PECOS Database Audit Enhanced to include NPI Audit

The Rock-Pond PECOS Database audit has been extended to include audits for invalid NPI numbers.  In addition to reviewing the batch physician file against the PECOS registration file, Rock-Pond now reviews every NPI number against the master NPI file to determine if the NPI number is valid. 

Once the invalid NPI numbers are identified, use the FREE NPI / Physician lookup available from Rock-Pond to find the correct NPI number and update your physician file. 

We are excited to leverage our commitment to keep the NPI and PECOS databases current for our PECOS Database Audit customers, to provide a FREE and useful service for the home health care industry.  Although there are other places you can look up NPI numbers, most of them do not include PECOS registration information at the same time. 

Our goal is to simplify the process of complying with Medicare regulations, reduce or eliminate unnecessary denials and thereby help to improve the profitability and quality of care provided by our customers.

Rock-Pond launches FREE NPI / PECOS Search feature

Healthcare providers who have the need to lookup physician NPI information, including the current status of PECOS registration can do so from the Rock-Pond Solutions website for FREE. 

Rather than having to go to multiple websites to get the information or go through the technical process of downloading files that are constantly updated by CMS, anyone can simply look this information up from our NPI / PECOS Search page (available from the drop-down Solutions menu).  Physician information be found by providing the NPI number, first name, last name, city or state information.  ‘*’ can be used as a wildcard to find physicians when you are not sure how their name is spelled. 

This FREE service compliments our PECOS database audit service which allows a provider to batch audit their entire physician database at one.  This service is available for a nominal charge of $600 and includes unlimited batch audits for a year.  This will be plenty of time for providers to get their files in order by the compliance deadline.  Rock-Pond recommends you purchase a PECOS database audit service to see exactly how many of the physicians referring you Medicare patients are not registered in PECOS, put the process in place to contact and follow up on these physicians and modify your new patient intake process to validate the NPI and PECOS information for all your patients using the FREE Rock-Pond Solutions Search feature.

Featured Artist – Bill C. Ray

HomecareNet PECOS tracking

One of the great things about HomecareNet is that it is so robust. Sometimes viewed as complicated, it all pays off when you need to respond to business / industry changes. It’s great for the Mediware development staff too since they don’t have to constantly release “little fixes” with special instructions so the system will handle new, unforseen requirements.

The word of the moment is PECOS, the CMS physician registration process that everyone is scrambling to make sure their referring physicians have completed so they can get paid from Medicare. As a home infusion provider you need to do three things:

1. Identify the physicians you work with that are not registered.
2. Change your intake process to verify that the physician is registered with PECOS.
3. Contact physicians that are not registered to “encourage” them to register or make a decision not to take their patients. 

Do these three things and PECOS will not be a problem for you.  Best of all, these are not hard.  If you are using HomecareNet from Mediware, we recommend:

1. Use the Rock-Pond PECOS Database Audit to find out exactly where you stand right now.
2. Set up a PECOS organization in your HomecareNet system and add it as an affiliation to all of the physicians you work with who you’ve verified are registered in PECOS.  Modify your intake process to check this whenever a Medicare patient is admitted. 
3. Work with your physicians to see that they get registered. 

That’s it.

Featured Artist – Karrie Evenson

What are my billers doing?

All home infusion software systems have the ability to assign billers and collectors to payers, patients, invoices, at varying levels.  However, the day to day process of managing your billing department to measure and increase productivity requires the ability to report the revenue based on who actually created the claim versus who is assigned in the system to bill for the patient.  This will help you accurately measure who is creating revenue and measure the volume of claims and patients a billing clerk is working on.

The following are some areas that cause difficulty in accurately measuring productivity:

• Billing primary versus secondary claims
• Assigning specific billers to a therapy across all payers (such as IVIG) is usually not supported by software systems.
• The need to manually transfer the assigned payer when the invoice is transferred to the secondary payer or the patient is time consuming and often not done.
• The difficulty of billing based on therapy and payer is not always the same across therapies and payers, thereby making it difficult to compare productivity across billers.
• Employee changes and the need to temporarily or permanently adjust the billing workload makes the default assignments in the system ineffective.

The end result is that even though it appears that assigment and management of billing personnel is handled by existing software features, in other than the smallest home infusion providers, this is a very challenging area.  The first measurement to answer the question, “What are my billers are doing” requires the ability to produce a report like the one below, that is based on the biller who created the claim rather than who was assigned to the claim.

