Notice: This CMS-approved document has been submitted - Philips ...

CMS-1403-FC
instead, it will force them to join already existing
entities.
Response: We do not believe that the Medicare program
pays for services rendered prior to the date a new practice
location is established. As described above, the physician
or NPP would be allowed to file his or her enrollment
application 30 days prior to the opening of new practice
location and receive payments for services provided from
the day the practice location was established or opened
assuming that the physician met State licensing
requirements and other Medicare program requirements at the
time of filing and subsequently thereafter.
Comment: One commenter urged CMS to withdraw any
proposed changes to the enrollment process, but stated that
they would consider supporting limiting retrospective
billing to the later of the date of filing or the date the
practice location is operational but only after Internet-
based PECOS has been proven to facilitate timely enrollment
processing (fewer than 30 days). Another commenter
supported CMS implementing this requirement once the
enrollment processing time is at a period of 30 to 45 days.
Response: We do not believe that a change to the
effective date of Medicare billing privileges has a nexus
to the implementation of the Internet-based PECOS.
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