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CMS-1403-FC
or change in practice location within 30 days since these
events may be unrelated to the Medicare program and the
reporting time frame is unduly burdensome to physicians.
Response: We disagree with this commenter. Since
June 20, 2006, physicians and NPP organizations have been
required to report a change in ownership within 30 days and
changes in practice locations and final adverse actions
within 90 days(see §424.516(d)). Since we are aware of
situations where physicians and NPPs have not reported
State license suspensions/revocations or final adverse
actions which may affect a physician or NPPs eligibility to
participate in the Medicare program, we believe that it is
essential to establish more stringent reporting
requirements than in the past. We believe that these
requirements along with corresponding enforcement
procedures will encourage physicians, NPPs and physician
and NPP organizations to report changes in ownership, final
adverse actions, and changes in practice location in a
timely manner (that is, 30 days.)
Comment: One commenter stated that “any adverse legal
action” is not defined; therefore a 30-day reporting
requirement is unreasonable as are the other proposed
requirements. The commenter also stated that we should
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