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CMS-1403-FC
Response: While we understand this commenter’s
concern, we believe that physicians, NPPs, physician and
NPP organizations have an obligation to report certain
changes, including State license suspensions and
revocations, felony convictions as described in
§424.535(a)(3), Federal debarments and exclusions, within
30 days since these adverse actions may affect a physician,
NPP or physician or NPP organization’s ability to continue
to participate in the Medicare program.
Comment: One commenter urged CMS to consider that the
failure to notify Medicare contractors of a change in
location is an oversight rather than a true attempt to
defraud the Medicare program.
Response: Since physicians, NPPs, and physician and
NPP organizations routinely notify State medical societies,
vendors, employees, utility companies, leasing companies,
and others prior to a change in practice location, we
disagree with this commenter that change in location is an
oversight.
Comment: One commenter stated that that while there
is a need to maintain timely provider records and track
Medicare payments, proposed penalties for failure to report
an address change promptly are so out of proportion to the
offense as to be draconian.
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