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 identification number (TIN), reassigning benefits to another entity, or by submitting an enrollment application as another provider or supplier type even though the entity for which the provider or supplier furnished services and has had its billing privileges revoked, suspended, or has an outstanding Medicare overpayment. Absent a reason to reject or deny a Medicare enrollment application, the Medicare FFS contractor is required to approve the enrollment application for a provider or supplier who meets all other Federal and State enrollment requirements for their provider or supplier type. By submitting and having an enrollment application (for example, an initial application or a change of ownership) with a new TIN, some physician and NPP organizations and individual practitioners are able to circumvent existing Medicare revocation, payment suspension, overpayment recovery, and medical review processes by obtaining additional Medicare billing privileges. By obtaining additional billing privileges for multiple locations, these providers and suppliers are able to discontinue the use of the NPI that has an administrative action against it and bill and receive payment under another NPI. 282

CMS-1403-FC Consistent with existing §405.371, we will impose a payment suspension when we possess reliable information that an overpayment or fraud, or willful misrepresentation exists, or that payments to be made may not be correct. Suspension procedures give providers and suppliers an opportunity to submit a rebuttal to CMS’ payment suspension determination. We believe that it is essential that we resolve the payment suspension determination before we grant additional billing privileges to these providers or suppliers. In concert with §405.372(c), once a payment suspension has been terminated, providers and suppliers may then apply for billing privileges. Moreover, we are obligated to recover Medicare overpayments as expeditiously as possible. Providers and suppliers can pay the debt or Medicare can reduce present or future Medicare payments and apply the amount withheld to the indebtedness. When we identify an overpayment and provide notice of the overpayment, physician and NPP organizations and individual practitioners are given an opportunity to appeal the determination. Under certain conditions, the overpayment collection process is suspended during the appeals process. However, if the physician and NPP organization or individual practitioner does not appeal the overpayment determination, or if the overpayment 283

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

identification number (TIN), reassigning benefits to<br />

another entity, or by submitting an enrollment application<br />

as another provider or supplier type even though the entity<br />

for which the provider or supplier furnished services and<br />

<strong>has</strong> had its billing privileges revoked, suspended, or <strong>has</strong><br />

an outstanding Medicare overpayment. Absent a reason to<br />

reject or deny a Medicare enrollment application, the<br />

Medicare FFS contractor is required to approve the<br />

enrollment application for a provider or supplier who meets<br />

all other Federal and State enrollment requirements for<br />

their provider or supplier type.<br />

By submitting and having an enrollment application<br />

(for example, an initial application or a change of<br />

ownership) with a new TIN, some physician and NPP<br />

organizations and individual practitioners are able to<br />

circumvent existing Medicare revocation, payment<br />

suspension, overpayment recovery, and medical review<br />

processes by obtaining additional Medicare billing<br />

privileges. By obtaining additional billing privileges for<br />

multiple locations, these providers and suppliers are able<br />

to discontinue the use of the NPI that <strong>has</strong> an<br />

administrative action against it and bill and receive<br />

payment under another NPI.<br />

282

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