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CMS-1403-FC
Otherwise, delays associated with contractor processing
could become a larger concern.
Response: We agree with this commenter and have
adopted the “date of filing” as the date that the Medicare
contractor receives a signed provider enrollment
application that the Medicare contractor is able to process
to approval.
Comment: Several commenters strongly opposed the
approach where billing privileges would be conveyed based
on the date of approval by the Medicare contractor and
maintain that tying billing privileges to a contractor’s
approval of a practitioner’s Medicare enrollment
application could create unintended access problems for
some patients. Other commenters added that in certain
situations, the physicians would furnish services and would
not be able to be compensated which they do believe is an
unintended consequence by CMS.
Response: We agree with the commenters and have not
adopted the proposed approach as it was proposed but revised
it so that it would establish the effective date of billing
for physicians, NPPs, and physician and NNP organizations as
the later of date of filing of a Medicare enrollment
application that was subsequently approved by a Medicare
contractor or the date they first began furnishing services
at a new practice location.
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