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

determines in February 2008 that a physician failed to<br />

notify Medicare about a final adverse action that occurred<br />

on June 30, 2007, that physician may be subject to an<br />

overpayment for all Medicare payments beginning<br />

June 30, 2007 and have their Medicare billing privileges<br />

revoked effective retroactively back to June 30, 2007 as<br />

well.<br />

Additionally, we proposed to add a requirement for<br />

change in location at §424.516(d)(1)(iii). Since a change<br />

in location may impact the amount of payment for services<br />

furnished by placing the physician and NPP organizations<br />

and individual practitioners into a new Core Based<br />

Statistical Area (CBSA). We believe that it is essential<br />

that physician and NPP organizations and individual<br />

practitioners report changes in practice location including<br />

those that impact the amount of payments they receive<br />

within a timely period (that is, 30 days). However, unlike<br />

a final adverse action, which may preclude all payments if<br />

reported, failure to report a change in practice location<br />

may impact the amount of payment, not whether a physician<br />

and NPP organizations and individual practitioners may be<br />

eligible to receive payments. Accordingly, we believe that<br />

failing to report changes in practice location would result<br />

in an overpayment for the difference in payment rates<br />

291

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