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CMS-1403-FC
Comment: One commenter stated that we should allow
offsite and electronic storage of ordering and referring
records.
Response: The provisions of the final rule do not
preclude offsite or electronic storage as long as these
records are readily accessible.
Comment: One commenter urged CMS to adopt the
proposed requirement for record retention, but only with a
provision that such record retention requirements became
effective as of the effective date of the final rule.
Further, the commenter states that those providers and
suppliers that, until now, have not kept ordering and
referring documentation for 10 years from the date of
service (and were under no other statutory or regulatory
requirement to do so) would not be liable and face possible
revocation of billing privileges as long as the provider or
supplier was in compliance with currently existing
requirements.
Response: We agree with this commenter; however, we
have revised this final rule to establish the ordering and
referring record retention period as 7 years from the date
of service.
After reviewing public comments, we are finalizing the
provision at proposed §424.516(f) that would require
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