CMS confirms retroactive payments, eases address reporting

CMS has clarified rules governing telehealth services following the extension of virtual care flexibilities through Jan. 30, 2026. The agency has confirmed that it will retroactively pay claims for telehealth services provided during the government shutdown and that telehealth providers need not report their home addresses when billing for services provided from their homes.

CMS clarified these rules in an updated FAQ on Nov. 14, soon after the 43-day government shutdown ended, reinstating telehealth flexibilities and the Acute Hospital Care at Home (AHCAH) waiver.  

The FAQ confirms that CMS will pay for telehealth services "retroactively as if there hadn't been a temporary lapse in the application of the telehealth flexibilities" until Jan. 30, 2026.

Additionally, most healthcare providers who conduct telehealth visits from their homes but have a physical practice location will not be required to report their home address on their Medicare enrollment application.

"CMS's guidance is a welcome, commonsense step that spares providers needless red tape," said Chris Adamec, executive director of the Alliance for Connected Care, in an emailed statement. "It enables the flexibility in how and when telehealth is delivered that is key to driving patient-centered care. We're ready to help CMS take the next step and extend a similar approach to providers without physical practice sites."

Telehealth stakeholders were left concerned when the final Physician Fee Schedule (PFS) for 2026 referenced this address reporting issue, but did not extend the flexibility. CMS noted that all future actions would be sub-regulatory guidance. 

"The issue had previously been extended during the PFS," Adamec shared in an email. "We had to interpret the omission as a choice not to continue."

When the final PFS rule was released earlier this month, the alliance noted that eliminating the address reporting flexibility would "dramatically increase regulatory burden" for telehealth providers. Thus, the confirmation in the update FAQ offers welcome relief.

However, CMS confirmed that virtual-only telehealth providers whose only physical practice location is their home will need to provide their home address as a practice location.

Kyle Zebley, CEO designate and senior vice president of public policy at the American Telemedicine Association and executive director of its advocacy arm, ATA Action, noted that eliminating the address reporting burden for telehealth providers with physical practice locations is a "significant step toward protecting provider privacy and supporting the continued expansion of virtual care. But, not extending the flexibility to virtual-only providers does not "go far enough" to protect them. 

Still, the confirmation of retroactive payments will ease concerns among telehealth providers, many of whom continued to provide telehealth services to Medicare patients during the shutdown, relying on the expectation that CMS would retroactively pay them.

The telehealth flexibilities and associated payments will end on Jan. 30, 2026, unless Congress acts to extend them once again or make them permanent, setting up another telehealth cliff in the new year.

Anuja Vaidya has covered the healthcare industry since 2012. She currently covers the virtual healthcare landscape, including telehealth, remote patient monitoring and digital therapeutics.