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

CMS-1403-FC
effective date of billing for physicians, NPPs, and
physician and NPP organizations, we believe that Medicare
will only pay for services furnished by licensed
practitioners that meet all of the Medicare program
requirements. In addition, we implemented the NPI on
May 23, 2008. Accordingly, we do not believe that there is
a nexus between the implementation of the effective date
for physicians, NPPs, and physician and NPP organizations
and the implementation of the Internet-based PECOS or the
implementation of the NPI.
Comment: One commenter suggested that payment not
commence until the provider’s application has been
processed and approved and that if the approval date is
after the date the provider first started to render
services, then payments will be paid retroactive to the
rendering date. The commenter also requested that CMS
implement an electronic enrollment processing system.
Response: We are finalizing a provision that allows
physicians, NPPs (including CRNAs), and physician or NPP
organizations to retrospectively bill for services up to a
30 days prior to their effective date of billing when the
physician or NPP organization met all program requirements,
including State licensure requirements, where services were
provided at the enrolled practice location prior to the
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