There are particular challenges as a tele-mental-health provider. Most insurers and CMS require you to have a physical location that they can list on their directories.
CMS updated their rules as of April 2024 to allow for Type 1 NPIs to use a PO Box or private delivery service location for your primary practice location1.
However, they did not extend that to Type 2 NPIs which are usually needed to create a group structure. They require a physical location even if the entire practice is virtual and have a database of private delivery service locations they are checking against.
Here are some options for dealing with this:
- Use a home address. This has obvious issues, but it’s somewhat ameliorated by the fact that it would be associated with your business and not your personal name.
- Use a registered agent. As you may already know, there’s a similar issue with using your home address for LLC registration. You can hire a registered agent to receive mail for you and forward it on. I know that some of them are fairly cheap to get 2-3 pieces of mail a year. They also offer mail scanning services for more incoming mail than that. As far as I can tell, CMS will accept this address.
- Try to bypass this. It might be possible to have a group without a type 2 NPI.
- “The first line location address of the provider being identified. For providers with more than one physical location, this is the primary location. This address can only include the USPS post office box location or personal mailbox offered by a private delivery service if the provider’s NPI is Entity type code = 1 and the provider does not have a physical location other than their home address (for example, a provider that exclusively provides telehealth services from their home).” ↩︎