If a specialist leaves a practice, can that specialist charge a 116 in the new practice without having a 110 on file with the new provider number?

If a specialist leaves one practice and joins another new practice, can that specialist charge a 116 in the new practice without having a 110 on file with that new provider number? Medicare will have a record of a previous 110 at some point? It seems silly to charge a 110 in a new location.