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<strong>CMS</strong>-1403-FC<br />

Response: As stated above, we do not believe that a<br />

change to the effective date of Medicare billing privileges<br />

<strong>has</strong> a nexus to the implementation of the Internet-based<br />

PECOS.<br />

Comment: Several commenters recommended that we<br />

shorten the period of time during which retrospective<br />

billing is permitted from 27 months to 12 months. Another<br />

commenter stated that reducing retrospective billing from<br />

27 months to 12 months would provide sufficient time for<br />

enrollment to occur, reduce the possibility of improper<br />

billing and eliminate the unreasonable administrative<br />

burden that the our alternatives would place on all new<br />

physicians.<br />

Response: We appreciate these comments, but continue<br />

to believe that allowing retrospective billing for<br />

12 months prior to enrollment poses a significant risk to<br />

the Medicare program. Accordingly, with the implementation<br />

of this final rule, physician and NPPs and physician and<br />

NPP organizations will have a limited time period to submit<br />

claims before the effective date of their respective<br />

Medicare billing privileges.<br />

Comment: Several commenters urged <strong>CMS</strong> to establish<br />

the new web-based program and determine the accuracy and<br />

ease of the system before making new enrollment rules.<br />

251

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