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CMS-1403-FC
services are complying with Medicare program requirements
in a matter consistent with policy and are not attempting
to “game” the system. However, should we move forward with
this proposal, the commenter advises the drafting of
policies to identify unusual activities beyond the control
of the provider or supplier, such as hurricanes and other
natural disasters, that necessitate a provider or supplier
of services obtaining additional Medicare billing
privileges in order to provide services.
Response: We are finalizing a provision that allows
physicians, NPPs, physician or NPP organizations to
retrospectively bill for services up to a 90 days prior to
their effective date of billing when the physician or NPP
organization met all program requirements, including State
licensure requirements, services were furnished at the
enrolled practice location prior to the date of filing and
a Presidentially-declared disaster under the Robert T.
Stafford Disaster Relief and Emergency Assistance Act, 42
U.S.C. §§5121-5206 (Stafford Act) precluded enrollment in
advance of providing services to Medicare beneficiaries in
§424.521(a)(2).
Comment: A large number of commenters do not support
either approach and go further to state that both proposals
will negatively impact the ability of hospital emergency
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