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

CMS-1403-FC
continued to state that this would bring consistency to the
Medicare Parts B and D programs, and reduce the need to
create new storage capacity for paper prescription records.
Response: Since Medicare is a Federal program that
already requires a 7-year retention period from the date of
billing, we disagree that this change will create a
significant burden.
Comment: One commenter stated that the extension from
7 to 10 years would add a substantial recordkeeping burden.
Response: We agree with this commenter and have
revised this final rule with comment period to establish an
ordering and referring record retention period as 7 years
from the date of service.
Comment: One commenter urged CMS to reconsider our
position regarding maintaining ordering and referring
documentation. In addition, this commenter stated that
this change would constitute an unfunded mandate.
Response: We disagree with this commenter that this
change is an unfunded mandate because providers and
suppliers are already required by CMS’ manual instructions
to maintain ordering and referring documentation for
7 years from the date of billing.
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