Notice: This CMS-approved document has been submitted - Philips ...

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