Are You Compliant With Medicare Telehealth’s 2026 Physical Address Requirements?

The landscape of telehealth has undergone dramatic shifts since 2020, when emergency waivers transformed how mental health professionals could deliver care. As we approach 2026, another significant change is on the horizon—one that could catch many practitioners off guard and potentially disrupt their revenue streams if not addressed promptly.

The Centers for Medicare & Medicard Services (CMS) has released final guidance that effectively ends certain temporary flexibilities around practice location documentation for telehealth providers. If you're a therapist, counselor, or mental health professional billing Medicare for telehealth services, the next few weeks are critical for ensuring your compliance and protecting your cash flow into the new year.

Understanding the Shift: What's Actually Changing?

Since the COVID-19 public health emergency, Medicare has operated under a series of temporary waivers designed to expand access to telehealth services. One of these flexibilities allowed mental health providers to maintain a degree of privacy regarding their home addresses while still billing Medicare for services delivered from those locations.

This accommodation was particularly valuable for solo practitioners and small group practices that operated primarily or entirely through telehealth platforms. Many providers took advantage of these waivers to protect their personal privacy while building thriving remote practices.

However, beginning January 1, 2026, these temporary measures are being scaled back significantly. The new guidance clarifies that while providers may continue to operate from home offices, the "Practice Location" listed in the Provider Enrollment, Chain, and Ownership System (PECOS) must be verified as a legitimate site of service for providers to receive reimbursement at the non-facility rate.

This distinction is crucial. The non-facility rate is typically higher than the facility rate, reflecting the overhead costs that independent practitioners incur when maintaining their own practice locations. To qualify for this higher reimbursement rate, CMS now requires verifiable documentation of your actual practice location—even if that location is your home.

The PO Box Problem: A Persistent Source of Confusion

One of the most significant points of confusion—and potential compliance risk—centers on the use of post office boxes and virtual mailbox services. CMS has been emphatic in its guidance, reiterating as recently as last Friday that PO boxes and virtual mail drops are not valid practice locations under any circumstances.

This includes popular business solutions like UPS Store mailboxes, virtual office addresses from co-working spaces where you don't physically practice, and any other mail-forwarding or address-rental services. While these solutions may have worked during the pandemic's peak flexibility period, using them as your practice location in PECOS after January 1, 2026, will trigger immediate claim denials.

The consequences of this mistake could be severe. Unlike some administrative issues that might result in delayed payments or requests for additional documentation, using an invalid practice location is likely to result in automatic claim rejections. This means providers could face a complete halt to their Medicare reimbursements—a cash-flow crisis that could threaten the viability of their practices.

Why CMS Is Making This Change

To understand how to comply with these new requirements, it helps to understand CMS's rationale. The agency has several legitimate concerns driving this policy shift:

Fraud Prevention: Throughout the pandemic, there was a documented increase in fraudulent telehealth billing schemes. Some bad actors created shell companies with fake addresses, billed for services never rendered, or misrepresented their qualifications and locations. By requiring verified physical addresses, CMS aims to ensure that providers are real, accountable practitioners.

Quality Oversight: State licensing boards and Medicare administrative contractors need to be able to locate providers for quality assurance reviews, complaint investigations, and compliance audits. A verifiable physical address ensures that providers can be reached through official channels if needed.

Appropriate Reimbursement Rates: The distinction between facility and non-facility rates exists because different practice settings have different overhead costs. CMS wants to ensure that providers claiming the non-facility rate are genuinely maintaining independent practice locations with the associated expenses.

Return to Normalcy: As the public health emergency recedes further into the past, CMS is systematically evaluating which pandemic-era flexibilities should become permanent and which should sunset. This represents part of that normalization process.

While these concerns are reasonable from a policy perspective, they create real challenges for providers who have built their practices around the temporary flexibilities of the past few years.

What Providers Need to Do Right Now

The December 15 deadline mentioned in the CMS guidance isn't arbitrary—it represents the last practical date to make changes to your PECOS enrollment before the January 1 effective date. Processing times for PECOS updates can vary, and the system typically experiences heavy volume at year-end as providers address various administrative requirements.

Step One: Access Your PECOS Account

If you haven't logged into PECOS recently—or ever, if your billing company handles everything—now is the time to gain access. You'll need your PECOS username and password, which may require a password reset if it's been a while. The system can be accessed through the CMS Enterprise Portal.

