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Health Systems Press CMS to Let Doctors Use Telehealth at Home

Analysis  |  By Eric Wicklund  
   October 23, 2023

Several large health systems are among more than 100 organizations urging CMS to preserve a Medicare waiver that allows providers to bill Medicare for telehealth delivered from their homes.

A key Medicare waiver that allows healthcare organizations to develop provider-friendly telehealth programs is set to expire at the end of the year, and advocates are lobbying federal officials to make it permanent.

More than 110 organizations, supported by the American Telemedicine Association and including several large health systems, have signed a letter asking the Centers for Medicare & Medicaid Services (CMS) to extend a pandemic-era waiver that enables providers to bill Medicare for telehealth services delivered from their homes.

The waiver allows health systems to design programs that allow their doctors to work from home, enabling more on-demand and 24/7 coverage and cutting administrative and operational costs associated with an in-house telehealth program that requires staff to be on-site or in operations centers. It also allows health systems to develop work-at-home policies to reduce workplace stress and burnout among staff and attract new physicians.

Prior to the pandemic, CMS wasn’t clear on how a “distant site” was defined for providing telehealth services, only offering that providers should, for the purposes of billing Medicare, list the site where they typically practice healthcare. As a result, many health systems were wary of launching telehealth programs where Medicare reimbursement wasn’t assured, or they created programs where providers had to be located on-site.

In a letter to CMS Administrator Chiquita Brooks-LaSure, advocates say the waiver enables health systems to be more flexible in developing telehealth programs.

“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,” the letter states. “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 practitioners agree that retaining the opinion to provide virtual care from a location convenient to the practitioner would ‘significantly reduce the challenges of stress, burnout, or fatigue’ facing their profession and eight in 10 indicate that this flexibility would make them more likely to continue providing medical care.”

The letter also argues that providers should not have to explicitly state their home address as their practice location, given the heightened animosity toward medical professionals during the pandemic and increasing acts of violence against providers since then.

The letter urges Brooks-LaSure to take two steps:

  1. Permanently continues the waiver that allows provider to bill Medicare for telehealth services delivered from “a location at which the clinician is capable of offering in-person care to patients, even when the practitioner is practicing from a different location such as the home.”
  2. Work with stakeholders to develop an alternative method for determining reimbursable sites for delivering telehealth services that does not require doctors to report their home address. One option could be to allow the reporting of a business address for purposes of enrollment and a zip code or similar geographic indicator for purposes of billing.

“This is an extremely important issue for the healthcare providers in general and the telehealth community in particular,” the letter concludes. “As providers are beginning to update their practice and systems in a post pandemic era, we should arm them with the tools to continue to offer telehealth services as they see clinically appropriate.”

Those signing the letter include Advocate Health, Allina Health, Ascension, Avera Health, Baylor Scott & White Health, Duke Health, Intermountain Health, MaineHealth, the Mayo Clinic, MedStar Health, the Minnesota Hospital Association, Northwell Health, Stanford Health Care, the University of Kansas Health System, UPMC, and the Yale School of Medicine and Yale New Haven Health System.

Eric Wicklund is the associate content manager and senior editor for Innovation, Technology, and Pharma for HealthLeaders.


CMS enacted a waiver during the pandemic that allows healthcare providers to bill Medicare for telehealth services delivered from their homes, but that waiver is scheduled to end this year.

The waiver enables health systems to be more flexible in designing telehealth services, allowing doctors to work from home and reducing the need for costly and complex on-site telehealth centers.

Advocates say making the waiver permanent would also reduce stress and burnout.

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