Anonymous-TX

Document ID: CMS-2011-0161-0005
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: November 08 2011, at 12:00 AM Eastern Standard Time
Date Posted: November 15 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: October 24 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: December 23 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80f68037
View Document:

This is comment on Proposed Rule

Medicare and Medicaid Programs: Regulatory Provisions to Promote Program Efficiency, Transparency, and Burden Reduction

View Comment

Thank you for the opportunity to comment on this proposed regulation. In December 1995, the Department of Health and Human Services Office of the Inpector General recommended in OEI-01-94-00231 that HCFA should require the carriers to deactivate annually all provider numbers without current billing history and to update provider records periodically. The report states that the OIG believes that a 1-year time period for deactivation should be established. This OIG report also states that a large number of active but unused numbers poses signifcant issues regarding integrity and efficiency, including misusing provider numbers, skewing utilization reviews, evading sanctions, and knowing accurate group composition. I recommend that CMS explain why it is disregarding the OIG's 1995 recommendation found in OEI-01-04-00231 to establish a 1-year time period for deactivation. I also recommend that CMS explain why it made the decision not to include the history and background associated with reason for establishing a 1-year deactivation process.