On May 5, 2010, CMS published an Interim Final Rule (IFR) with comment period that implements section 6402(a) of the Patient Protection and Affordable Care Act, which requires all providers of services and suppliers under Medicare or Medicaid that qualify for a National Provider Identifier (NPI) to include their NPI on all enrollment applications and all claims for payment. The IFR also allows for rejection of Medicare claims that do not include the required NPI or that do not contain the legal name and NPI of the ordering or referring physician or eligible professional.
Further, the IFR creates a requirement that physician enrollment in Medicare is a condition for Medicare coverage of services they order. This enrollment requirement could impact teaching hospitals that rely on residents to order diagnostic tests and/or refer Medicare beneficiaries to other services. Teaching hospitals should ensure that all residents enroll in Medicare and make sure they stay enrolled, as after 12 months if a physician does not submit any bills to Medicare the physician will be disenrolled.
The effective date of the IFR and the deadline for comments is July 4, 2010. Please click here to view the IFR.