is a significant policy shift that many practitioners likely weren’t prepared for. The requirement to formally enroll your home as a practice location adds a layer of administrative burden, especially for providers offering telehealth across multiple states. It’s going to be interesting to see how CMS handles the anticipated enrollment backlogs and whether they’ll offer any grace period for practices still working through the compliance process.
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