Physicians enrolling in the Medicare program should be aware that Medicare recently changed the rules applicable to when a physician’s enrollment is deemed to take effect. Specifically, the FY 2009 Medicare Physician Fee Schedule establishes that the effective date of billing for physicians and non-physician practitioners is the later of: (1) the date of filing of a Medicare enrollment application that was subsequently approved by a Medicare contractor; or (2) the date an enrolled physician or non-physician practitioner first started furnishing services at a new practice location.

The rule also provides that physicians and non-physician practitioners who meet all program requirements may bill retrospectively for services furnished up to 30 days prior to the billing effective date (as opposed to the 23 months allowed under current regulations).  Note also that physicians and non-physician practitioners have 30 days to notify their Medicare carrier of a change of ownership, final adverse action (e.g., exclusion, debarment, felony conviction, license suspension or revocation), or a change of location.  Failure to notify the carrier within 30 days can result in an overpayment from the date of the reportable event. 

The 2009 Medicare Fee Schedule can be viewed here.