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19.02.2013 Views

CMS-1403-FC with their initial or revalidation enrollment application, or change in enrollment application. 3. Revocation of Enrollment and Billing Privileges of IDTFs in the Medicare Program Historically, we have allowed IDTFs whose Medicare billing numbers have been revoked to continue billing for services furnished prior to revocation for up to 27 months after the effective date of the revocation. Since we believe that permitting this extensive billing period poses a significant risk to the Medicare program, we proposed to limit the claims submission timeframe after revocation. In §424.535(g) (redesignated as §424.535(h), we proposed that a revoked IDTF must submit all outstanding claims for not previously submitted items and services furnished within 30 calendar days of the revocation effective date. We stated that this change is necessary to limit the Medicare program’s exposure to future vulnerabilities from physician and NPP organizations and individual practitioners that have had their billing privileges revoked. Accordingly, the proposed change would allow a Medicare contractor to conduct focused medical review on the claims submitted during the claims filing period to ensure that each claim is supported by medical documentation that the contractor can verify. We maintain that focused medical review of 220

CMS-1403-FC these claims will ensure that Medicare only pays for services furnished by a physician or NPP organization or individual practitioner and that these entities and individuals receive payment in a timely manner. In addition, we also proposed to add a new provision at §424.44(a)(3) to account for this provision related to the requirements for the timely filing of claims. The timely filing requirements in §424.44(a)(1) and (a)(2) will no longer apply to physician and NPP organizations, physicians, NPPs and IDTFs whose billing privileges have been revoked by CMS. Comment: Several commenters recommended that we withdraw all of our proposed changes to the requirements for physician enrollment in Medicare, including changes to the effective date of billing privileges, eligibility to participate in the program, enrollment processing, reporting requirements, and revocation of billing privileges. Many of the commenters were concerned that it would be burdensome to add new requirements where they must submit all claims within 60 days of the effective date of revocation because of the time it takes to process claims and that it would be easier to leave the retrospective billing rules as they are. 221

<strong>CMS</strong>-1403-FC<br />

with their initial or revalidation enrollment application,<br />

or change in enrollment application.<br />

3. Revocation of Enrollment and Billing Privileges of<br />

IDTFs in the Medicare Program<br />

Historically, we have allowed IDTFs whose Medicare<br />

billing numbers have <strong>been</strong> revoked to continue billing for<br />

services furnished prior to revocation for up to 27 months<br />

after the effective date of the revocation. Since we<br />

believe that permitting this extensive billing period poses<br />

a significant risk to the Medicare program, we proposed to<br />

limit the claims submission timeframe after revocation. In<br />

§424.535(g) (redesignated as §424.535(h), we proposed that<br />

a revoked IDTF must submit all outstanding claims for not<br />

previously <strong>submitted</strong> items and services furnished within 30<br />

calendar days of the revocation effective date. We stated<br />

that this change is necessary to limit the Medicare<br />

program’s exposure to future vulnerabilities from physician<br />

and NPP organizations and individual practitioners that<br />

have had their billing privileges revoked. Accordingly,<br />

the proposed change would allow a Medicare contractor to<br />

conduct focused medical review on the claims <strong>submitted</strong><br />

during the claims filing period to ensure that each claim<br />

is supported by medical <strong>document</strong>ation that the contractor<br />

can verify. We maintain that focused medical review of<br />

220

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