Notice: This CMS-approved document has been submitted - Philips ...

Notice: This CMS-approved document has been submitted - Philips ... Notice: This CMS-approved document has been submitted - Philips ...

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19.02.2013 Views

CMS-1403-FC registered nurse anesthetists (CRNA), clinical social workers, nurse practitioners (NPs), physician assistants (PAs), clinical psychologists, psychologists billing independently, speech language pathologists, and registered dieticians or nutrition professionals Once enrolled, physician and NPP organizations and individual physicians and NPPs, depending on their effective date of enrollment, may retroactively bill the Medicare program for services that were furnished up to 27 months prior to being enrolled to participate in the Medicare program. For example, if a supplier is enrolled in the Medicare program in December 2008 with an approval date back to October 2006, that supplier could retrospectively bill for services furnished to Medicare beneficiaries as early as October 1, 2006. Currently, physician and NPP organizations and individual practitioners, including physicians and NPPs, are allowed to bill Medicare prior to their enrollment date. Therefore, it is possible that the physician and NPP organizations and individual practitioners who meet our program requirements on the date of enrollment may not have met those same requirements prior to the date of enrollment, even though that supplier could bill Medicare and receive payments for services furnished up to 27 months 224

CMS-1403-FC prior to their enrolling in the Medicare program. In the proposed rule, we stated our concern that some physician and NPP organizations and individual practitioners may bill Medicare for services when they are not meeting our other program requirements, including those related to providing beneficiary protections, such as Advance Beneficiary Notices. We solicited public comment on two approaches for establishing an effective date for Medicare billing privileges for physician and NPP organizations and for individual practitioners. The first approach would establish the initial enrollment date for physician and NPP organizations and for individual practitioners, including physician and NPPs, as the date of approval by a Medicare contractor. This approach would prohibit physician and NPP organizations and individual practitioners from billing for services furnished to a Medicare beneficiary before they are approved and enrolled by a designated Medicare contractor to participate in the Medicare program and Medicare billing privileges are conveyed to their National Provider Identifier (NPI). Physicians and NPPs are eligible for NPIs and may apply for their NPIs at any time. To enroll in Medicare, a physician or NPP must have an NPI. If an 225

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

prior to their enrolling in the Medicare program. In the<br />

proposed rule, we stated our concern that some physician<br />

and NPP organizations and individual practitioners may bill<br />

Medicare for services when they are not meeting our other<br />

program requirements, including those related to providing<br />

beneficiary protections, such as Advance Beneficiary<br />

<strong>Notice</strong>s.<br />

We solicited public comment on two approaches for<br />

establishing an effective date for Medicare billing<br />

privileges for physician and NPP organizations and for<br />

individual practitioners.<br />

The first approach would establish the initial<br />

enrollment date for physician and NPP organizations and for<br />

individual practitioners, including physician and NPPs, as<br />

the date of approval by a Medicare contractor. <strong>This</strong><br />

approach would prohibit physician and NPP organizations and<br />

individual practitioners from billing for services<br />

furnished to a Medicare beneficiary before they are<br />

<strong>approved</strong> and enrolled by a designated Medicare contractor<br />

to participate in the Medicare program and Medicare billing<br />

privileges are conveyed to their National Provider<br />

Identifier (NPI). Physicians and NPPs are eligible for<br />

NPIs and may apply for their NPIs at any time. To enroll<br />

in Medicare, a physician or NPP must have an NPI. If an<br />

225

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