Anonymous-DC

Thank you for the opportunity to comment on this proposed regulation. According to the California Department of Health Care Services, a provider number is deactivated when: • Warrants or documents mailed to the service or business address or the pay-to address were returned by the United States Postal Service as not deliverable. • A claim has not been submitted for reimbursement from the provider for one year. • A Medi-Cal enrolled business is sold and the new owner (transferee) has been subsequently approved for enrollment. Prior to deactivating a provider number for either of the first two reasons above, DHCS makes an attempt to contact the provider by telephone or mail. If unable to make contact, DHCS is required to deactivate the provider number immediately without prior notice. For additional information about deactivation for returned mail or for non-participation, please refer to W&I Code, Section 14043.62(a) for the full text of the statute and the Provider Guidelines section of the Part 1 manual. First, I recommend that CMS explain why it did not consider any alternatives to its proposed change in its physician deactivation policy. I disagree with CMS’ proposal and believe that this proposed change will increase identity theft and fraud. Second, I recommend that CMS withdraw its proposed deactivation policy in CMS-9070-P and consider alternatives such as the State of California approach of notifying a physician by mail or telephone prior to deactivation. Third, I recommend that CMS explain why it is creating inconsitent deactivation policies within the Medicare and Medicaid programs.