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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,
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