Alt-Spacebar brings up Windows Menu

Unless you’ve been in a situation where you have a window that is partially on your screen and you need to move it, you won’t fully appreciate this tip.  Or if you are set up to use two monitors with your laptop and you are out of the office and only have one monitor, only to find that Windows “remembers” that when you launch a program that it is to appear on your second monitor.   If you been in either of these situations, you’ll agree with me that this is the tip of the year.

SITUATION: You are accessing a system remotely and a program window is half off (or completely off) of the screen and you want to move it so you can use it. You can’t see (or click on) the top part of the window to move it.

TIP: Hold the alt-key down and press spacebar. This will bring up the windows menu and allow you to select a command by pressing the appropriate key. Press the “M” key to select move and use your arrow keys to move the window until it magically appears on your screen.

This is just one of the many keyboard shortcuts you can use with Windows.  Others can be found on the Microsoft Website.

Unlimited audits included with PECOS Audit purchase

Rock-Pond announces unlimited PECOS Database Compliance Audits with single audit Solution purchase. 

The PECOS Database compliance audit tool released last week has been enhanced to provide repeated audits as new databases are released from CMS.  Each time a new database is released by CMS, all customers will be notified and if they want to re-audit their physicians, they simply have to reply to the email with their updated physican export attached and the Audit Excel Spreadsheet will be returned via email. 

“This is the kind of simplicity and service our customers expect from Rock-Pond” said Pete Tanguay.  “Especially in a time of uncertainty with the entire PECOS compliance situation.”

The PECOS audit tool has been well received by our customers and has also introduced a number of new home infusion providers to Rock-Pond Solutions. The tool works with the CPR+ system as well as the Ascend, Ascend-HI and HomecareNet systems from Mediware.

NHIA members have access to a PECOS compliance page in the Reimbursement Resource Center on their website.  It has comments from NHIA as well as valuable links for more information and free web-based tools to help you be informed and ready.  Click on the image on the left to go to this page.

PECOS Compliance – Clearly unclear

The following is a portion of the July 12 HomeCare Monday email discussing the current status of PECOS compliance. It’s bad enough that home infusion providers are being held for physician compliance, something they do not have control over, but reading this gave some real insight to the precarious position we are in and the lack of clarity from CMS.

Say What about the PECOS?
BALTIMORE—The question has been asked any number of times now in any number of ways: What exactly is the deal with PECOS compliance regarding DME claims?

The industry’s latest attempt at getting a straight answer came from the American Association for Homecare’s Walt Gorski, vice president of government affairs, on a CMS Open Door Forum July 7.

The background:

The deadline for physician and other prescriber enrollment in the Provider Enrollment, Chain and Ownership System was Jan. 3, 2011, but in order to be compliant with the new health reform law (Affordable Care Act, or ACA), CMS pushed that deadline up to July 6 in an interim final rule.

In a June 30 announcement, the agency said it would “for the time being not implement PECOS edits that would automatically reject claims based on orders, certifications, and referrals made by providers that have not yet had their applications approved by July 6, 2010.”

But the agency gave providers no assurance that, in future audits, they wouldn’t have to give back their Medicare reimbursements based on claims submitted from July 6 to Jan. 3 if the ordering physician was not enrolled in PECOS.

So, AAHomecare’s Gorski asked:

Will [you] address that specific issue, that CMS and its contractors will not seek recoupment from claims that are receiving warnings during this period?

Jim Bossenmeyer, CMS director of provider enrollment, responded this way:

There are a number of reasons why Medicare may recoup money.”

He added that DMEPOS suppliers should:

• Make sure their claims contain the legal name of the physician or other eligible professional along with their Type 1 NPI;
• Make sure the individual is licensed to practice in the state and has not been excluded from the program by the Office of Inspector General;
• Keep documentation from orders for services referred to them; and
• Work with their referral sources to make sure they know there is a requirement for PECOS enrollment.

Gorski tried again:

If we do that and a ZPIC or RAC audit occurs in 2012 and they look and see the effective date of the IFR and see that the referring physician was not enrolled in PECOS, you are telling the supplier community that the money will not be recouped?

To which Bossenmeyer replied:

I have not said that. I understand what you would like me to say, but I cannot give you that answer today.

