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

date of filing and circumstances precluded enrollment in<br />

advance of providing services to Medicare beneficiaries in<br />

§424.521(a)(1). Further, we are implementing<br />

Internet-based PECOS for physicians and NPPs by the end of<br />

CY 2008 to facilitate the electronic enrollment process.<br />

Comment: One commenter suggested that the enrollment<br />

payment policy for CRNAs remain as it is.<br />

Response: We are finalizing a provision that allows<br />

physicians, NPPs (including CRNAs), and physician or NPP<br />

organizations to retrospectively bill for services up to a<br />

30 days prior to their effective date of billing when the<br />

physician or nonphysician organization <strong>has</strong> met all program<br />

requirements, including State licensure requirements, where<br />

services were provided at the enrolled practice location<br />

prior to the date of filing and circumstances, such as,<br />

when a physician is called to work in a hospital emergency<br />

department which precluded enrollment in advance of<br />

providing services to Medicare beneficiaries in<br />

§424.521(a)(1).<br />

Comment: One commenter would like to recommend that<br />

<strong>CMS</strong> not make the new Web-based enrollment system too<br />

cumbersome. Their concerns are based on current member<br />

experiences with the IACS for review of PQRI claims. The<br />

requirements for the practice to designate a security<br />

235

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