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

Management Manual (IOM Manual 100-06). Lastly, collection<br />

of overpayments related to §424.516(d)(1)(iii) would not<br />

begin until after the effective date of the final rule.<br />

Since it is essential that physician and NPP<br />

organizations and individual practitioners notify their<br />

designated contractor of these types of reportable events<br />

in a timely manner and to ensure that the provider or<br />

supplier continues to be eligible for payment, we believe<br />

that it is essential that we establish an overpayment from<br />

the time of the reportable event. We believe that<br />

establishing an overpayment and revocation of billing<br />

privileges for noncompliance from the time of the<br />

reportable event would provide the supplier with a<br />

compelling incentive to report reportable changes in the<br />

30-day reporting period.<br />

In addition, if <strong>CMS</strong> or our designated contractor<br />

determines that a physician and NPP organization or an<br />

individual practitioner <strong>has</strong> moved and <strong>has</strong> not reported the<br />

reportable event within the 30-day reporting period, <strong>CMS</strong> or<br />

our designated contractor would impose an overpayment, if<br />

applicable, and revoke billing privileges for a period of<br />

not less than 1 year.<br />

Comment: One commenter would like to laud <strong>CMS</strong> for<br />

expounding on reporting requirements for the updates<br />

293

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