CMS Teleradiology Enrollment Rules: What Radiology Practices Need to Know Now

What Are the New CMS Teleradiology Enrollment Requirements for 2026?

As of August 2026, CMS released updated guidance clarifying Medicare enrollment requirements for teleradiology providers, specifying that teleradiologists must report the physical location where they perform image interpretations on their Medicare enrollment, including a home address when no other practice site exists. This guidance distinguishes teleradiology from standard telehealth enrollment because remote image interpretation is not classified as a service ordinarily furnished in person.

• Who must act: Any radiologist interpreting imaging studies remotely, whether from home, a satellite office, or across state lines, must confirm that their Medicare enrollment reflects the correct practice location.
• Key distinction: CMS treats teleradiology differently from telehealth because remote image interpretation is not a service normally performed face to face, so standard telehealth enrollment flexibilities do not apply.
• Immediate risk: Practices with radiologists reading from unreported locations may face claim denials, enrollment revocation, or compliance audit triggers if the enrollment record does not match the service location.

What CMS Changed in August 2026

On August 20, 2026, CMS published updated enrollment guidance through its MLN Connects newsletter, accompanied by a new document titled “Understanding Telehealth and Teleradiology Enrollment.” The guidance was developed in response to ongoing confusion among providers about how to report practice locations when radiology interpretations are performed remotely. The core change is a formal clarification, not a new regulation, but it carries operational weight because it defines how CMS expects enrollment records to reflect actual service delivery locations for teleradiology.

The guidance establishes that teleradiology is not telehealth under Medicare’s statutory definition. Section 1834(m) of the Social Security Act defines telehealth as services ordinarily furnished in person that are instead delivered via two-way telecommunications. Because remote image interpretation has never been an in-person service, it falls outside that definition entirely. This distinction matters because the temporary telehealth enrollment flexibilities that CMS extended through December 31, 2027, including waived geographic restrictions and relaxed practice location reporting, do not apply to teleradiology.

For radiology practices, the practical impact is straightforward: every radiologist performing remote reads must have their actual interpretation location listed on their Medicare enrollment. If a radiologist reads from home, that home address must appear on the enrollment application. CMS does allow the use of a specific practice location designation to prevent that home address from being publicly displayed on the Care Compare directory, but the address must still be reported to CMS. Practices looking for a deeper understanding of how regulatory changes affect radiology billing compliance should review ACR’s current documentation standards alongside this CMS update.

Does This Apply to My Radiology Practice?

This guidance applies to any radiology practice, imaging center, or hospital system where radiologists interpret studies from a location other than the facility where the imaging was performed. If your practice uses any form of remote reading, whether through a contracted teleradiology company, a radiologist working from home after hours, or a multi-site group with centralized reading rooms, the enrollment record for each interpreting radiologist must reflect where the reads actually happen.

The guidance specifically addresses several common scenarios. A radiologist who maintains a physical practice location but occasionally reads from home generally does not need to add the home address to their enrollment. However, a radiologist who works entirely through virtual care, with no physical office, must report the home address as their practice location. For radiologists who reassign benefits to a medical group located in a different state, the enrollment must reflect the radiologist’s physical location during interpretation, and applicable state licensing requirements still apply.

In our experience matching radiology practices with billing partners, the enrollment gap we see most often involves after-hours reading arrangements. A practice contracts with a teleradiology service for overnight or weekend coverage, and the covering radiologists are enrolled under the teleradiology company’s main office address rather than the locations where they actually sit during reads. Under CMS’s clarified guidance, that mismatch is a compliance risk. Providers often come to us after a denied claim surfaces the problem, and by that point the correction involves updating enrollment records, resubmitting claims, and in some cases working through an appeals process.

Why CMS Distinguishes Teleradiology from Telehealth

The distinction is not arbitrary. Telehealth under Medicare refers to services that would normally happen in person, such as an office visit or a mental health consultation, but are instead delivered via live audio and video. Congress authorized temporary flexibilities for these services during and after the pandemic, and CMS extended many of those flexibilities through the end of 2027. Those flexibilities include waived geographic restrictions for patients, relaxed originating site requirements, and the option for providers to deliver telehealth from their home without reporting the home address on their enrollment.

Teleradiology does not fit that framework. A radiologist interpreting a CT scan from a remote workstation is performing a service that has always been done remotely. The images are transmitted electronically, and the read happens wherever the radiologist is sitting. Because this was never an in-person service, CMS does not classify it as telehealth and does not extend telehealth-specific enrollment rules to cover it. The consequence is that teleradiologists must follow standard Medicare enrollment rules, which require accurate reporting of every practice location where services are rendered.

For practices that assumed their remote radiologists were covered under telehealth flexibilities, this clarification changes the compliance picture. The ACR and RBMA have both noted that the distinction has created confusion, particularly among smaller radiology groups that added remote reading capacity during the pandemic years without updating enrollment records to match.

