October 20, 2023
The Honorable Chiquita Brooks-LaSure
Centers for Medicare & Medicaid Services
Department of Health and Human Services
200 Independence Avenue SW
Washington, D.C. 20201
RE: Stakeholder Leter Urging Swift Acton on Practicioner Reportng of Home Address for Medicare Enrollment and Billing
Dear Administrator Brooks-LaSure,
On behalf of the undersigned organizations, we thank the Centers for Medicare and Medicaid Services (CMS) for the continued support for telehealth by proposing to extend many of the Medicare telehealth flexibilities implemented during the COVID-19 Public Health Emergency (PHE) beyond CY2023. We appreciate CMS providing this necessary clarity for patients and providers, but we write today to raise atention to an issue that will hinder providers’ ability to continue to offer telehealth services post CY2023 if not addressed.
The provision of remote health care services offers great benefit not only to the patient receiving the services, but to the provider as well. Allowing appropriately licensed and credentialed providers to practice telehealth from their home improves patient access to healthcare services, reduces healthcare costs, while maintaining and meeting patient demand for care. This was necessary during the height of the COVID-19 pandemic and remains just as important today amidst provider workforce shortages and burnout, given that 78 percent of health care practicioners agree that retaining the option to provide virtual care from a location convenient to the practicioner would “significantly reduce the challenges of stress, burnout, or fatigue” facing their profession and 8 in 10 indicate that this flexibility would make them more likely to continue providing medical care. This option should be made permanent. It is not practical, workable, or safe to require a provider to publicly report their home address as their practice location. Medicare providers should not be compelled to share their personal information, especially when it relates to their home addresses. In an environment in which threats against healthcare professionals has markedly increased, the safety and privacy of physicians must be paramount.
October 20, 2023