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

CMS-1403-FC
Comment: One commenter stated that they understand
that there have been Medicare Carriers that allow CRNAs to
hold their claims and back bill for up to 1 year prior to
the date they are certified, consistent with Medicare
payment policy.
Response: We believe that physician and NPPs must
meet all State licensing requirements before Medicare can
convey billing privileges. Moreover, 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 their effective date of
Medicare billing privileges.
Comment: One commenter urged CMS to adopt the Council
for Affordable Quality Healthcare’s (CAQH) Universal
Credentialing Database (UCD) as its provider credentialing
information gathering tool. This commenter stated that
CAQH has over 600,000 providers and suppliers in its
database and is working with hospitals and State Medicaid
programs as well.
Response: While we appreciate this comment, this
comment is outside the scope of this final rule. However,
it is important to understand that CMS’ national enrollment
repository, PECOS, maintains Medicare enrollment records on
more than 610,000 physicians, 280,000 NPPs, 75,000 single
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