I first wrote about the topic of giving up an office in 2020, just a few months into the COVID lockdown. This topic is even more timely now that the COVID pandemic is (hopefully) in our rear-view window, so here’s my update.

While many therapists have returned to providing in-person sessions, it seems a large number who have been holding on to their physical office for years are now giving up their offices completely. Many of us enjoyed telehealth more than we imagined we would – and therapists and clients alike enjoy the convenience.

But there are important considerations for those who have given up their offices – or are considering it …

1. “How are health plans accepting all-telehealth practices?” Many plans – including OPTUM/UBH/UHC, Evernorth/Cigna, Magellan, and Lyra – have been generally supportive of the all-telehealth practice. However, even these plans may require a physical address on your superbill, or on your claim form in Box 32 as the “Service Location.” Medicare told one provider they needed a physical address, but it was OK not to be practicing there. Other plans (like some Blue Cross and Blue Shield plans) have said they will not credential telehealth-only new providers, and some have said that all current providers must have a physical office. Blue Cross of California, for example, has told many network providers that they want their providers to have a physical office, probably so that that option is available to clients who don’t have access to technology, who aren’t telehealth-appropriate, or who are in crisis.

2. “So, can I do telehealth from home?” This should not be a problem. I’ve never heard a health plan forbid therapists from sitting at home while providing telehealth sessions. Don’t confuse doing telehealth from home with having a “home office,” a term most health plans use when referring to seeing clients in-person at home. Anthem Blue Cross of California sent one provider a “Home Office and Standards Attestation” which stated

“Home offices are not permitted as a practice location. In addition, practice locations that are within, attached to, or on the immediate premises of a home or residence are not allowed.”

This typically means just that you you cannot see clients in-person at your home.

3. “Well, can I use my home address as my service location?” In my 2021 survey of therapists, 33% of those without offices were using their home address on claims and superbills. However, I don’t advise this. This can put you at risk of identity theft or having your home address online in places you might not want it. Two therapists told me they had negative consequences related to listing their home address. Also, having your home address on a claim or superbill means it could be seen by clients or their angry family members (they could see it on your superbill or it could end up an Explanation of Benefits). This may not be a good idea.  Health plans are generally instructing providers to report their official physical office address as the Service Location on the claim or superbill, even when doing telehealth from home.

4. “So, if I give up my office, but don’t use my home address, what address can I give to health plans?” In my survey, 67% of therapists without offices were using “fake” office addresses, such as an old office or a colleague’s office. One therapist got a false street address through the UPS store, but the NPPES (the NPI Enumerator organization where NPI numbers are registered) would not accept it. Another said Medicare rejected her USPS/UPS fake street address. Many have gotten a virtual office address through companies like Regus, iPostal1, or Office Evolution, which may give you a real office address and process/forward mail to you. Others pay a small “rent” to a colleague who has an office, but never uses the office. No matter what option was chosen, most reported worrying about the ethics of this, and possible negative consequences of reporting a false service location.

5. “So, what address CAN I use for my NPI?” The NPPES (the organization which manages your National Provider Identification Number) announced that effective 4/03/2024, they “will allow for submission of a post office box or personal mailbox offered by a private delivery service as a practice location address when the provider does not have a physical location other than their home address.” (To read more – click here). However, it is important to note that it appears from the NPPES website that this does not apply for Type 2 NPIs. “For Type 2 NPIs, this must be a physical address, it cannot be a PO Box or a CMRA (Commercial Mail Receiving Agency).”

6. “How am I going to be listed in the health plan provider directory?” Ask the health plans you work with – each has different policies about how they list all-telehealth providers in their directory. CIGNA, Lyra and OPTUM/UBH stated they could list a provider in the directory as “telehealth only.” However, your referrals may be affected since your name may no longer come up in the directory when a client searches by zip code. OPTUM said they could list a provider by City and State only. Other plans have stated you can have your address suppressed in the directory. This is where having an official service address can be helpful.

7. “What about the claim form?” When doing telehealth sessions, continue to use your office address (if you still have one) in Box 32 of the claim form, unless you are told otherwise by the plan. You might be able to just write the word “telehealth,” but if you use an Electronic Health Record (EHR), it may require an address here. Plans may not accept a P.O. Box here. Usually, a P.O. Box is fine in Box 33, which designates where to send the payments.

8. “What should I ask when I contact the plan?” Ask whether telehealth-only practices are allowed. Don’t tell them if you’ve already given up your office – tell them you are considering it. Don’t ask if a “home office” is allowed – this means to them that you are seeing clients in your home.

9. “What about my superbills?” I have heard many stories where superbills were rejected because they only had a P.O. box location for the therapist.

10. “What else should I be thinking about?” Will you need a physical office address for your professional license, malpractice, city business license, 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. What about your CAQH profile – you may need a physical address for your practice here. If you practice telehealth out of your home, does your home need to be zoned for a home business? I’d also suggest you check with your home insurance company to see if there is a need for changes necessary if working from home. You might also want to get advice from a tax consultant to see if you can take home-office tax deductions. Your malpractice should cover you no matter where you are (as long as you are legally practicing), but you may want to check.

I NEED YOUR HELP!! If you have information on how health plans and other organizations are handling all-telehealth practices and the lack of an office address, message me here so I can share this information with others.