If you've never personally accessed PECOS because your credentialing specialist or billing service manages everything, contact them immediately to request a review of your current information. While delegating administrative tasks is perfectly acceptable, you remain ultimately responsible for the accuracy of your enrollment data.

Step Two: Review Your Current Practice Location

Once you're in PECOS, navigate to your practice location information. This is where you'll see the address that CMS has on file as your site of service. Ask yourself these critical questions:

• Is this address where you actually provide services?

• If it's a home address, is it accurate and current?

• Is it a PO Box or virtual mailbox service?

• If it's a commercial location, do you still maintain a presence there?

• Does this address match what's on file with your state licensing board?

Any discrepancies, outdated information, or use of prohibited address types must be corrected before year-end.

Step Three: Understand Privacy Protections for Home Addresses

Many providers resist listing their home addresses out of legitimate privacy and safety concerns. The good news is that CMS does have protocols in place to suppress home addresses from public directories while still maintaining them in the backend system for administrative purposes.

These suppression protocols vary slightly depending on your circumstances, but generally involve:

• Documenting that your home is your practice location in PECOS.

• Following the specific procedures for address suppression in the National Plan and Provider Enumeration System (NPPES)

• Ensuring consistency between your PECOS enrollment and your NPI registry information

• Understanding that while your address will not appear in public searches, it remains accessible to CMS, Medicare Administrative Contractors, and other oversight entities

If you're unclear on how to implement these privacy protections properly, this is an area where working with a credentialing specialist can be invaluable. The goal is to be compliant with the new requirements while maintaining appropriate boundaries around your personal information.

Step Four: Consider Your Long-Term Practice Strategy

For some providers, this policy change may prompt broader questions about practice structure and location strategy. Now might be an appropriate time to consider:

Shared Office Space: Some providers are exploring arrangements where they rent desk space or a small office in a professional building on an as-needed basis. This provides a commercial address while maintaining flexibility for primarily remote work. However, ensure that you actually use this space and can document your presence there—simply renting an address you never visit won't satisfy CMS requirements.

Group Practice Affiliation: Joining or forming a group practice can provide a legitimate commercial address while still allowing considerable autonomy in how you structure your work. This might also offer other benefits like shared administrative support, referral networks, and marketing leverage.

Professional Corporations or LLCs: Some providers are establishing professional entities with registered agent addresses that comply with both state business requirements and CMS's practice location rules. This approach requires careful legal and tax planning but can offer liability protection and privacy benefits.

Home Office Optimization: If you're committed to maintaining a home-based practice, consider whether your home office setup meets best practices for telehealth delivery. This includes appropriate space, technology, privacy measures, and professional appearance. Documenting these investments can support your claim for non-facility reimbursement rates.

Special Considerations for Different Practice Types

The impact of these changes varies depending on your specific practice model:

Solo Practitioners Working Exclusively from Home

You're actually in a relatively straightforward situation. List your accurate home address in PECOS, implement the privacy suppression protocols, and ensure your home office meets professional standards. Your biggest challenge is simply overcoming any reluctance to list your home address—but remember, it won't be publicly visible if you follow the proper procedures.

Providers Splitting Time Between Multiple Locations

If you practice from both a commercial office and your home, or divide time between multiple clinical sites, you need to carefully document all practice locations in PECOS. CMS allows multiple practice locations, but each must be valid and verifiable. Consider which location you want designated as your primary practice site, as this can affect various aspects of your enrollment and reimbursement.

Providers Who Recently Relocated

If you've moved in the past year but haven't updated your PECOS information, this is your wake-up call. Outdated address information is one of the most common enrollment issues, and it's about to become much more consequential. Update both your PECOS practice location and your NPI registry information to reflect your current location.

Providers Using Virtual Office Services

You're facing the most significant challenge. If your current PECOS address is a virtual office, UPS Store mailbox, or similar service, you must change this information immediately. Determine where you actually provide services—most likely your home—and update your enrollment accordingly. This may feel like a step backward in terms of presenting a commercial image, but compliance with Medicare requirements must take precedence.

The Financial Impact of Non-Compliance

It's worth pausing to consider what's at stake here. For many mental health providers, Medicare represents a significant portion of their payer mix. Medicare Advantage plans often follow traditional Medicare guidelines, so issues with your Medicare enrollment can ripple across multiple revenue streams.

