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

CMS-1403-FC
We maintain that a provider or supplier should retain
the necessary ordering and referring documentation received
from physicians and NPPs as defined in section 1842
(b)(18)(C) of the Act to assure themselves that coverage
criterion for an item has been met. If the information in
the patient’s medical record does not adequately support
the medical necessity for the item, the supplier would be
liable for the dollar amount involved unless a properly
executed Advance Beneficiary Notice of possible denial has
been obtained.
Comment: One commenter urged CMS to adopt its proposal
that would specify that a provider or supplier is required
to maintain ordering and referring documentation, including
the NPI received from the physician or eligible NPP, for 10
years from the date of service, but that this provision
only apply to services furnished on or after the effective
date of this final rule with comment period.
Response: We agree with this commenter in that we are
basing the ordering and referring record retention
requirement based upon the date of service, however we are
adopting the provision for 7 years from the date of
service. We believe that this approach is administratively
consistent with current manual record retention policy that
requires that suppliers retain ordering and referring
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