PECOS Registration Scramble Resumes

BALTIMORE — Earlier this year, HME providers heaved a sigh
of relief when CMS announced it would delay implementation of
the PECOS edits — which require verification of a
referral source’s Medicare enrollment — until Jan. 3, 2011.
But regulations related to the Patient Protection and Affordable
Care Act have put them right back in the hot seat on making sure
their referring physicians are registered in the Internet-based
system.

The Provider Enrollment, Chain and Ownership System 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 in question, if ordering/referring
physicians or other non-physician practitioners listed on DMEPOS
claims are not in PECOS, those claims will reject.

CMS had originally set Jan. 4, 2010, as the effective date for
the system edits, but later pushed that date out to April 5 and
then to Jan. 3, 2011. Following passage of the new health care
reform law, however, on May 5, CMS published an interim final rule
stipulating that physicians and other eligible professionals who
order items and/or services for Medicare beneficiaries must have an
approved enrollment in PECOS by July of this year.

On a Special Open Door Forum May 19, CMS’ Jim Bossenmeyer noted
that the new regulation would become effective July 6. Confused
callers wondered: If they submitted claims for items and/or
services ordered after July 6 by a physician who was not enrolled
in PECOS, would the claims reject?

In an exchange with one caller, Bossenmeyer seemed to indicate
the edits’ implementation date would remain Jan. 3, 2011. (See
“New PECOS
Chapter to Begin for HME Providers, May 24.)

But last week on a May 26 call, Bossenmeyer said CMS is
developing the system edits now to check whether order/referring
physicians or non-physician practitioners are enrolled in PECOS.
The edits may not be active by July 6, but  ”we reserve the
right to go back and reprocess claims,” Bossenmeyer said.

“When we implement those edits … if we don’t have the
correct name and NPI combination on the claim for the ordering and
referring [physician] or the individual is not enrolled in the
Medicare program, your claim will be rejected,” he said, adding
that CMS would notify providers in advance of when the edits will
be implemented.

Comments on the IFR are being accepted until July 6. Bossenmeyer
said CMS “will carefully review all comments, including the
concerns you have raised about compliance with the July 6
deadline.” However, he continued, “The interim final rule is
effective until we publish a final version of this rule.”

CMS recently announced that HME providers would be able to
utilize the PECOS system to manage their own
enrollment processes beginning July 13. For more information,
check CMS’ “Getting Started” guide for DMEPOS
suppliers.

For a downloadable list of physicians with current enrollment
records in PECOS, see www.cms.gov/MedicareProviderSupEnroll. Select the
“Ordering Referring Report” on the left, then scroll down to the
PDF file.