As the demand for tele-mental health services continues to grow, so too do the complexities of compliance. One of the more frustrating issues providers face is the requirement to maintain a physical address—even when their entire practice operates virtually. Insurers and the Centers for Medicare & Medicaid Services (CMS) still cling to outdated location requirements that don’t align with modern telehealth models.
Why a Physical Address Is Still Required
Most insurance companies and CMS require mental health providers to list a physical address in their directories. This remains true even for solo practitioners working exclusively online.
However, there was a meaningful update in April 2024: CMS now allows providers with Type 1 NPIs (individual practitioners) to use P.O. Boxes or private delivery service locations (such as a UPS store) as their primary practice location1. This is a welcome shift for solo providers who don’t have a brick-and-mortar office.
Unfortunately, this rule change does not apply to Type 2 NPIs, which are generally required to set up a group or organizational structure. CMS continues to require a physical address for Type 2 NPIs and has even implemented a database to flag non-compliant delivery service addresses.
Your Options: Workarounds and Practical Solutions
If you’re building a tele-mental health practice, here are a few ways to navigate the physical address requirement:
1. Use Your Home Address (Cautiously)
This is the most straightforward solution, though it raises obvious privacy concerns. Still, the address would be linked to your business entity, not your personal identity. For some providers, this trade-off is acceptable.
2. Hire a Registered Agent
Just as registered agents are used for LLC registration, they can also serve as a business address for your practice. These services typically receive a small amount of mail on your behalf and may offer scanning or forwarding options. Many are affordable and low-maintenance. Early indications suggest that CMS will accept registered agent addresses—at least for Type 2 NPIs.
3. Avoid the Need for a Type 2 NPI (If You Can)
Depending on how you structure your business, you might be able to operate entirely under a Type 1 NPI. This can simplify compliance and sidestep the physical address problem altogether. That said, this approach isn’t feasible if you’re planning to build a group practice or hire additional clinicians.
Final Thoughts
Tele-mental health is here to stay, but the infrastructure supporting it hasn’t quite caught up. Until CMS and insurers modernize their systems, telehealth providers will need to get creative with compliance. Whether you’re just starting out or restructuring your practice, carefully weighing your address options can help you stay within the rules—without compromising your privacy or adding unnecessary overhead.
Have questions about setting up your telehealth practice or navigating CMS regulations? Share your experiences or drop a comment below—we’d love to hear from you.
- “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).” ↩︎