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CMS-1403-FC
not maintain the NPI documentation for each service, but
the provider or supplier must maintain sufficient
documentation to identify the individual who ordered or
referred the beneficiary for their services. In addition,
upon review, CMS or our contractor may validate the
ordering/referring documentation maintained by the billing
provider or supplier with the individual practitioner who
ordered/ referred the beneficiary for these services.
Comment: One commenter recommends that CMS defer to
the judgment of the State boards of pharmacy regarding the
length of record retention, and also allow offsite
electronic storage of ordering and referring records.
Response: We appreciate the importance of the
requirements of State boards of pharmacy; however, we
uphold that Medicare is a national program and it is
necessary to establish national standards for maintaining
the ordering and referring record retention period. We
believe that this approach will lead to consistency.
Further, the provisions of the final rule do not preclude
offsite or electronic storage as long as these records are
readily accessible and retrievable.
Comment: One commenter proposes CMS to abandon its
proposal for the 10-year record retention period and allow
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