CMS published an interim final rule with comment period on May 5, 2010 implementing several enrollment and documentation changes to the Medicare and Medicaid programs as mandated by the PPACA. The rule is effective on July 6, 2010 and comments will be accepted through the effective date. In the final rule, CMS requires providers and suppliers to include their NPI on all Medicare enrollment applications, as well as all claims submitted to the Medicare and Medicaid programs. In addition, Part B services must be ordered or referred by a physician or, when permitted, another eligible professional. The final rule also requires physicians and other eligible professionals who order or refer Part B services for Medicare beneficiaries to be enrolled in the Medicare program or maintain a valid opt-out record. With respect to home health services, the services must be ordered by a physician (not an “eligible professional”). All claims submitted for Part B items or services must contain the legal name and NPI of the physician or eligible professional who ordered or referred the item or service. In addition, the rule requires both the furnishing and ordering provider or supplier of DMEPOS, home health, laboratory, imaging, or specialist services to maintain documentation of the order or referral for 7 years, including the NPI of the ordering or referring physician or eligible professional. The documentation of the order or referral must be supplied to CMS or the Medicare contractor upon request. Failure to comply with the documentation requirements may result in a 1 year revocation of enrollment and billing privileges in the Medicare program. Although much of the final rule was mandated by various sections of the PPACA, CMS is using its discretion to expand ordering and referring requirements to all Part B items and services except prescribed drugs. In the preamble to the final rule, CMS indicates that it “reserves the right” to apply these enrollment and ordering requirements to Part B drugs within the next year.