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

Comment: Several commenters urged <strong>CMS</strong> to adopt the<br />

proposal to limit retrospective billing to the later of the<br />

date of filing or date the practice location was<br />

established.<br />

Response: We agree with these commenters and have<br />

finalized this approach in this final rule with comment<br />

period.<br />

Comment: One commenter recommended that we should not<br />

implement the revised effective date for billing privileges<br />

until January 1, 2010.<br />

Response: We disagree with the commenter because we<br />

believe that it is essential that Medicare only pay for<br />

services to eligible practitioners that are qualified to<br />

bill for services.<br />

Comment: Several commenters recommended that we<br />

refrain from implementing any proposed changes to the<br />

effective date of Medicare billing privileges until the<br />

Provider Enrollment, Chain and Ownership System (PECOS)<br />

system is fully functional and a thorough discussion is<br />

held between all affected parties and/or all current<br />

National Provider Identifier (NPI) applications are<br />

processed.<br />

Response: While we understand this comment, we<br />

disagree with these commenters. By establishing an<br />

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