The American Academy of Sleep Medicine recently joined dozens of national health care organizations in a sign-on letter to the Centers for Medicare & Medicaid Services urging continued flexibility in provider location reporting for telehealth and virtual-only clinicians. Current enrollment and billing requirements can require fully virtual providers to report a personal home address, creating privacy concerns and unnecessary administrative hurdles.

The letter asked CMS to:

  • Develop location reporting options for fully virtual providers that do not require listing a home address.
  • Allow alternatives, such as reporting a business address or a geographic indicator (e.g., ZIP code), for payment purposes.
  • Convene stakeholders to inform future policy solutions.
  • Coordinate with the Drug Enforcement Administration to align location requirements and reduce conflicting rules for telehealth prescribing.

The AASM believes modernizing these requirements will better support a growing remote workforce while maintaining program integrity and access to care. The AASM will continue to work with CMS and coalition partners to promote practical, patient-centered policies that reduce burden on clinicians and protect access to virtual sleep services.

Members may send questions regarding this communication to coding@aasm.org.