Providers Add PECOS to the Worry Pile

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.