We find this impossible to believe. The form for individual health care practitioners, which must be completed by all physicians who render medical services to Medicare beneficiaries and to which our comments are directed, is 31 pages, including 15 pages of instructions. Indeed, the pages of instructions outnumber the pages of information that the physician must actually complete. Further, physicians who also plan to provide services as part of an organization must also complete a form to reassign their Medicare benefits. That form is 9 pages, including instructions.
Most health plans have physician enrollment forms that are one or two pages long.
We do not believe HCFA needs an application of 31 pages to achieve the same result. As detailed below, we have several suggestions for how HCFA can shorten the form. Further, the form is unnecessarily intrusive. For example, it asks questions about the applicant's age, gender, and national origin, all of which are classes protected from discrimination under federal law. It also asks where patient records are stored, which has nothing to do with the applicant's qualifications for providing quality care to Medicare beneficiaries.