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 NPPs, and physician and NPPs 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), which limited retrospective billing to the later of the date of filing or the date the practice location was established. Response: We agree with these commenters and have adopted this approach in this final rule. Comment: One commenter recommends allowing those physicians who are about to complete their fellowship to submit an application to Medicare for a generic provider number which at a later date can be linked to an eventual employer. Response: Since we do not establish a provisional enrollment status for physicians or other suppliers, but rather convey billing privileges to a NPI, we disagree with this commenter. Comment: One commenter suggests that to improve the Medicare enrollment process, the processing of enrollment applications should take 30 to 45 days versus a 90 to 120 days activity. Medicare could follow the process employed by private payers and utilize one central repository for 246
CMS-1403-FC provider enrollment given that all processes basically require the same essential information. Response: CMS already utilizes a single national repository of enrollment information. The national enrollment repository is known as the Provider Enrollment, Chain and Ownership System (PECOS). Comment: Several commenters supported our proposed approach that would establish the initial enrollment date for individual practitioners and physician and NPP organizations as the date an enrolled supplier started furnishing services at the new practice location as it would be the fairest option for all enrollees. Response: We appreciate this comment, and as stated above, we are finalizing this proposal with revisions 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 stated that physician practices that allow new practitioners to treat Medicare patients before their applications are approved run the risk of submitting an application that is ultimately returned on a 247
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<strong>CMS</strong>-1403-FC<br />
provider enrollment given that all processes basically<br />
require the same essential information.<br />
Response: <strong>CMS</strong> already utilizes a single national<br />
repository of enrollment information. The national<br />
enrollment repository is known as the Provider Enrollment,<br />
Chain and Ownership System (PECOS).<br />
Comment: Several commenters supported our proposed<br />
approach that would establish the initial enrollment date<br />
for individual practitioners and physician and NPP<br />
organizations as the date an enrolled supplier started<br />
furnishing services at the new practice location as it<br />
would be the fairest option for all enrollees.<br />
Response: We appreciate this comment, and as stated<br />
above, we are finalizing this proposal with revisions so<br />
that it would establish the effective date of billing for<br />
physicians, NPPs, and physician and NNP organizations as the<br />
later of date of filing of a Medicare enrollment application<br />
that was subsequently <strong>approved</strong> by a Medicare contractor or<br />
the date they first began furnishing services at a new<br />
practice location..<br />
Comment: One commenter stated that physician practices<br />
that allow new practitioners to treat Medicare patients<br />
before their applications are <strong>approved</strong> run the risk of<br />
submitting an application that is ultimately returned on a<br />
247