How Do You Verify and Update Your PECOS Enrollment?

Every radiology practice using remote interpretation should verify enrollment records now, before a claim denial or audit surfaces the gap. The verification process is straightforward, and the steps below apply whether you are checking a single radiologist or an entire group.

1. Log into the Provider Enrollment, Chain, and Ownership System (PECOS) at pecos.cms.hhs.gov. Each radiologist who interprets studies remotely should have their enrollment record reviewed.
2. Review the practice location section. Confirm that every location where remote reads occur is listed, including home addresses for radiologists who have no other physical office.
3. Check the practice location designation. CMS allows a specific designation that prevents home addresses from appearing on Care Compare. Verify this designation is applied if a home address is listed.
4. Confirm reassignment records. If a radiologist bills through a group practice, the reassignment must be active and the group’s enrollment must also reflect the appropriate state and location information.
5. Verify state enrollment alignment. A teleradiologist must be enrolled in the state where they are physically located while performing interpretations. If the radiologist reads from Florida but the group is enrolled in Texas, the radiologist needs enrollment in Florida.
6. Submit any updates through the standard PECOS enrollment change process. CMS recommends submitting updates promptly, as inactive or incomplete PECOS applications can be automatically deleted due to inactivity.

Across the billing companies we work with, the most common enrollment error is a radiologist who moved or added a home reading location and never updated PECOS. The correction itself is not complex, but delayed updates create a window where claims can be denied for location mismatch.

Common Enrollment Mistakes Radiology Practices Make

The CMS clarification is a response to patterns the agency has observed, and those patterns mirror what we see across the radiology practices that come through our platform. Several enrollment errors recur frequently enough that every practice using remote reads should audit for them.

Assuming telehealth flexibilities cover teleradiology is the most consequential error. A practice that relies on the temporary waiver of geographic and location reporting requirements for its remote radiologists may have been operating outside enrollment rules for years without realizing it. Because CMS has now formally clarified the distinction, that assumption is no longer defensible in an audit.

Listing only the group’s main office when radiologists read from multiple locations is another common gap. CMS expects every location where services are rendered to appear on the enrollment record. A radiology group with ten radiologists reading from ten different home offices should have each of those locations documented.

Failing to update PECOS after a radiologist relocates creates a mismatch between the enrolled address and the actual service location. This is especially common with locum tenens radiologists or contract teleradiology providers who move between states.

Overlooking state enrollment requirements compounds the problem. Medicare enrollment is state-specific for teleradiology. A radiologist physically in one state reading images generated in another state must be enrolled in the state where the radiologist is sitting, not where the patient or the imaging equipment is located.

Teleradiology vs. Telehealth Enrollment: Key Differences

The table below summarizes the enrollment distinctions CMS established in its August 2026 guidance.

How Enrollment Compliance Fits Your Revenue Cycle

Enrollment accuracy is not a standalone compliance task. It connects directly to whether claims get paid. When a radiologist’s enrollment record does not match the location where the interpretation was performed, the payer has grounds to deny the claim. For Medicare specifically, a mismatch between the enrolled address and the service address can trigger a post-payment audit, a request for refund, or in more severe cases, a referral to the Office of Inspector General.

Practices that handle radiology billing in-house frequently miss this connection because enrollment management and claims submission are managed by different people. The person submitting claims may not know that a radiologist started reading from a new location, and the person managing enrollment may not realize the operational change happened. A billing company with radiology experience treats enrollment verification as part of the pre-claim workflow, not as a separate administrative function.

One question we hear constantly from practice managers is whether a single location mismatch can really cause a denial. The answer is yes. Medicare’s claims processing system cross-references the service location against the provider’s enrollment record, and a mismatch can generate a rejection at the front end or a recovery demand after payment. For high-volume radiology groups processing hundreds of remote reads per week, even a brief period of non-compliance can create a substantial accounts receivable problem.

The CMS guidance also intersects with the broader compliance landscape for radiology practices. The 2027 OPPS proposed rule, which includes site-neutral payment expansions for imaging services, will require even more precise location documentation from radiology groups operating across multiple sites. Practices that align their enrollment records with the new teleradiology guidance now will be better positioned when those payment changes take effect. For a complete breakdown of what to evaluate when choosing a radiology billing partner, enrollment compliance experience should be a qualifying criterion.

Frequently Asked Questions

Next Steps

Review each remote radiologist’s PECOS enrollment to confirm practice locations match where interpretations actually occur. If your practice uses contracted teleradiology services, confirm that covering radiologists maintain compliant enrollment records. For a deeper understanding of how ACR guidelines and documentation standards affect your billing workflows, explore our resource library. If your current billing setup does not include enrollment monitoring as part of the revenue cycle, that gap is worth addressing before the next payer audit.