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 ...

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19.02.2013 Views

CMS-1403-FC precluded enrollment in advance of providing services to Medicare beneficiaries. While these changes limit the retrospective payments that a physician, NPP, or physician and NPP organization may obtain from the Medicare program, we believe that this approach will ensure that a Medicare contractor is able to verify that a physician, NPP or physician and NPP organization meets all program requirements at the time of filing, including State licensure. In addition, this approach will afford Medicare beneficiaries the appropriate protections under the statute, regulations, and CMS policy. To ensure that eligible physicians, NPPs or physician and NPP organizations receive reimbursement for services furnished, we will require that Medicare contractors deny Medicare billing privileges when a Medicare contractor is not able to process an incomplete enrollment application that is submitted by a physician, NPP or physician and NPP organization. This is a change from our earlier final rule, “Medicare Program; Requirements for Providers and Suppliers to Establish and Maintain Medicare Enrollment,” (CMS-6002-F) which was published on April 21, 2006. In this earlier rulemaking effort, we stated that we would reject an incomplete enrollment application. In order to provide physician and NPP organizations and individual 266

CMS-1403-FC practitioners with the opportunity to preserve an initial application filing date, we will deny incomplete applications for these supplier types. We believe that §424.530(a)(1) permit a Medicare contractor to deny an incomplete enrollment application. By denying billing privileges for enrollment in the Medicare program or to establish a new practice location, rather than rejecting an enrollment application, physicians, NPPs or physician and NPP organizations will be afforded appeal rights which will preserve the original date of filing the application. Reimbursement for services furnished back to the effective date of billing will be permitted as long as the applicant submits a corrective action plan or appeal in accordance with §405.874 and submits the necessary information to cure any application deficiencies. However, if the applicant does not submit a corrective action plan or appeal within the timeframe established in §405.874, then the applicant would not preserve the right to bill the Medicare program for services furnished from the date of the initial filing of the application or the date the practitioner or organization first started furnishing services at its new practice location. 267

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

precluded enrollment in advance of providing services to<br />

Medicare beneficiaries.<br />

While these changes limit the retrospective payments<br />

that a physician, NPP, or physician and NPP organization<br />

may obtain from the Medicare program, we believe that this<br />

approach will ensure that a Medicare contractor is able to<br />

verify that a physician, NPP or physician and NPP<br />

organization meets all program requirements at the time of<br />

filing, including State licensure. In addition, this<br />

approach will afford Medicare beneficiaries the appropriate<br />

protections under the statute, regulations, and <strong>CMS</strong> policy.<br />

To ensure that eligible physicians, NPPs or physician<br />

and NPP organizations receive reimbursement for services<br />

furnished, we will require that Medicare contractors deny<br />

Medicare billing privileges when a Medicare contractor is<br />

not able to process an incomplete enrollment application<br />

that is <strong>submitted</strong> by a physician, NPP or physician and NPP<br />

organization. <strong>This</strong> is a change from our earlier final<br />

rule, “Medicare Program; Requirements for Providers and<br />

Suppliers to Establish and Maintain Medicare Enrollment,”<br />

(<strong>CMS</strong>-6002-F) which was published on April 21, 2006. In<br />

this earlier rulemaking effort, we stated that we would<br />

reject an incomplete enrollment application. In order to<br />

provide physician and NPP organizations and individual<br />

266

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