Notice: This CMS-approved document has been submitted - Philips ...
Notice: This CMS-approved document has been submitted - Philips ... Notice: This CMS-approved document has been submitted - Philips ...
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. 242
CMS-1403-FC Comment: The suggestion to use the Medicare contractor’s date of approval as the initial enrollment date would mean that an employer can expect to generate no revenue from a new hire for a minimum of 3 to 6 months, which is unacceptable. Response: As stated above, we have not adopted the proposed approach 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.. Comment: One commenter supports the establishment of an effective billing date for physicians, NPPs, and physician and NPP organizations as the later of: (1) the date of filing of a Medicare enrollment application that was subsequently approved by a Medicare contractor; or (2) the date an enrolled physician or NPP first started furnishing services at a new practice location. The commenter further urges the agency to tie enrollment and when billing privileges begins to offering services at a new practice location. 243
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<strong>CMS</strong>-1403-FC<br />
Comment: The suggestion to use the Medicare<br />
contractor’s date of approval as the initial enrollment<br />
date would mean that an employer can expect to generate no<br />
revenue from a new hire for a minimum of 3 to 6 months,<br />
which is unacceptable.<br />
Response: As stated above, we have not adopted the<br />
proposed approach but revised it so that it would establish<br />
the effective date of billing for physicians, NPPs, and<br />
physician and NNP organizations as the later of date of<br />
filing of a Medicare enrollment application that was<br />
subsequently <strong>approved</strong> by a Medicare contractor or the date<br />
they first began furnishing services at a new practice<br />
location..<br />
Comment: One commenter supports the establishment of<br />
an effective billing date for physicians, NPPs, and<br />
physician and NPP organizations as the later of: (1) the<br />
date of filing of a Medicare enrollment application that<br />
was subsequently <strong>approved</strong> by a Medicare contractor; or (2)<br />
the date an enrolled physician or NPP first started<br />
furnishing services at a new practice location. The<br />
commenter further urges the agency to tie enrollment and<br />
when billing privileges begins to offering services at a<br />
new practice location.<br />
243