Well, after my last article “Thinking About Giving Up Your Office?” my inbox blew up with responses! (if you missed that article, click here).

Researching the questions brought up in that article is still a work in progress.  Most notably, will plans require network providers to have a physical address?  The answer seems to vary between plans.  Many plans (including many Blue Cross plans) are insisting that their network providers have an office address, and don’t allow home offices. But will they kick providers off the plan if they go all-telehealth?  Or will the pandemic bring policy changes?

Another mystery is what address to put in Box 32 on the CMS-1500 Claim (Service Location). Now, If you are doing telehealth from home, you put your office address. But what if you give up your office?  Plans seem mystified by this question.  While most plans seem to allow P.O. boxes or other addresses in Box 33 (Billing Address), they don’t seem quite sure what to do with Box 32 for the office-free provider.

I was able to get some important clarification from the NPI folks about whether they need a physical address — read below.

So, hurray for crowdsourcing! I asked you all to share the answers you all got when calling insurance plans, to share your own attempts to solve these riddles. So, read on for a compilation of some of the responses I got– thanks to all of you who shared your info!

IS TELEHEALTH-ONLY AN OPTION?

• “Optum/UBH/UHC Provider Relations told me we can provide telehealth-only services on a permanent basis, as long as the clinician attests as a telehealth provider at Optum’s online website (Provider Express.) I was told to write a letter to Provider Relations  to tell them I’m going telehealth-only.”
• “I wrote to BCBS Michigan about giving up an office. They replied ‘BCBS requires all providers to have a physical address, P.O. Boxes are not accepted. This is the address that we will publish in the directory. With that being said, you can check with the postal office and check on getting a physical address box vs a PO Box. Again, this is the address that we will have in the directory so for your own safety do not use your home address as your practice location. You will need to update your information with enrollment.'”
• “I work with Compsych and recently gave up my office. I called them to ask not to list my street address. They were able to list me as telehealth-only, with just my city and state.”
• “Here is what Anthem Blue Cross of California told me: ‘Due to COVID-19 an exception is being made but as soon as the shelter in place is lifted you will not be able to work from home and will need to have a professional office location.'”
• “Due to Covid-19 I changed all my billing to my house. However, each company emailed me, asking if I still had my business address.”
• “I spoke to someone in the Provider Relations Dept. at Beacon Health Options. Right now, they cover telehealth sessions, but not normally, but it sounded to me like they may be considering changing that.  However, they do require me to have a physical address that can appear on the Explanation of Benefits that goes to my clients.”

THE CLAIM FORM

• “I tried to just put the word “Telehealth” in Box 32 for Service Location. But when I submitted the claim via OfficeAlly.com, Office Ally wouldn’t let me submit the claim with an address in that box.”
• ” An OPTUM/UBH/UHC network manager responded to my email and told me a P.O. box can only be used as the remittance address, therefore, my home address would be on the provider directory (and possibly on the Explanation of Benefits that go to clients).  She did not answer my questions about writing “Telehealth” on the Practice Location of a 1500 form, possibly because Optum has online billing and we don’t need to write in a Practice Location when billing online.”

IS A POST OFFICE BOX THE ANSWER?

• I have set up a PO box and have all my mail forwarded to me automatically. I never go into the PO.  You can do this with a Post office location that will let you use a street address.  What I was told is that I set up a temporary forwarding  on the PO box, that can be renewed every 6 months.  Not every PO location has the capacity to have a street address. In the town where my office is located there are 3 PO offices, but only one location lets you use the street address. I needed to open my box at that location.”
• “Thanks for your article on giving up your office. One consideration you didn’t mention: While businesses like the UPS Store and Mailboxes, Etc. may offer a real street address where the Post Office may not, from my experience 15 years ago, none of these services would forward mail once I decided to stop using the box.  I had to contact everyone myself to notify them of my address change, and there were some things that fell through the cracks.  Maybe that’s changed, but it is something to check.”
• “Wanted to share what I learned about getting a post office box now that I’m giving up my office and don’t want to give out my home address. Here is what I will have to do:  I need to go online to request my mail be forwarded to my new P.O. Box.  Although they usually don’t do it, the postmistress said they would let me use the street address.  I then file a forwarding address with my local post office so they will deliver the mail received for me at the Post Office Box to my home mailbox — yay!  Takes longer for me to get it at home but that’s no problem.  I’m paying $6/month (plus $8 for the P.O. box keys I’ll never use).”
• “… folks should read the fine print in customer agreement forms used by the USPS, which for the street address option of a PO Box states “You may not use the street address option as your physical residence or place of business in legal documents. Misuse of your street address in this manner may result in closing your PO Box and may be in violation of civil and criminal laws.” When I investigated using the real street address option through UPS, their customer agreement defers to USPS (“Customer agrees that Customer will not use Center premises, Mailbox, or any Center services for any unlawful, illegitimate, or fraudulent purpose, or for any purpose prohibited by U.S. postal regulations”).”

OTHER CONSIDERATIONS

• Here is the reply I got from the official NPI Enumerator, which manages NPI numbers: “The National Provider Identifier (NPI) application requires both a Business Mailing Address and Business Practice Location Address to be listed. The Business Mailing Address may be the same as the Business Practice Location Address if mail can be delivered to that address.  The Business Mailing address may be a P.O. Box but the Business Practice Location Address cannot, a physical address is needed.  Only one address is allowed for the Business Mailing Address. However, multiple addresses may be listed under the Business Practice Location address, but one will need to be selected as the primary address.  Both the Business Mailing Address and Business Practice Location Address are made public via the NPI Registry on the National Plan and Provider Enumeration System (NPPES) and can be updated at any time….If you have any further questions email customerservice@npienumerator.com or contact the NPI Enumerator at 1-800-465-3203 between 9 a.m. and 5 p.m. EST. — Lesley S. NPPES Customer Service Representative”
• “Letters to the county assessor and business license departments may need to be written if relinquishing an office you have been subletting. Municipalities do want their taxes.   Also, remember to update your addresses on CAQH and/or the Provider Data Management section of Availity.”
• “Reading your piece on giving up your office and things to consider was really helpful in reminding me of what I hadn’t updated yet. For the NPI, they took my mailing address but asked for where I am practicing so I gave my home address. I’m wondering who all can see that. I’m wondering if I should be worried about that.”
• “CAQH just announced that you can add practice locations that are virtual only.”
• “Going all-telehealth may be the same as opening a home business, which can involve paperwork and fees.  Check with your city.”

This conversation will continue in future blog posts, but a final thought:  Many plans may not continue to cover telehealth after the pandemic passes.  This means clients covered by those plans would no longer be covered for your work if you don’t have an office.  If you go all-telehealth, can your clients afford to pay out of pocket to continue to see you?