Anonymous -- NY

Thank you for the opportunity to comment. REVALIDATION In this propose rule, CMS states, "To assist CMS in assuring that the statutory effective date is met, we are proposing at 42 CFR 424.515 to permit CMS to require that a provider or supplier revalidate its enrollment at any time." Unfortunately, CMS does not provide sufficient justification or rationale for this position. Moreover, CMS also failed to review its own proposed rule (see April 25, 2003) and final rule (April 21, 2006) in which CMS proposed and finalize the concept of revalidation. In the April 25, 2003 proposed rule, CMS indicated that revalidation would be used to ensure compliance with Medicare requirements. The new proposal seems punitive and overly board since CMS does not furnish amble discussion for the public to fully evaluate this proposal. Therefore, I recommend that CMS remove its proposal to to permit CMS to require that a provider or supplier revalidate its enrollment at any time." because CMS does not justify its reasons for establishing this new authority. Moreover, CMS fails to describe is existing authorities and how this proposal is different. Finally, CMS does not provide justification regarding the number of times that CMS can require revalidation within a given period of time. Recommendation 2: To reduce the paperwork burden imposed on providers and suppliers and to reduce the administrative expense associated with processing a revalidation application, I recommend that CMS allow providers and suppliers in good standing to submit an annual attestation rather than revalidation application. The attestation would be used in lieu revalidation and require the provider or supplier to notify CMS of any changes or to attest that there were no changes within the prior year. By adopting this approach, providers and supplier would not responsible for submitting an application fee with a revalidation application. This approach would also promote compliance.