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.

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