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

CMS-1403-FC
plan that demonstrates that they are in compliance with
Medicare requirements when CMS or our contractor imposes a
revocation based on certain types of adverse actions such
as a Federal exclusion or debarment. Accordingly,
consistent with revoking billing privileges with the date
of exclusion or debarment, we believe that similarly
situated revocations such as felony convictions and license
suspension or revocation do not lend themselves to a
corrective action plan and that the revocation should be
effective with the date of the felony conviction or the
license suspension or revocation. Moreover, we maintain
that when CMS or our contractor determines that a provider
or supplier, including a DMEPOS supplier, is no longer
operating at the practice location provided to Medicare on
a paper or electronic Medicare enrollment application that
the revocation should be effective with the date that CMS
or our contractor determines that the provider or supplier
is no longer operating at the practice location.
Further, while we do not believe that revocations
based on felony convictions, license suspension or
revocation, or a revocation based on a provider or a
supplier no longer being operational at a specific practice
location, lend themselves to a corrective action plan, we
believe that these providers and suppliers should be
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