If your claims begin being denied on January 1 due to an invalid practice location, you're looking at several potential consequences:

Immediate Revenue Loss: Every claim submitted for dates of service after January 1 with an invalid practice location will likely be denied. This could mean weeks or months without Medicare reimbursement while you sort out the issue.

Retroactive Correction Challenges: While you should eventually be able to resubmit corrected claims, the process can be time-consuming and may hit timely filing limits depending on how quickly you identify and address the problem.

Administrative Burden: Correcting enrollment issues, resubmitting denied claims, and managing the administrative aftermath will consume significant time and potentially require professional assistance at additional cost.

Cash Flow Crisis: For practices operating on tight margins, even a few weeks without Medicare revenue can create serious financial stress, potentially affecting your ability to meet payroll, pay rent, or cover other operating expenses.

Potential Audit Triggers: Patterns of denied claims or enrollment issues can flag your practice for closer scrutiny from Medicare Administrative Contractors, potentially leading to prepayment reviews or more extensive audits.

The time you invest now in ensuring compliance is infinitely more valuable than the time you'll spend dealing with these consequences later.

Working with Credentialing Specialists

While many providers can navigate PECOS and make necessary updates independently, this may be an ideal time to engage professional help if you're uncertain about any aspect of the process. Credentialing specialists focus specifically on provider enrollment, understand the nuances of CMS requirements, and can often identify issues you might overlook.

A credentialing specialist can help you:

• Review your current PECOS enrollment for any red flags

• Implement proper privacy suppression protocols for home addresses

• Ensure consistency across PECOS, NPPES, state licensing, and payer enrollment

• Develop a strategy if your situation is complex (multiple locations, recent changes, etc.)

• Document your practice location in a way that withstands scrutiny

The cost of these services is typically modest compared to the potential revenue loss from enrollment issues, making this a worthwhile investment for providers who are uncertain about compliance.

Looking Beyond January 2026

While the immediate focus must be on January 1 compliance, it's worth considering what these changes signal about the future of telehealth reimbursement. CMS is clearly in a phase of evaluating and adjusting telehealth policies as we move further from the acute pandemic period.

Several trends are worth monitoring:

Continued Flexibility with Increased Accountability: CMS seems committed to maintaining many telehealth expansions while tightening administrative requirements. Expect more changes that preserve access while addressing fraud and abuse concerns.

State-Level Variations: Individual states may adopt their own Medicaid telehealth policies that differ from Medicare requirements. Providers working with multiple payer types need to stay informed about varying standards.

Geographic and Specialty Considerations: Some specialties and geographic areas may see continued or expanded flexibilities based on access needs, while others face more restrictions.

Technology and Documentation Standards: As telehealth becomes more normalized, expect evolving standards around technology platforms, documentation requirements, and quality measures specific to virtual care.

The key takeaway is that telehealth compliance isn't a one-time checkbox but an ongoing responsibility that requires attention to evolving regulations and guidance.

Conclusion: Take Action Today

The changes taking effect January 1, 2026, represent a significant shift for Medicare telehealth providers, but they're entirely manageable with prompt action. The consequences of inaction, however, could be severe—automatic claim denials, cash flow disruptions, and administrative headaches that could have been avoided with a few hours of work in December.

Here's your action plan:

1. By December 10: Access your PECOS account and review your practice location information

2. By December 12: Identify and plan corrections for any issues (invalid addresses, outdated information, etc.)

3. By December 15: Submit all necessary updates to PECOS

4. Before December 31: Confirm that your updates have been processed and are reflected in the system

5. January 2026: Monitor your initial claims to ensure proper processing under the new requirements

If you discover issues you can't resolve quickly, or if your situation is complex, engage a credentialing specialist immediately. The small investment now could prevent a significant financial crisis in January.

The telehealth landscape has changed dramatically over the past few years, and it will continue evolving. Providers who stay informed, remain proactive about compliance, and adapt their administrative practices accordingly will be best positioned to thrive in this new environment. Don't let an administrative oversight undermine the practice you've worked so hard to build.

Take action today, ensure your compliance, and enter 2026 with confidence that your Medicare reimbursements will continue without interruption.