Working From Home Is Not the Same as Having a Medical Practice

The COVID-19 public health emergency dramatically changed how healthcare was delivered. Physicians and other qualified healthcare professionals who had spent their careers working from medical offices suddenly found themselves seeing patients from spare bedrooms, home offices, and kitchen tables.

That emergency has been over for more than three years.

Telehealth, of course, did not disappear with it. In fact, many of the changes made during the pandemic have become part of the permanent healthcare landscape. But there is an important distinction that some providers and practices continue to overlook:

The fact that Medicare allows you (the physician/provider) to furnish telehealth from home does not mean that Medicare treats a virtual-only home practice exactly the same as a practitioner who maintains a legitimate physical practice location.

CMS has now made that distinction particularly clear in its Medicare enrollment guidance.

The Question Providers Should Be Asking

The Center for Connected Health Policy (CCHP) recently addressed Medicare enrollment for telehealth practitioners and highlighted a question that I believe every physician and practice administrator should understand:

Does the practitioner have an actual physical practice location, or is the practitioner’s home the only place from which the practice operates?

The answer has significant enrollment and privacy implications.

CCHP explains that CMS has made permanent the policy allowing a practitioner who furnishes Medicare telehealth services from home, but who also has a physical practice location, to enroll and bill from that physical practice location as though the telehealth service had been furnished there in person. In that situation, the practitioner generally does not have to add the home address to the Medicare enrollment simply because the practitioner occasionally or routinely performs telehealth from home.

CMS’s own 2026 guidance confirms the same rule: a practitioner providing telehealth from home who has a physical practice location does not need to report the home address on the Medicare enrollment application.

That is a very different situation from a virtual-only practice.

Scenario One: You Have a Brick-and-Mortar Practice

Consider a cardiologist, internist, psychiatrist, or other practitioner who has an established office where patients are seen in person.

The physician may work in the office three or four days per week and decide to perform telehealth visits from home on another day.

Under CMS’s permanent policy, the physician does not have to enroll the residence as an additional Medicare practice location merely because those telehealth encounters originate from the physician’s home.

The physician can remain enrolled and bill through the physical practice location as though the telehealth service were furnished there.

The CCHP publication explains that the same general concept applies when an individual practitioner reassigns Medicare benefits to a group with a physical practice location. The practitioner submits the appropriate reassignment, and the group reports its physical practice locations. The practitioner’s home is not automatically added simply because the practitioner happens to conduct telehealth from there.

This is one of the strongest practical reasons I see for maintaining a legitimate brick-and-mortar practice location.

You retain an identifiable professional location for your medical practice while preserving the flexibility to perform appropriate telehealth services from home. Not to mention that many State Medicaid programs require that a participating provider who provides telehealth services also has an in-person location when the patient requests that type of encounter. You cannot “force” telehealth only on Medicaid covered patients in many states.

Scenario Two: Your Home Is Your Medical Practice

Now change the facts.

Suppose the practitioner has closed the medical office entirely. There is no clinic, medical suite, group practice location, or other physical practice location. The physician sees patients exclusively by telehealth from a home office.

That changes the Medicare enrollment analysis.

CMS states that when a virtual-only telehealth practitioner’s only physical practice location is the practitioner’s home address, the home address must be reported as a practice location.

CCHP makes the same distinction: if the practitioner operates a virtual-only practice and the home is the only physical practice location, the home address must be reported. Likewise, when benefits are reassigned to a virtual-only group with no physical practice location, the group must report the location from which services are actually furnished—which could be the practitioner’s residence.

In other words:

You cannot eliminate every physical practice location and then continue treating the old office address as though the practice was still operating there.

If your home is your only actual practice location, Medicare enrollment needs to reflect that reality. Also, remember that many cities have rules about using your home as a medical practice. They may mandate ADA parking, security fencing around a pool, and/or a certain floor plan for accessibility even though the patient may never come to your actual residence.

What About the Address on the Medicare Claim?

This is where I think practices need to be precise.

A provider’s Medicare enrollment address and the service-facility/location information reported on a professional claim are related concepts, but they are not interchangeable.

CMS’s enrollment guidance says that a practitioner with a physical practice location may enroll and bill from that location as if the telehealth service were furnished there in person, even when the practitioner actually performed the telehealth encounter from home.

For the virtual-only practitioner, however, the home is the enrolled practice location because there is no alternative physical practice location to use.

Therefore, practices should not solve the privacy problem by simply continuing to submit a former office, billing office, corporate address, P.O. box, or another convenient address as though it were the practitioner’s active practice location. Enrollment and claim information must accurately correspond with the practitioner’s Medicare enrollment and the applicable claim-reporting rules.

Also remember that Place of Service is determined by the applicable telehealth billing rules and, for POS 02 versus POS 10, by where the patient is located—not by whether the physician happens to be sitting at home. CMS defines POS 02 as telehealth when the patient is somewhere other than the patient’s home and POS 10 when the patient is in the patient’s home.

