Therapists and other mental health clinicians have relied on telehealth to continue to provide services during these difficult times. Some are working from home, and find that this works pretty well. Some are considering closing their brick-and-mortar office and transitioning to a home office, providing telehealth-only services. MHConcierge wonders whether and how this will work, and if there might be unforeseen consequences. To get help with these questions, I posted questions on several local and national listservs. I also sent questions to Provider Relations staff at 5 Minnesota insurance companies: BCBS MN, Medica/UHC/Optum, HealthPartners, UCare and PreferedOne.
The questions were:
- If a therapist closes her office and relocates to her home, and therefore has to notify her contracted insurance companies of an address change, is she at risk for being terminated by the insurance companies that believe that they have too many providers?
- Do insurance companies have a category in the databases and provider directories for “telehealth-only” providers in general and telehealth providers who are working out of their home, in particular.
- And, for telehealth-only providers is it possible NOT list the provider’s home (or office) address as the office location in provider directories.
(Some aspects of these questions were not so clear when I first asked them, but they simulated quite a bit of discussion and this helped focus and refine the questions.)
So, here is a summary of what I learned from the discussions:
- First, in regard to being terminated after a change of address, there was not any clear evidence that this is a risk. In fact, one savvy colleague who used to work for an insurance company and is knowledgeable about these matters provided a helpful backchannel response. It is her understanding that if you are changing your address but not changing your Tax ID/TIN, you should be OK. In other words, if you are changing your practice, such as joining a new practice group or changing jobs, and this results in a new TIN, then you may be at risk for being terminated.
- In regard to the question of how insurance companies would credential providers working from their home, there clearly is a precedent of providers who work from their home, but they provide in-person services. The responses that I received from insurance companies about credentialing telehealth-only providers working from their home were generally vague, but none stated that they would not credential such a provider. It seems likely that insurance companies have not yet caught up with the current telehealth developments by updating their policies.
- In regard to having your home address published in a provider directory, many respondents pointed out, accurately, that it is easy for people to locate our address online. I had asked with this in mind (could have stated this) and was more interested in the idea that it could be confusing to consumers who may expect to be able to come to see us in person at the published address (home or office); hopefully, directories can have a “telehealth only” category and can specify that the published address is only for correspondence, and no in-person services are provided. Another concern is the question of whether one could use a rented mail box as their address. Apparently Medicare and some insurance companies prohibit this. One option, suggested by several respondents, would be to sublet an office, even for 1/2 day per week, and to have access to the brick-and-mortar address at that location. This also may enable a small number of in-person appointments for those who are interested in a “hybrid” approach.
- Finally, many respondents helpfully pointed out that there may very well be unanticipated/unintended consequences of the transition to a home office. For example, apparently PPP loans specify that the recipient must have a brick-and-motor office and part of the loan will be used to pay rent. Others pointed out that the wavers for HIPPA are not permanent, and currently will expire either at some date in 2021 or “when the emergency passes,” depending upon what regulatory body is involved. On the other hand, there clearly is a major push to make some of the most important and helpful wavers permanent, such as allowing the patient/client to receive telehealth services in the home and to receive them by phone. There is, as far as I can tell, no push to allow therapists to provide them from their home as a permanent option – but there is the precedent for credentialing therapists who see patients in their homes.
So, as several respondents pointed out, we are dealing with an evolving set of situations, and there are some challenging questions about the future of telehealth in general, and the possibility of having a telehealth-only home office. But, the trend is pretty clearly in favor of maintaining the expansion of telehealth, and there is a precedent for insurance companies to credential therapists working from their homes.
Of course, this is a summary of a collegial discussion and (mostly vague) responses from insurance companies, and does not provide guaranteed answers to these questions. If you are considering transitioning to a telehealth-only home office, you will need to do your own due diligence.
Your comments and feedback are welcome.