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

The date of approval is the date that a designated<br />

Medicare contractor determines that the physician or NPP<br />

organization or individual practitioner meets all Federal<br />

and State requirements for their supplier type<br />

Given this first approach, in proposed §424.520, we<br />

stated that we may implement regulations text that reads<br />

similar to: “the effective date of billing privileges for<br />

physician and NPP organizations and individual<br />

practitioners, including physicians and NPPs, is the date a<br />

Medicare contractor conveys billing privileges to a NPI.”<br />

We also stated in the CY 2009 PFS proposed rule that<br />

we believe that this approach--<br />

● Prohibits physicians, NPP organizations, and<br />

individual practitioners from receiving payments before a<br />

Medicare contractor conveys Medicare billing privileges to<br />

an NPI (69 FR 3434);<br />

● Is consistent with our requirements in §489.13 for<br />

those providers and suppliers that require a State survey<br />

prior to being enrolled and the requirements for durable<br />

medical equipment, prosthetics, orthotics, and supplies<br />

(DMEPOS) suppliers in §424.57(b)(2);<br />

● Is consistent with our requirements for providers<br />

identified in §400.202 and surveyed suppliers that are<br />

allowed to bill for services only after they are <strong>approved</strong><br />

227

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