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 evidence that the supplier is not operational (see §424.535(b)(5)) Comment: One commenter stated that they oppose changing the time period for reporting a change in location from 90 days to 30 days because the physician is still eligible for payment and Medicare’s vulnerability to overpayments is limited. Response: While we agree that a physician may still be eligible to receive payment, the issue in question is the amount of payment. Moreover, as a payer of health care, we believe that physicians and all other providers and suppliers have a responsibility to update their enrollment record when a change in practice location occurs. This will allow CMS or our contractor to verify that services are actually furnished at the practice locations identified by the medical practices. Comment: One commenter stated that if we finalize our reporting requirements, a better option would be to limit the types of actions that are reportable to similar actions that are required to be reported to the National Practitioner Data Bank (NPDB) which was established by the Congress to address the need to improve the quality of medical care by encouraging State licensing boards, health care entities such as hospitals, and professional societies 298
CMS-1403-FC to identify and discipline those who engage in unprofessional behavior, as well as restrict a practitioner’s ability to move from State to State without disclosure of previous adverse action history. Response: We disagree with this commenter. In considering the types of events that should be reported within 30 days of the reportable event, with this final rule with comment period, we have limited the types of reportable events to three specific types of events: (1) change in ownership, (2) final adverse actions, and (3) change in practice location. We believe that the failure to report any of these types of reportable events may result in payments to the wrong organization, erroneous payments if the physician or NPP payment no longer meets State licensure requirements, or payments in the wrong amount when a change in practice location impacts the payment to a physician, NPP or physician or NPP organization. Comment: One commenter stated that our proposal to revoke billing privileges for a period of not less than 1 year for failure to comply with the proposed 30-day reporting period is a harsh and unjust penalty for a minor paperwork offense. 299
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- Page 261 and 262: CMS-1403-FC Response: While we moni
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- Page 295 and 296: CMS-1403-FC Response: Based on thes
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<strong>CMS</strong>-1403-FC<br />
evidence that the supplier is not operational (see<br />
§424.535(b)(5))<br />
Comment: One commenter stated that they oppose<br />
changing the time period for reporting a change in location<br />
from 90 days to 30 days because the physician is still<br />
eligible for payment and Medicare’s vulnerability to<br />
overpayments is limited.<br />
Response: While we agree that a physician may still<br />
be eligible to receive payment, the issue in question is<br />
the amount of payment. Moreover, as a payer of health<br />
care, we believe that physicians and all other providers<br />
and suppliers have a responsibility to update their<br />
enrollment record when a change in practice location<br />
occurs. <strong>This</strong> will allow <strong>CMS</strong> or our contractor to verify<br />
that services are actually furnished at the practice<br />
locations identified by the medical practices.<br />
Comment: One commenter stated that if we finalize our<br />
reporting requirements, a better option would be to limit<br />
the types of actions that are reportable to similar actions<br />
that are required to be reported to the National<br />
Practitioner Data Bank (NPDB) which was established by the<br />
Congress to address the need to improve the quality of<br />
medical care by encouraging State licensing boards, health<br />
care entities such as hospitals, and professional societies<br />
298