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 Response: We appreciate this comment and have adopted a modified approach where that date of filing is the effective date of billing for physicians, NPPs, and physician and NPP organizations. Comment: One commenter requests that current procedures change and allow enrollment applications to be submitted 60 days prior to a change. Response: We disagree with the commenter and maintain that permitting billing 30 days before the filing of an enrollment application will provide a sufficient amount of time in most cases. Comment: One commenter stated that the establishment of an effective billing date for physicians, NPPs, and physician and NPP organizations as: (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 will improve patient access to Medicare providers, since patients could be scheduled for appointments based on the date that a Medicare provider submits an enrollment application to the Medicare Administrative Contractor (MAC). This also allows new Medicare providers more flexibility when initiating services under Medicare. 244
CMS-1403-FC Response: We thank the commenter for their support of this provision. Comment: Several commenters recommend that providers should be able to submit enrollment applications with a requested effective date. Response: We believe limiting retrospective payments will ensure that physicians, NPPs, and physician and NPP organizations will ensure that only qualified practitioners are able to bill for services furnished to Medicare beneficiaries. Moreover, we believe that establishing an effective date of Medicare billing privileges and establishing limited retrospective payments will encourage physicians, NPPs, and physician and NPP organizations to enroll and maintain their enrollment in with the Medicare program. However, the effective date of billing privileges is 30 days prior to the later of the date an enrollment application is filed or the date services were furnished at a new practice location. Comment: Several commenters urged CMS to retain its current retrospective billing policy for physicians and NPPs. However, these commenters stated that if CMS revised its retrospective billing policy for physicians, NPPs, and NPP organizations that they preferred option 2 (establishment of an effective billing date for physicians, 245
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<strong>CMS</strong>-1403-FC<br />
Response: We appreciate this comment and have adopted<br />
a modified approach where that date of filing is the<br />
effective date of billing for physicians, NPPs, and<br />
physician and NPP organizations.<br />
Comment: One commenter requests that current<br />
procedures change and allow enrollment applications to be<br />
<strong>submitted</strong> 60 days prior to a change.<br />
Response: We disagree with the commenter and maintain<br />
that permitting billing 30 days before the filing of an<br />
enrollment application will provide a sufficient amount of<br />
time in most cases.<br />
Comment: One commenter stated that the establishment<br />
of an effective billing date for physicians, NPPs, and<br />
physician and NPP organizations as: (1) the date of filing<br />
of a Medicare enrollment application that was subsequently<br />
<strong>approved</strong> by a Medicare contractor; or (2) the date an<br />
enrolled physician or NPP first started furnishing services<br />
at a new practice location will improve patient access to<br />
Medicare providers, since patients could be scheduled for<br />
appointments based on the date that a Medicare provider<br />
submits an enrollment application to the Medicare<br />
Administrative Contractor (MAC). <strong>This</strong> also allows new<br />
Medicare providers more flexibility when initiating<br />
services under Medicare.<br />
244