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 ...
CMS-1403-FC changes to the enrollment application must be reported within 90 days. While physician and NPP organizations and individual practitioners are required to report changes within 90 days of the reportable event, in many cases, there is little or no incentive for them to report a change that may adversely affect their ability to continue to receive Medicare payments. For example, physician and NPP organizations and individual practitioners purposely may fail to report a felony conviction as described in §424.535(a)(3), or other final adverse action, such as a revocation or suspension of a license to a provider of health care by any State licensing authority, or a revocation or suspension of accreditation, because reporting this action may result in the revocation of their Medicare billing privileges. Thus, unless CMS or our designated contractor becomes aware of the conviction or final adverse action through other means, the change may never be reported by a physician and NPP organization or individual practitioner. Alternatively, if CMS or our designated contractor becomes aware of the conviction or final adverse action after the fact, we have lacked the regulatory authority to collect overpayments for the period in which the physician and NPP organizations and 288
CMS-1403-FC individual practitioners should have had their billing privileges revoked. Since we believe that physician and NPP organizations and individual practitioners must furnish updates to their Medicare enrollment information in a timely manner, we are adopting a new §424.516(d) which would establish more stringent reporting requirements for physician NPP organizations and individual practitioners. (We proposed to redesignate §424.520 as §424.516 and amend the provisions in new §424.516.) In addition to a change of ownership (as currently specified in redesignated §424.516(d)(1)(i)), we proposed to add §424.516(d)(1)(ii) requiring all physician and NPP organizations and individual practitioners to notify our designated contractor of any final adverse action within 30 days. We stated that final adverse actions include, but are not limited to, felonies, license suspensions, and the HHS Office of the Inspector General (OIG) exclusion or debarment. We believe that a physician and NPP organizations and individual practitioner’s failure to comply with the reporting requirements within the time frames described above may result in the revocation of Medicare billing privileges and a Medicare overpayment from the date of the reportable change. Specifically, we 289
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<strong>CMS</strong>-1403-FC<br />
individual practitioners should have had their billing<br />
privileges revoked.<br />
Since we believe that physician and NPP organizations<br />
and individual practitioners must furnish updates to their<br />
Medicare enrollment information in a timely manner, we are<br />
adopting a new §424.516(d) which would establish more<br />
stringent reporting requirements for physician NPP<br />
organizations and individual practitioners. (We proposed<br />
to redesignate §424.520 as §424.516 and amend the<br />
provisions in new §424.516.) In addition to a change of<br />
ownership (as currently specified in redesignated<br />
§424.516(d)(1)(i)), we proposed to add §424.516(d)(1)(ii)<br />
requiring all physician and NPP organizations and<br />
individual practitioners to notify our designated<br />
contractor of any final adverse action within 30 days. We<br />
stated that final adverse actions include, but are not<br />
limited to, felonies, license suspensions, and the HHS<br />
Office of the Inspector General (OIG) exclusion or<br />
debarment. We believe that a physician and NPP<br />
organizations and individual practitioner’s failure to<br />
comply with the reporting requirements within the time<br />
frames described above may result in the revocation of<br />
Medicare billing privileges and a Medicare overpayment from<br />
the date of the reportable change. Specifically, we<br />
289