Confusingly, NCDs are "effective" on the day they are published, but contractors develop "implementation" rules and instructions over months - in this case, over a year. (See here).
The "effective" date remains March 16, 2018, but the brand new "implementation" date is April 8, 2019.
- See Transmittal 214 here.
CMS also indicates that it knows stakeholders are confused and upset and it is working on the issue.