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  • Writer's pictureMac Rinehart

New CMS rules deconflict CMRA and NPI regulation

In July 2023, the USPS released new regulations that change the definition of Commercial Mail Receiving Agencies (CMRAs). Under the new USPS regulation, any commercial activity that involves receiving mail delivered by the USPS to a single point, and then handling that mail on behalf of clients, requires that the commercial entity (whether a person or a business) register as a CMRA. This definition is very expansive, effectively it means that a variety of situations that previously were not a concern are now subject to regulation including:

  • Coworking business like Brightside.

  • Professional Office Buildings that have mail rooms as a shared service to tenants.

  • Subletting relationships where mail is received for multiple occupants at a single point.

  • Groups of independent businesses or individuals jointly leasing space and receiving mail through a single point.

The key factor for qualifying as a CMRA is whether mail is being accepted and managed on behalf of others, not the legal structure of a business or tenant relationship.

The fact is that many businesses or organizations that previously were not considered to be CMRAs now must register as CMRAs with the USPS. In addition, the USPS regulations require that these CMRAs must issue a Private Mailbox Number (or PMB) to their clients, and that the clients must use this PMB in their address to guarantee mail delivery. This rule is a critical issue for healthcare professionals.

What does this have to do with CMS?

CMS has had a long-standing rule that the providers cannot use a Private Mailbox Number as part of their practice location. Back when this rule was formulated, the Private Mailbox number indicated that the provider was using a service like Postal Annex or the UPS Store as their practice location. CMS regulation was intended to prohibit providers from not disclosing their actual place of business. With new USPS regulation on CMRAs this rule no longer makes sense.

Brightside Takes Action

Naturally, Brightside Coworking is quite concerned about the new USPS regulation and its implication for our clients and our business. To address this issue we contacted US Senator Ron Wyden's office and the CMS Provider Enrollment Team to seek a change in CMS policy on rules related to the practice location field in the National Provider Identifier Application. We're happy to report that CMS has decided to change their regulations to address this issue!

What Are the new rules?

CMS rule changes are apply to individual practitioners only. The rule change is posted as an announcement on the NPPES home page, scroll to their Announcements in the middle of the page:

Effective on 4/3/2024: NPPES will allow for submission of a post office box or personal mailbox offered by a private delivery service as a practice location address when the provider does not have a physical location other than their home address.

This regulation applies only to individual practitioners who operating from their homes exclusively. Brightside Contacted NPPES staff to discuss regulations for Group practices, and has also determined a path forward for group practices, as well as for individuals that operate from facilities that must register as CMRAs. This method is to submit two addresses for the entity registration with NPPES as follows:

  • Physical Address: The physical address is the Brightside Office address without a PMB number. This is the current address that all members use. This address should be submitted as the practice location.

  • Mailing Address: The mailing address will be the Brightside Office address including the PMB number.

NPPES Enumerator staff have confirmed that this approach will be accepted for Group Practices that are operating their businesses out of co-working locations like Brightside Coworking, as well as for Individuals that use CMRA facilities to deliver healthcare services.

Is there Anything Else to Know on This Topic?

Providers should be interested in a CMS regulation called the Address Flexibility Rule. Prior to the COVID-19 pandemic, CMS regulations required that providers list the location from which they provided service as their practice location. For telehealth services provided from the provider’s home, the home address was required as the practice location. Because the practice location is publicly available information, providers might naturally be concerned about having their home address published where anyone could find it.

Before COVID, this was largely a non-issue. Telehealth services were less common, and if they were offered the provider typically performed the service from their place of business rather than their home. But when COVID lockdowns happened, home-based telehealth service expanded rapidly, and healthcare professionals became concerned about the CMS practice location rules and risks to their privacy and security.

In response, CMS implemented a temporary rule called the Address Flexibility Rule. This rule stated that providers who deliver telehealth services from a home office can use their business address their practice location in their National Provider Identifier. In our research on the practice location rules, we confirmed that the Address Flexibility Rule has been extended by CMS through the end of 2024.

The Address Flexibility Rule is not directly related to the issue with using a CMRA as a practice location, but it does allow medical professionals who principally provide healthcare services via telehealth from their home to use a professional office in their NPI registration as their practice location instead of their home address. This should be welcome news for the many Brightside members who deliver telehealth services from their home and use Brightside as their place of business.

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