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:
- They must identify on an ongoing basis which of their physicians who refer Medicare patients are not in the PECOS database.
- The new physician process needs to be changed to add the step to check the CMS website to determine if the physician is registered.
- 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
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