PECOS Edits Delayed until 2011

BALTIMORE — Home medical equipment providers working
frantically to get physicians enrolled in the Provider Enrollment,
Chain and Ownership System got a gift of time Wednesday when CMS
announced it would delay planned — and controversial —
PECOS edits until 2011.

“CMS is going to delay the implementation of [change requests]
6417 and 6421 until Jan. 3, 2011,” Jim Bossenmeyer, CMS director of
provider enrollment, told more than 1,000 relieved listeners on a
Special Open Door Forum call.

The Internet-based PECOS allows physicians and other
practitioners to enroll in Medicare, check on the status of an
application or make a change in their enrollment information. Under
the edits, if ordering/referring physicians or other non-physician
practitioners listed on DME claims are not in PECOS, those claims
will reject. CMS had originally set Jan. 4 as the effective date
for the edits, but later pushed the date out to April 5.

The agency did not give a reason for the delay, but the American
Association for Homecare did in its Wednesday afternoon
newsletter.

“Facing overwhelming enrollment problems, CMS recognized that it
was unable to implement PECOS on the scheduled implementation date
of April 5, 2010,” the association said, noting that it had been
pushing for the delay and had reached out to the American Medical
Association for support on the issue.

Last November, the AMA and more than 50 other physician and
related groups wrote acting CMS Administrator Charlene Frizzera
requesting that the agency delay its PECOS plans. At that time, the
groups estimated “as many as 200,000 or 30 percent of all Medicare
physicians and other health care practitioners are not in PECOS and
will need to re-enroll.”

CMS has said it is the responsibility of DME providers to ensure
that the ordering physicians on their claims are registered in the
PECOS. But that has caused an uproar among the industry’s
providers, who reminded agency officials that they have no
authority over physicians and that there is no incentive for
physicians to participate in the system.

On an Open Door call in January, Alabama provider Carey Jinright
crystallized the problem. “I don’t have control over my physicians,
and many of them are much more interested in their own benefits
than mine … so why is there not a consequence for their
inaction?” he asked.

His physicians, Jinright told CMS representatives, “don’t
understand what is being asked of them and the importance of that.
Their question to me is, ‘Will my claims deny for my Medicare
beneficiaries as of April?’ and I have to say, ‘Honestly, no, but
mine will.’”

“Ideally, we would like to see some sort of requirement that
ties physicians to the PECOS enrollment process. Their claims were
not in jeopardy, but ours were,” said Walt Gorski, AAHomecare vice
president of government affairs. “The burden should not be placed
on the HME provider to press physicians to enroll. Nevertheless,”
he said of the delay, “this is an excellent outcome.”

Bossenmeyer said CMS would offer a little leverage that
could  help providers get physicians enrolled.

“We’re working with the physician community to ensure that all
physicians and non-physician practitioners update their enrollment
by January of next year,” he said. Otherwise, they won’t be able to
order/refer under Medicare.

Bossenmeyer said CMS will be sending out revalidation letters to
physicians who have not updated their information for six years.
Medicare contractors began updating the PECOS with physician
enrollments in November 2003; physicians who enrolled before then
are not in the database. Physicians who have not billed Medicare
within the last 12 months also need to file an application to
revalidate, officials said.

 ”We’ll be validating that Medicare has current information
on contractors it is paying,” Bossenmeyer said.

He noted that in 2009, 10,000 revalidations were received and
are still being processed. Because PECOS enrollment is ongoing,
providers will continue to see warning messages on their
GenResponse reports for claims that wouldn’t pass muster under the
edits.

Officials said the PECOS would be available for DMEPOS providers
who want to enroll or update their own information online later in
2010.

While the PECOS delay was the hot news of the day, it was the
system itself that garnered the most questions on the call.
Numerous representatives from physician groups and others described
frustrating glitches that ranged from the absence of a view
function on the site and being referred to wrong numbers to getting
conflicting information on questions.

“It’s also frustrating as a provider that even the customer
service reps we speak to, they’ve never seen the system,” said one
Massachusetts caller. “I think it’s important that they get a
demonstration … they have no idea what the screens look like,
they’ve never been to the application. And we’re unable to speak
with provider enrollment personnel …

“It’s a little bit of a cumbersome system. It needs some
user-friendy interface.”

In other announcements during the Open Door, officials also
noted that:

• CMS will study the consignment closet issue in the coming months
  and determine whether or not to redo the policy. In August 2009,
  the agency issued
  a new rule governing the closet arrangements, but rescinded the
  rule earlier this month.

• Pharmacies billing HME to Medicare must be accredited by March
  1. CMS had previously said revocations for those not meeting the
  Jan. 1
  pharmacy accreditation deadline would be “prioritized based on
  any potential beneficiary access issues as well as the agency’s
  workload.”

• Medicare contractors are conducting more on-site reviews and
  “the provider must be operational at the location provided,”
  Bossenmeyer said. “They will be reviewing state licensure and
  accreditation information. If there is a change in your
  accreditation or licensing, you need to notify the applicable
  Medicare contractor as soon as possible.”

An audio recording of Wednesday’s call will be available on the
Open Door Web site around March 1, officials
said.