The comment period for the IFR closed July 6.

At some point,” Bossenmeyer said, “CMS, after we have gone through looking at the public comments, will make a decision regarding the implementation of systematic editing.

One more try from Gorski:

If that is the case, what do [suppliers do if they] get a referral from a physician that is not PECOS-enrolled?

Said Bossenmeyer:

What I’m suggesting to you is that most physicians have an enrollment record in PECOS.” There are 26,000 more physicians and 3,400 more non-physician practitioners in the system’s “pending” file that are currently going through the enrollment process, he added.

“DMEPOS suppliers know the physicians they work with and they know the non- physician practitioners they work with,” Bossenmeyer said. “They should submit compliant claims.

What I’m suggesting to you is that most physicians have an enrollment record in PECOS.” There are 26,000 more physicians and 3,400 more non-physician practitioners in the system’s “pending” file that are currently going through the enrollment process, he added.

With that, AAHomecare reported in its July 8 newsletter, the association “continues to press CMS for clear and unambiguous guidance and is working with providers and patient groups to address our concerns.” And there are a lot of them.

In an eight-page letter sent to CMS, the association formally requested a delay in enforcement of PECOS regulations. The letter reads, in part:

Under the circumstances, it would be patently unfair for CMS and its contractors to reopen claims as a means of enforcing ACA compliance. DMEPOS providers, at best, have only limited influence over what their referral sources do.

More importantly, the IFR offers zero guidance with respect to what providers must do to demonstrate their compliance with the new rules. Although we appreciate the steps CMS is taking to soften the impact of the rule, the potential that providers, whose claims get paid after July 6 but before CMS implements rejections for ordering/referring physicians, will nonetheless be at risk for recoupments based on audits. This will affect HME providers’ cash flow in ways that can be disruptive to patient care.

Consequently, we request that CMS delay the rule and its enforcement until January 3, 2011, at the earliest. Further, because our experience proves how difficult it is to motivate referral sources to comply with these rules, we strongly recommend that CMS publish the percentage of physicians and eligible professionals enrolled in PECOS as of November 30, 2010. If the percentage of providers who are not enrolled in PECOS is greater than five percent of the total number of prescribing physicians and eligible professionals nationwide, CMS should delay the implementation date until this target is met.” Also on the Open Door call, Bossenmeyer said DMEPOS suppliers would not able to use the PECOS system themselves “until the fall of this year.” CMS had previously said the system would be open for DMEPOS enrollment in July.

Rock-Pond Solution’s PECOS Database Audit Tool is one way to assess your risk and do something about it NOW. 

PECOS Database Audit Service a Huge Success

Rock-Pond Solutions added a PECOS database audit service to assist home infusion and DME providers determine their readiness for the CMS requirement that all ordering and referring physicians related to a Medicare claim be registered in the CMS PECOS database.  Although the deadline to be fully compliant was extended from the July 6, 2010 date, the service has proven extremely useful to those who have gone through the audit. 

According to one customer who utilized the service, “The real challenge here is being able to identify the physicians that are not registered who are associated with active patients.  Over time our physician file has grown to thousands of physicians and the Rock-Pond audit service enabled us to focus on the unregistered physicians that were involved with active Medicare patients.  We know our exposure, have adjusted our intake process to include PECOS registration verification and billing notification and we are ready when CMS decides to enforce compliance.” 

One customer who had us process their file today had the following stats.  We turned the file around in less than 10 minutes.  It doesn’t matter how cheap your clerical staff is, you can’t beat the price to quickly identify your exposure like this.  They had:

• 4,463 physicians
• 1,131 that were not in the PECOS database
• 3,332 that found a match in PECOS
• Of the 1,131 that were not there, it told them that only 30 had current active patients on census
• The report provides a drill-down “view patient” feature to quickly identify which ones have Medicare insurance
• Of the 3,332 that a match was found, 1,445 had differences in the first name and 192 had differences in the last name.

They have everything they need to put together a plan so when Medicare decides to enforce compliance, they are ready.  They went “from thousands of physicians, where do we start, I hope we are doing ok” to “we know exactly where we are and we can get this done” within 10 minutes.  We will do another batch comparison for them for free when compliance goes into effect. 

