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

CMS-1403-FC
officer, submit old IRS documents, etc. are extremely
time-consuming, burdensome and serve as disincentives to
physician participation.
Response: This comment is outside the scope of the
proposed rule and cannot be addressed within this final
rule.
Comment: One commenter asked that if we adopt either
of these enrollment strategies, we should consider an
exemption for hospital-based emergency physicians and NPP
organizations to allow a period of retroactive billing and
payment once an enrollment application is approved by the
contractor.
Response: We are finalizing a provision that allows
physicians, NPPs, 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 furnished at
the enrolled practice location prior to the date of filing
and circumstances precluded enrollment in advance of
providing services to Medicare beneficiaries in
§424.521(a)(1).
Comment: One commenter stated that they support our
efforts to ensure participating providers and suppliers of
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