The effective date is the later of the following two dates:

  • The filing date of an enrollment application that was subsequently approved, or
  • The date the provider first began furnishing services at a new practice location.

The provider may bill retrospectively for services when:

  • The supplier has met all program requirements, including state licensure requirements, and
  • The services were provided at the enrolled practice location for up to
    • 30 days prior to their effective date if circumstances precluded enrollment in advance of providing services to Medicare beneficiaries, or
    • 90 days prior to their effective date if a presidentially-declared disaster precluded enrollment in advance of providing services to Medicare beneficiaries. 

Example:

Suppose that a non-Medicare enrolled physician began furnishing services to beneficiaries at her office March 1. She submitted the CMS-855I initial enrollment application May 1, and the application was approved June 1. The physician’s effective date of enrollment would be May 1, which is the later of: (1) the date of filing, and (2) the date she began furnishing services. The retrospective billing date is April 1 (or 30 days prior to the effective date of enrollment). 

Reference