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 Comment: One commenter suggested that we allow 30 to 60 days before submission of an application to serve as the date of approval because this timeline will allow for practices to obtain provider signatures, licenses, and certifications so that we can approve back to the date of licensure and/or the date the provider started furnishing services with a minimum of 30 to 60 days. Response: We disagree with this commenter, because physicians, NPPs and physician and NPP organizations should have all the necessary licenses/certifications at the time of filing, not 30 or 60 days after filing an enrollment application. Comment: Several commenters asked for clarification of the “date of filing” when submitting an application for enrollment. Response: We have clarified the “date of filing” in the provision of the final rule as the date that the Medicare contractor receives a signed provider enrollment application that the Medicare contractor is able to process to approval. Comment: One commenter recommends that we wait until the internet-based PECOS system has been released and used by the physician population before making these changes. 250
CMS-1403-FC Response: As stated above, 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. Comment: Several commenters recommended that we shorten the period of time during which retrospective billing is permitted from 27 months to 12 months. Another commenter stated that reducing retrospective billing from 27 months to 12 months would provide sufficient time for enrollment to occur, reduce the possibility of improper billing and eliminate the unreasonable administrative burden that the our alternatives would place on all new physicians. Response: We appreciate these comments, but continue to believe that allowing retrospective billing for 12 months prior to enrollment poses a significant risk to the Medicare program. Accordingly, with the implementation of this final rule, physician and NPPs and physician and NPP organizations will have a limited time period to submit claims before the effective date of their respective Medicare billing privileges. Comment: Several commenters urged CMS to establish the new web-based program and determine the accuracy and ease of the system before making new enrollment rules. 251
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- Page 243 and 244: CMS-1403-FC Comment: The suggestion
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<strong>CMS</strong>-1403-FC<br />
Comment: One commenter suggested that we allow 30 to<br />
60 days before submission of an application to serve as the<br />
date of approval because this timeline will allow for<br />
practices to obtain provider signatures, licenses, and<br />
certifications so that we can approve back to the date of<br />
licensure and/or the date the provider started furnishing<br />
services with a minimum of 30 to 60 days.<br />
Response: We disagree with this commenter, because<br />
physicians, NPPs and physician and NPP organizations should<br />
have all the necessary licenses/certifications at the time<br />
of filing, not 30 or 60 days after filing an enrollment<br />
application.<br />
Comment: Several commenters asked for clarification of<br />
the “date of filing” when submitting an application for<br />
enrollment.<br />
Response: We have clarified the “date of filing” in<br />
the provision of the final rule as the date that the<br />
Medicare contractor receives a signed provider enrollment<br />
application that the Medicare contractor is able to process<br />
to approval.<br />
Comment: One commenter recommends that we wait until<br />
the internet-based PECOS system <strong>has</strong> <strong>been</strong> released and used<br />
by the physician population before making these changes.<br />
250