Thinking of Giving Up Your Office?  Read this First…

By Barbara Griswold, LMFT 

August 4, 2020 (note: READ THIS AND THEN TO READ AN UPDATED ARTICLE ON THIS TOPIC, click here)

• “Are health plans OK with all-telehealth practices?” Unfortunately, each plan varies on its policies, so you’ll need to contact the plans you work with and ask how they feel about home-based offices. Try to talk to someone in Provider Relations. But you will likely have the same trouble I’m having — it’s hard to find a knowledgeable person you can trust that can answer this question. My sense is that many health plans haven’t yet figured out how they will handle providers giving up their offices. It’s a scenario they never envisioned.

Only a few plans I’ve talked to (including CIGNA and Lyra) seem completely comfortable with telehealth-only providers, both stating they could list a provider in the directory as telehealth only. However, the Lyra rep warned that doing so might cut down on referrals, I suppose since your name would no longer come up in the directory when a client searches using zip code.

It seems, however, the majority of plans are sticking to policies which require network providers to have an office address, and don’t allow home-based offices or telehealth-only provider listings. When an Anthem Blue Cross of California rep said this was their policy, I asked what they would do to providers who did give up their offices.  She was unable to answer that, except to say that these policies were being reviewed.

• “How can we get them to change their policies?” As I said, I think plans are in the midst of telehealth policies. So let’s all contact them via email, phone, and in writing if their policies need changing. Perhaps they need to hear how many of us are giving up our offices before change will happen.
• “What about the CMS-1500 claim form?” When asked about “service location” in Box 32, continue to use your office address (as long as you have one) unless you are told otherwise by the plan. Plans may not accept a P.O. Box here. You might be able to just write the word “telehealth. I would not use your home address, out of concern it might end up on the Explanation of Benefits that the client receives after the claim is processed.

• “What should I ask when I contact the plan?”

1. 1. Ask whether telehealth-only practices are allowed. Don’t ask if a “home office” is allowed– this may mean to them that you are seeing clients in your home. State whether you are a network or out of network provider.
   2. Ask what should be put for the Service Location in Box 32 on the CMS-1500 claim form. Is the word “telehealth” enough? Or a P.O. Box?
   3. Ask what should be put for Billing Address. Is a P.O. Box OK? What about a home address? If I use my home address, will it appear on the Explanation of Benefits (EOB) that tells clients how the claim was processed?
   4. Can I get listed in the online provider directory as “telehealth-only?”

• “What else should I be thinking about?”  Will you need a physical office address for your professional license, malpractice, city license, your NPI, tax ID, Schedule C on your taxes, business checking account or business credit cards?  A P.O. Box may be fine for many of these, but not others.

• “So, what options do I have other than keeping my office?” Getting a P.O. Box might be a good idea for a billing address, but you may need more than that. One colleague shared that she got a P.O. Box and virtual business address through the UPS store, but the NPPES (where NPI numbers are registered) would not accept the address.  Other therapists I know have gotten a “virtual office” through a company like Regus or Office Evolution.  These companies offer a real address, and may forward mail to your home address — you can also rent an office by the hour, if needed, to see clients in person.  Many therapists have made agreements with colleagues to use their office address, even though they don’t have an office there.  I worry these options with a false address could be seen as unethical, depending on how they are used, or they could bring problems if there is an audit. Another therapist suggested that it may be worth renting a few hours of office space from a colleague so you can have a signed contract, and use that as your official office address, even if you work from home.

• A few other considerations: There has been some suggestion that you may need to see if your home is zoned for a home business. I’d also suggest you check with your malpractice and home insurance companies to see if there is a need for changes in coverage if you are working from home. You might also want to get advice from a tax consultant to see if you can take home-office tax deductions.

• What I need from you:  HELP ME! Let’s share information we find out from insurance plans or any other information you get on this topic.  If you talk to a plan, message me here and let me know their answers to the above questions, so I can share this information with others.  If possible, document the name and the phone number and department you spoke to.

READ AN UPDATED ARTICLE ON THIS TOPIC — click here