Telehealth/Telemedicine Enrollment

Telehealth services are services that a physician or practitioner provides using two-way, interactive telecommunications technology. These services substitute for an in-person visit and generally involve real-time communication between the practitioner at one location and the patient at another location using audio and video technology. In certain situations, real-time audio-only communication may also be used when Medicare requirements are met.

Medicare covers telehealth services when they are provided by physicians or practitioners who are properly enrolled in Medicare and meet all Federal and State requirements.

Enrollment for telehealth does not require a separate Medicare application; however, providers must ensure their enrollment record accurately reflects all practice locations, services, and licensure necessary to furnish telehealth services.

Provider Enrollment and Eligibility

To provide telehealth services, physicians and other eligible practitioners must be enrolled in Medicare and allowed to bill under Medicare Part B. The provider must be licensed according to State law and may only provide services that fall within their scope of practice. Telehealth services must meet the same Medicare coverage requirements as services provided in person.

Practice Location and Enrollment Record Requirements

Providers who furnish telehealth services must keep their Medicare enrollment information accurate, including their practice location. If a provider delivers telehealth services from their home but also has an enrolled practice location, they do not need to report their home address. If the home is the only practice location, it must be included in the enrollment record and identified appropriately. Keeping this information current is important for compliance and proper claims processing.

Telehealth Service Location and Reporting

Telehealth services must be billed using the correct Place of Service (POS) code. POS 02 is used when the patient is not located in their home, and POS 10 is used when the patient is in their home. By using these codes, the provider confirms that the telehealth service met Medicare requirements.

Technology and Service Requirements

Telehealth services are generally required to use two-way, real-time audio and video communication that allows the provider and patient to interact during the visit. The service must be appropriate to provide through telehealth and must meet Medicare coverage rules. In limited situations, certain programs allow the use of technology that does not require real-time interaction.

Beneficiary and Compliance Considerations

The patient must be present and involved in the telehealth visit unless a specific exception applies. The patient's location at the time of the service must meet current Medicare telehealth rules. Providers are responsible for following all Medicare requirements for enrollment, licensing, and service delivery. CMS may review telehealth services to ensure providers are meeting program requirements.

Enrollment Scenarios

Telehealth providers shall enroll based on their enrollment scenario. Note that teleradiology is a different model of care from telehealth and has its own set policies.

Provider has a private practice.

  • No reassignments exist
  • Dr. Smith has a private practice and provides telehealth from his home in Maryland (MD)
  • Dr. Smith submits an 855I to the MD MAC and lists his home address on the application
  • Dr. Smith selects the practice location type as "Business Office for Administrative/Telehealth Use Only" or "Home Office for Administrative/Telehealth Use Only" to prevent his home address from being published on Care Compare
  • Claims will be paid based on Dr. Smith's home location

Provider reassigns to a group in the same state. Group has a physical location (brick and mortar office).

  • Dr. Smith provides telehealth from his home in MD
  • Dr. Smith reassigns to Jones Medical Group also in MD
  • Dr. Smith submits an 855I to the MD MAC to reassign Jones Medical (no location listed, all locations on the 855B)
  • Jones submits an 855B to the MD MAC listing their physical location and does not list Dr. Smith's home address as a practice location
  • Claims will be paid as if Dr. Smith provided the service in person at the physical location

Provider reassigns to a group out of state. Group has a physical location.

  • Dr. Smith provides telehealth from his home in MD
    • Providers shall identify on the application or via a cover letter with the application, that it is a telehealth arrangement
      • If it is not indicated or clear from the application, MACs shall develop to confirm
    • MACs shall defer to state law for licensure requirements
    • Providers are not required to report the state the patients are located or for MACs to confirm licensure in the patient's state
      • MACs only need to verify licensure in the state where the provider is located
      • It's the provider's responsibility to ensure they are compliant with any additional state licensure laws
    • Licenses do not need to be checked for new reassignments (changes of information) consistent with existing policies and procedures
  • Dr. Smith reassigns to Jones Medical Group in FL
  • Jones Medical submits an 855B to the FL MAC listing the physical location and does not list Dr. Smith's home address as a practice location
  • Dr. Smith submits an 855I to the FL MAC to reassign to Jones Medical (no location listed, all locations on the 855B)
  • Claims will be paid as if Dr. Smith provided the service in person at the physical location

Note: Providers may choose to follow the policy in section 10.3.1.4(E) (Inter-Jurisdictional Reassignments) of the Program Integrity Manual (PIM), Chapter 10 and are not required to convert their current enrollments to align with this permanent telehealth policy.

Provider reassigns to group with no physical location (virtual telehealth services only).

  • Dr. Smith provides telehealth from his home in MD
  • Dr. Smith reassigns to Jones Medical Group who does not have a physical location
  • Jones Medical submits an 855B to the MD MAC listing Dr. Smith's home address as its practice location
  • Dr. Smith submits an 855I to the MD MAC to reassign to Jones Medical (no location listed, all locations on the 855B)
  • Jones Medical selects the practice location type as "Home/Business Office for Administrative Use Only" to prevent Dr. Smith's home address from being published on Care Compare
  • Claims will be paid based on Dr. Smith's home location

Note: This scenario is consistent with section 10.3.1.4(E) of the PIM. In addition, MACs shall allow and process submissions for groups who need to enroll in multiple states where the provider is located and rendering telehealth services from their home.

Common Questions

Q: Where must I be enrolled and licensed to provide telehealth services?
A. Providers are not required to enroll in every state where the beneficiary resides. They are required to enroll in the state where they are physically located or where the group is physically located. Co-working locations that offer rentable office space are acceptable practice locations for enrollment purposes.

Q: Can I use my home address as my telehealth practice location in PECOS?
A: Yes. Providers may list their home address as a practice location and designate it as "admin use only" or "telehealth only."

Q: Will my home address be publicly displayed on Care Compare?
A: If the location is designated as admin use/telehealth only, Care Compare shows the provider's name, city, state, and zip code rather than physical address.

Q: Are telehealth-only providers subject to Medicare site visits?
A: Locations designated as admin use/telehealth only are exempt from site visit requirements.

Q: How do I add a telehealth (home or virtual) location to my enrollment?
A: Submit a change request (PECOS or paper 855I/855B), add the address as a practice location, and designate it as "admin use only" or "telehealth only" when applicable.

Q: Can providers perform Medicare telehealth services while outside the U.S.?
A: No. Providers must be physically located in the U.S. or its territories when rendering telehealth services billed to Medicare.

Resources

Last Updated Jun 12 , 2026