Practice Management Alert

Question: The sequence in our state of applying for the advanced practice registered nurse (APRN) license and then to Medicare could mean that the graduate has been providing services for six months before we can apply to National Government Services with the National Provider Identifier (NPI). The current rule indicates that we can go back only 30 days from the date of the Medicare application. Does this rule disallow new master's degreeprepared graduate nurses from providing services to Medicare members?

Oklahoma Subscriber

Answer: Under the old rule, physician and nonphysician practitioners (NPP) could submit claims for services provided up to 27 months prior to the date of enrollment into the Medicare program.

The rule currently defines the enrollment date as the later of the dates an enrollment application was filed (assuming subsequent approval of the application) or the date when the enrolled provider started providing services at a new location. In either case, Medicare allows you to bill 30 days prior to a successfully filed enrollment application.

The rule applies to new physicians as well as certified registered nurse practitioners (CRNPs). The old concern was that a provider could treat Medicare patients for more than two years (27 months) before being classified as a successful or unsuccessful Medicare provider. The current rule dramatically shortens the time frame. Your practice or the applicant is responsible for having a completed application submitted to Medicare within 30 days of the new graduate treating these patients.

Pointer: Your ANRP can treat patients incident to a physician while she is waiting for her 30-day window to start.

Take note: CMS asserts that the Provider Enrollment, Chain and Ownership System (PECOS) will improve enrollment processing to allow contractors to process applications in 30 to 45 calendar days. The current process requires 60 to 90 calendar days. Again, the important time is 30 days before an approved application was completed (the approval date could be after that period). So if taking the exam and getting the APRN license requires six months, you would bill the services to Medicare only for the final month.