The  PECOS database audit service is a Rock-Pond Solution worth using whether you think you are in compliance or know you are not. It will check the name and PECOS status of ALL of your physicians at one time and tell you exactly where you stand.  Your results are delivered in an easy to use Excel Spreadsheet.

Featured Artist – Deborah Allen

CMS Physician Registration Compliance

Any physician who refers or orders services (DMEPOS, home health, specialist services [not defined by CMS], lab, or imaging) will need to be enrolled with Medicare in the Provider Enrollment, Chain and Ownership System (PECOS) by July 6, 2010. This includes any physician who has not submitted an updated enrollment application to Medicare since November 2003 or has had a change to their enrollment information during this time but has not reported the change. If physicians are not enrolled by July 6, the physicians who they refer patients to could see their claims reject. This enforcement goes beyond what is in the new health system reform law which says that by July 1, 2010, all physicians who refer/order home health and DMEPOS must be enrolled. The law does allow for the Secretary to require physicians who order/refer other services to be enrolled later, but CMS has decided to require them all to be enrolled in PECOS by July 6, 2010.

Earlier this year, the compliance date had been delayed to January 3, 2011. Physicians and other providers should not delay in verifying their current PECOS enrollment as the enrollment process takes about 45 days. To verify current PECOS enrollment, contact WPS Medicare enrollment at (866) 503-7664 or check the “Medicare Ordering and Referring File” periodically updated on the CMS Web site.

What this means for home infusion providers is:

1. They must identify on an ongoing basis which of their physicians who refer Medicare patients are not in the PECOS database.
2. The new physician process needs to be changed to add the step to check the CMS website to determine if the physician is registered.
3. A process needs to be put in place to contact the physician if they are not registered. 

Rock-Pond Solutions has added a PECOS database audit service to do a physician file audit with a 24 hour turnaround to assist providers in determining their physician compliance and minimize the financial risk of denials. 

The following is a sample letter that might be sent to a physician to request them to register in the PECOS database.

Dear Dr. XXXXXX:

By now you have likely heard of PECOS. PECOS (the Provider Enrollment, Chain, and Ownership System) is a comprehensive healthcare provider database maintained by the Centers for Medicare and Medicaid Services (“CMS”). 

On October 5, 2009, Medicare contractors began validating referring physicians referenced in claims for reimbursement for durable medical equipment against PECOS to ensure that only those physicians qualified to prescribe DME are doing so.

Currently, these validations result in warnings to the DME providers; however, on July 6, 2010 claims will be rejected if the referring physician’s information is not found in the PECOS database. It is important that your information in PECOS is complete and accurate so that your patients’ DME equipment is eligible for reimbursement after July 6, 2010.  It is ESSENTIAL that your information is complete and accurate to ensure your patients receive the necessary supplies, medications, and equipment required for their care at home.

Attached please find a basic guide for accessing and updating your PECOS information in the CMS database.  If you have not yet registered and would like more detailed instructions in how to complete this process, please contact our office at (XXX) XXX-XXXX.  Thank you in advance for your business.

Regards, 

Name
Title

IT-Business Convergence

We’ve come a long way since the first computer showed up in the temperature controlled room in the basement of the hospital or on the desk at patient registration in the physician’s office.  Technology has been one of the key enablers of the home health care industry. 

It has been a hard sell over the years to convince clinicians driven by the desire to care for people the importance of using point of care devices and spending an increasing amount of time with a machine rather than their patient.  It’s been even more challenging to get the owners and leaders of companies to understand that technology leadership starts at the top of the organization and they must understand, embrace and utilize technology and information on a daily basis. 

IT-business convergence occurs when a company breaks down the walls betweeen the IT and business sides of the business so that the technology professionals go beyond supporting the business to truly enabling and transforming the business. 

Companies with a high degree of IT-business convergence do the following:   

• View IT as an innovation engine that continually transforms the business, often enabling new revenue streams.
• Regard their customers as kings and view customer service, both internal and external, as supreme.
• Rotate business and IT staffers across departments and job functions.
• Provide an overarching goal that is crystal clear to each and every IT and business employee.
• Ensure that IT employees know how the company makes (or loses) money.
• Create a distinct, vibrant and unique company culture.

Reference:  “These CIOs go way beyond Business Alignment” – Computerworld, May 24, 2010 

There is simply too much opportunity for growth and risk of failure to allow key managers to claim IT ignorance or IT professionals in our company to remain isolated from the business they are serving.

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