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

CMS-1403-FC
immediately who is already employed within the organization
and is also an approved provider in the Medicare program at
their current practice location. Simply because the events
in this example happened so quickly, the physician’s CMS-
855R was submitted to the Medicare contractor 1 week after
he began providing services in the emergency department.
If the second approach were in effect, 1 week of services
the physician furnished to Medicare beneficiaries in the
emergency department would be denied as his enrollment at
this location was not in effect.
Response: We understand this commenter’s concerns and
are finalizing a provision that allows physicians, NPPs,
physician or NPP organizations to retrospectively bill for
services up to 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 should we adopt the
second approach, they requested that a standard be
established that defines what constitutes the receipt of a
substantially complete application form for which the
240