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

<strong>This</strong> commenter also stated the new web-based system should<br />

be far easier to use than the current process.<br />

Response: We agree with these commenters and, as<br />

previously stated, we expect to implement Internet-based<br />

PECOS for individuals by the end of CY 2008.<br />

Comment: One commenter stated that they have <strong>been</strong><br />

advised by Medicare that this change means upon receiving<br />

notice that a graduate nurse anesthetist had passed his or<br />

her certifying exam that the “graduate” now a CRNA can<br />

retain any Medicare claims from his or her certification<br />

date forward and then submit these held claims upon<br />

receiving his or her National Provider Identifier (NPI).<br />

Further, the commenter stated that Medicare carriers have<br />

allowed this payment practice with the understanding that<br />

graduate nurse anesthetists are qualified to bill Medicare<br />

for their services upon their certification date.<br />

Response: While we understand this comment, we<br />

believe that physicians and NPPs must meet all State<br />

licensing requirements before Medicare can convey billing<br />

privileges. Moreover, with the implementation of this<br />

final rule, physician and NPPs and physician and NPP<br />

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

claims before the effective date of their Medicare billing<br />

privileges.<br />

252

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