That distinction is frequently misunderstood.

The Privacy and Safety Problem with Using Your Home as Your Practice Location

This is the part of the conversation I believe deserves considerably more attention.

A physician’s home is not just an enrollment data point.

It is where that physician and potentially their spouse, children, and other family members live.

If a practitioner makes a residence the sole physical location of a medical practice, the home address becomes information that must be supplied to Medicare as a practice location.

CMS clearly recognizes the privacy and safety implications of this. In fact, CMS specifically provides a mechanism for clinicians who must enroll their homes to prevent their street addresses from appearing publicly on Medicare’s Care Compare profile.

The practitioner can identify the location in PECOS as “Home Office for Administrative/Telehealth Use Only” (or the applicable administrative/telehealth-only designation). CMS states that this suppresses the street-address details from the clinician’s public profile. CMS also permits clinicians to contact the Quality Payment Program Service Center to request suppression of the street address and/or telephone number.

The CCHP publication specifically calls attention to this protection as well.

That protection is important—but providers should understand its limits.

Suppressing an address from Care Compare does not mean the address disappears from Medicare’s enrollment records. CMS still needs the legitimate practice location for enrollment purposes. The suppression mechanism addresses public display; it does not transform the residence into a fictitious non-home location.

There are also broader operational concerns beyond Care Compare. Practices should consider how addresses flow through payer enrollment systems, credentialing databases, clearinghouses, directories, correspondence, explanation-of-benefits processes, and other administrative systems.

For a physician—particularly one who treats behavioral-health patients, manages controlled substances, handles contentious patient relationships, or has experienced threats or harassment—unnecessary disclosure of a residential address is not a trivial concern.

A Brick-and-Mortar Location Now Has an Additional Value: Privacy

Before COVID, few physicians thought of their medical office as a privacy firewall between their professional and personal lives.

Today, perhaps they should.

Maintaining an actual practice location gives providers a professional address for enrollment and billing while CMS’s permanent telehealth policy still permits them to furnish appropriate Medicare telehealth services from home without enrolling that residence simply because they work remotely.

That does not mean every physician must work in an office five days a week. It does not mean telehealth should disappear. And it certainly does not mean that a practitioner cannot legitimately operate a virtual-only medical practice.

It means providers should understand what they are choosing.

There is a material difference between:

“I have a medical practice, and I sometimes practice medicine from home,” and “My home is my medical practice.”

Under Medicare’s current enrollment policy, those two arrangements have different consequences.

COVID Changed Healthcare—But Emergency Operations Should Not Automatically Become Permanent Business Models

During the public health emergency, working from home was often necessary. Providers and healthcare organizations made extraordinary operational changes because circumstances required them.

Those circumstances no longer exist.

More than three years after the federal COVID-19 public health emergency ended, practices should be evaluating whether a home-only model still makes operational, compliance, privacy, and business sense rather than simply continuing it because that is what they started doing in 2020.

Telehealth can absolutely remain part of modern medical practice. CMS has made the enrollment flexibility for practitioners with physical offices permanent.

But that actually strengthens the argument for maintaining a physical practice location: you do not have to choose between having an office and having telehealth.

You can have both.

A practitioner with a legitimate physical practice location can continue furnishing appropriate telehealth services from home without adding the residence to Medicare enrollment merely because the provider conducts those visits there. A virtual-only practitioner whose home is the only physical practice location does not have that same option.

Before Closing the Office, Ask These Questions

Before a physician decides that maintaining a physical office “doesn’t make sense anymore,” I would encourage the practice to consider:

Do I want my residence to become my Medicare practice location?
Have I properly updated PECOS if my former office is no longer an actual practice location?
If my home must be enrolled, have I selected the proper administrative/telehealth-only designation to suppress the street address from Care Compare?
Have I confirmed that my address is not appearing in other payer directories or public-facing databases?
How are my commercial payers, Medicare Advantage plans, Medicaid program, malpractice carrier, state licensing board, and credentialing entities treating a home-only practice?
Do I understand the difference between my Medicare enrollment location, claim service-location information, and the telehealth POS code?
Am I comfortable with the privacy and personal-security consequences of making my residence the only physical location associated with my medical practice?
Is eliminating the office actually worth those tradeoffs?

CCHP also appropriately cautions that its discussion is specific to Original Medicare. Medicaid programs, Medicare Advantage organizations, and commercial insurers may impose their own enrollment, credentialing, billing, and practice-location requirements.

The Bottom Line

CMS is not telling physicians that they cannot work from home.

CMS is saying something much more practical:

If you have a physical practice location, you can furnish Medicare telehealth from home without generally having to enroll your home as a practice location. If you operate a virtual-only practice and your home is your only physical practice location, your home must be reported as the practice location.

For physicians contemplating a permanent home-only practice, that distinction deserves serious consideration.

Telehealth is here to stay.

That doesn’t necessarily mean your physical-location medical office should disappear with it.

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