8 Questions About Giving Up Your Office
By Barbara Griswold, LMFT (March 28, 2022)
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 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 they will terminate providers who give up their offices. Blue Cross 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 or aren’t telehealth appropriate.
2.“So, can I do telehealth from home?” This should not be a problem. I’ve never heard a health plan forbid therapists from providing telehealth sessions from home. 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 survey, 33% of those without offices were using their home address on claims and superbills. This can put you at risk of identity theft or having your home address online in places you might not want it — two therapists have told me this happened to them. Also, having your home address on a claim or superbill means it could be seen by clients as it may end up an Explanation of Benefits. Health plans are generally instructing providers to report their office as the Service Location on the claim, 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 (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 or Office Evolution, which may forward mail to you. Others rent a few office hours from a colleague but never use the office. No matter what option was chosen, most reported worrying about possible negative consequences of reporting a false service location.
5. “How am I going to be listed in the 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.
6. “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 your EHR 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.
7. “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.
8. “What else should I be thinking about?” Will you need a physical office address for your professional license, malpractice, city business 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. 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 malpractice and home insurance companies to see if there is a need for changes in coverage 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.
I NEED YOUR HELP!! If you have information on how health plans and other organizations are handling all-telehealth practices, message me here so I can share this information with others.