During the COVID-19 pandemic, the Centers for Medicare and Medicaid Services (CMS) implemented various temporary measures to facilitate the widespread use of telehealth services. One action was allowing healthcare professionals to render telehealth services directly from their homes, bypassing the regular requirement of reporting their residential addresses on claims forms. This was a practical response to the rapidly changing healthcare landscape during the pandemic, ensuring providers could reach patients efficiently while staying safe. CMS also indicated this waiver’s expiration by the year’s end, and concerns have been voiced by various healthcare stakeholders.
Groups including the American Hospital Association (AHA), the Alliance for Connected Care, and the American Telemedicine Association (ATA) have been at the forefront of these concerns. Their primary focus is the potential security and privacy risks linked with the mandatory reporting of home addresses. The urgency of this concern derives from the pandemic, where there was a marked increase in reported incidents against healthcare professionals, with a significant number of nurses encountering physical violence in their line of duty. Drawing attention to these statistics, Ashley Thompson of the AHA articulated the association’s viewpoint, stating that such disclosure norms might put healthcare workers at unnecessary risk, adversely affecting their ability to provide quality care.
The AHA claims that enforcing home address disclosures could serve as a deterrent to telehealth’s continued adoption. Given the current trend of hybrid work environments in various sectors, this could also pose challenges in retaining staff if they are wary of potential security threats. There is also the matter of administrative strain, which is the requirement to constantly update and report addresses could be difficult for both individual practitioners and larger healthcare institutions. Supporting the AHA’s perspective, the ATA and the Alliance for Connected Care highlighted another issue in the inherent ambiguity of the home address reporting policy predating the pandemic. These bodies are calling for CMS to put in place a permanent solution that allows healthcare providers to bill for telehealth services, irrespective of their actual location. Their proposition revolves around ensuring patient needs are met without placing undue administrative or security burdens on healthcare providers.
The CMS’s approach during the pandemic was commendable in its flexibility and responsiveness. Using their emergency waiver authorities, CMS rolled out, evaluated, and refined their measures in a swift manner. Their actions were not just about addressing the immediate needs of the pandemic. They were also about preparing for any future emergencies, ensuring that the healthcare system, as a whole, was fortified against similar challenges. CMS emphasized collaboration, seeking feedback and perspectives from a range of stakeholders across the healthcare industry. The challenge now is to navigate the balance between the efficacy of telehealth services, the practicalities of administration, and the privacy and safety of providers.