BALTIMORE — The Medicare competitive bidding window may have opened Oct. 21, but HME providers wanted to talk about the Medicare Provider Enrollment, Chain and Ownership System (PECOS) during a CMS Open Door Forum call Wednesday afternoon.
"You can probably tell that this is a big topic for us and the DME industry," said one provider in a comment that represented the frustration of many callers. "We are already struggling to keep our heads above water, and now we have been handed this daunting task of trying to get our physicians to do what we need to do, when there is really no incentive in it for them. I would ask that you all take that into consideration when you're looking at this process, and when you look at possibly delaying this deadline for us."
But a delay of the Jan. 1, 2010, deadline — when claims without PECOS-registered referrers begin to reject — may not be in the cards, according to CMS Division Director Jim Bossenmeyer. In responding to the comment, he said, "Currently there is no consideration for a delay in this process. We will continue to evaluate it, but there is currently not a decision made to delay this process. And I would not count on one happening."
Late last year, CMS rolled out its Internet-based PECOS, which allows physicians and other practitioners to enroll in Medicare, check on the status of an application or make a change in their enrollment information. But according to officials on the call, even if physicians are enrolled in Medicare but have not submitted any updates or changes to their enrollment record since 2003, it's likely their information won't be in the new system.
The January deadline concerns physician and non-physician practitioners who must be enrolled in PECOS. As of Oct. 5, if the ordering/referring physician on a claim is not in the system, or is in PECOS but not of the type/specialty to order or refer, the claim will continue to process — and the provider will receive a warning message from the Common Electronic Data Interchange (CEDI). Beginning Jan. 1, such claims will reject.
Rose Schafhauser, executive director of the Midwest Association of Medical Equipment Suppliers Association, reported in MAMES' newsletter earlier this week that home care providers have, in fact, already received hundreds of warnings, and she relayed this information to CMS officials in a question-and-answer period during the Open Door.
"Under the PECOS, we understand it is taking 45 to 60 days for the physician to show up in the registry; several members throughout our seven states have contacted physician offices and have been educating them, [but] physicians are unaware of the program and asking us to help them register," said Schafhauser. "Factoring all this, is CMS considering delaying the date of the start of the rejection of the claims?"
Again, Bossenmeyer reiterated that officials were considering no delay. "If a physician chooses to enroll using Internet-based PECOS, the application can be processed within a few days of the contractor receiving the signed certification and other supporting documentation," he said. "The fastest way for a physician or non-physician practitioner to enroll and update their enrollment information is to review the information that we have available and use the Internet-based PECOS process."
While some callers worried they had no way to find out whether physicians are in the system, Bossenmeyer said providers can check listings for referral sources at www.medicare.gov/physician/search/chooseprovider.asp.
Additional PECOS-related exchanges were as follows:
Physicians have 'no idea' what we're talking about
Question: I would just ask that continuing education go on with the physicians, because we have had the same thing that [Rose Schafhauser] mentioned when she called earlier. We are calling our physicians, and they have no idea what we are talking about.
Bossenmeyer: The question should be to the physician, 'Have you updated your enrollment information with Medicare since November 2003?' If they are a long-standing Medicare physician and have not made any changes in their enrollment information, they likely have not updated their information.
Question: The answer we are getting to that is 'Why is it any of your business? Why are you as a DME supplier telling us what to do?'
Bossenmeyer: Medicare will be raising this issue at the next physician Open Door Forum, and we will continue to educate physicians via conference calls and with our contractors to update and maintain their enrollment in the Medicare program.
Why should the burden fall on DME providers?
Question: Regarding the PECOS system, will the physician's claim also be rejected in January 2010 if they are not in the system?
Bossenmeyer: Physicians' claims will continue to be processed.
Question: Why are DME claims then being rejected?
Bossenmeyer: Medicare requires that we know who the physician is, that the physician is licensed and that they are qualified to continue to participate in the Medicare program. To implement that provision, physicians must be enrolled in Medicare with a current enrollment record within Medicare.
Question: So that burden falls on [DME providers] to make sure?
Bossenmeyer: Medicare will continue to conduct outreach to physicians. Again, there are only a limited number of nonphysician practitioners who are eligible, and those are physician assistants, certified clinical nurse specialists, nurse practitioners, clinical psychologists, certified nurse midwives and clinical social workers. So if you are receiving orders and referrals from nonphysician practitioners other than those, those will not be eligible for future payment beginning in January of next year.
How come physicians don't know they should register in PECOS?
Question: How have physicians been notified that they have to register with PECOS?
Bossenmeyer: CMS has encouraged physicians since November of 2006 to update their enrollment info with Medicare. We are doing revalidations where we are requiring physicians and other practitioners to update their Medicare enrollment information. If they do not respond to the revalidation, then Medicare would take some action to revoke their billing privileges.
Prior to the Q&A session, Bossenmeyer reminded providers that CR 6421 also requires that claims coming from DMEPOS suppliers must include the legal business name of the physician.
On the competitive bidding front, CMS' Joel Kaiser, deputy director of DMEPOS policy, added that the bidding window for the Round 1 rebid closes on Dec. 21, and that Nov. 21 is the "covered document review date," which is designed to motivate providers to turn in all financial documents no later than that date. If providers make the deadline, they will be notified of any missing documents. However, they will not be told if those documents are correct and/or filled out properly.
View an MLN Matters Article (MM6421) on the PECOS.
