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CMS-1403-FC
Response: We disagree with this commenter. As stated
above, we understand that physicians, NPPs, and physician
and NPP organizations routinely notify other payers and
affiliated business partners about a change of practice
location in advance of the change. In addition, to ensure
payment accuracy, it is essential that physicians, NPPs,
and physician and NPP organizations report changes in
practice locations prior to change, but not later than 30
days after the reportable event.
Comment: One commenter stated that it seemed
sufficient to collect any overpayment from providers that
file their change of address notice within the traditional
90-day window for updating enrollment records.
Response: As a payer of health care, it is essential
that we make every attempt to make correct payments for
services furnished by qualified providers and suppliers.
To help ensure that we are making the correct payments the
first time, we believe that it is necessary that
physicians, NPPs, and physician and NPP organizations
update their enrollment records when a change in practice
location occurs.
Comment: One commenter urges CMS to withdraw the
proposal to establish authority to require that physicians
report a change in ownership, “any” adverse legal action,
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