In the 2009 Final Physician Rule, CMS implemented changes in the rules related to physician enrollment in the Medicare program.  The rule changes will make it more important for physician practices to be current in their enrollment porcesses. 

Before 2009, a physician could enroll in Medicare, begin seeing patients and then go back and retroactively bill Medicare for patients seen 27  months before the enrollment date.  No more, the Final Rule changed that.  CMS will begin enforcing the new enrollment rules as of April 1, 2009.

For new providers in Medicare, a practice may retroactively bill 30 days from the later of:

• the date the physician began seeing patients
• the date that an application that was approved is received by your carrier/MAC. If the application is not successful, then that date is not used  as the effective date.

This significantly reduces a practice's ability to retroactively bill Medicare for patients seen  by a new provider. It is critical that a new provider be enrolled prior to seeing patients.  CMS will instruct carriers to deny (not reject) applications that needs more information.

Also included in the Final Rule were requirements requiring practices to report change in address, ownership or adverse actions.  If there is a change in address or ownership, this must be reported to Medicare within 30 days.

In the case of adverse actions, these must also be reported in 30 days. These adverse actions include:

• Medicare imposed revocation of privileges
• Suspension of license
• Revocation or suspensioin by accreditation organization
• Conviction of a felony
• Exclusion or disbarment from federal or state program