The Centers for Medicare & Medicaid Services (CMS) recently changed the Provider Enrollment rules related to when a practitioner’s enrollment in Medicare is deemed to take effect. This is significant as it affects when a practitioner can bill Medicare for services. The 2009 Medicare Physician Fee Schedule now establishes the effective date of billing for physicians and non-physician practitioners as the later of (1) the filing date of the practitioner’s Medicare enrollment application (the 855) assuming it is subsequently approved by a Medicare contractor, or (2) the date an enrolled physician or non-physician practitioner first began furnishing services at a new practice location. Physicians and non-physician practitioners who meet all program requirements may bill retrospectively for services furnished up to thirty (30) days prior to the billing effective date, which is significantly shorter than the 23 months allowed under prior regulations. Consequently, practice administrators should ensure that they submit all Medicare enrollment forms prior to a newly employed physician or non-physician practitioner providing services to Medicare patients.

Additionally, the rule requires physicians and non-physician practitioners as well as physician and non-physician practitioner organizations to notify their Medicare contractor of a change of ownership, final adverse action, or change of location within 30 days of the reportable event. Failure to notify the designated contractor of a change related to a final adverse action or a change of location may result in an overpayment from the date of the reportable event. CMS released revised Fact Sheets which address the types of Medicare enrollment information changes that trigger reporting responsibilities for physicians, non-physician practitioners, and group practices.

The new rules became effective January 1, 2009.