CMS Delays Ordering/Referring PECOS Regulation Until 2011

Okay so you have some breathing room but — don’t wait until the end of the year, CMS reps say.

Practices that have been struggling to make sure that their ordering/referring physicians’ national provider identifiers (NPIs) were in the PECOS system can now relax a little bit – at least until next year.

If your physician performs a service as the result of an order or referral, your claim must include the ordering or referring practitioner’s NPI, and that number must be in the Medicare Provider Enrollment, Chain, and Ownership System (PECOS) or the payer’s computer system.  As many of you know, on April 5th, CMS was going to begin denying your claim if the referring physician’s information was no in the MAC’s claim system or PECOS.  Currently, if the physician’s information is missing from the system you will receive a notification message advising you of this fact.

Because of number of physicians that have yet to enroll in PECOS, CMS has decided to push back the compliance date until Jan. 3, 2011, announced CMS’s Jim Bossenmeyer during a Feb. 17 CMS Open Door Forum. Repeating the information twice because of its importance, Bossenmeyer said, “CR 6417 and CR 6421 have been delayed until January 3, 2011.”

Don’t waste the extra time: Although many of you are breathing a sigh of relief, Mr. Bossenmeyer also made it clear to not wait until the last minute to register.

“The delay in implementing Phase 2 of these CRs will give physicians and non-physician practitioners who order items or services for Medicare beneficiaries or who refer Medicare beneficiaries to other Medicare providers or suppliers sufficient time to enroll in Medicare or take the action necessary to establish a current enrollment record in Medicare prior to Phase 2 implementation,” the CMS Web site indicates.

If you are unsure of whether your information is in the PECOS system, you review our previous post which includes a copy of the PECOS database.

Avoid Enrollment Application Lags

Also on the call, Bossenmeyer indicated that the number one reason for delayed processing of paper Medicare enrollment applications (855-I or 855-B forms) is “incomplete applications or delays in the submission of developmental materials.” CMS “strongly encourages” providers to use internet-based electronic PECOS, which is results in fewer errors. Always remember to sign, date, and mail your certification statement and any supporting documentation, Bossenmeyer noted.

DMEPOS suppliers will have internet-based PECOS availability later this year, Bossenmeyer said.

Get New Docs Into PECOS

One caller noted that her practice hired a new physician who moved from Oregon to Wyoming, but was remaining with the same MAC with which he was previously enrolled, despite moving from one state to another. Even in this case, the new practice should complete a new PECOS application for the physician.“Medicare enrolls physicians and NPPs (non-physician practitioners), along with groups, by state, not by MAC jurisdiction,” a CMS rep. noted on the call. “So if you’re in Montana and you’re in Utah, you should be enrolling twice – once for each state.” This is a common misperception and is unfortunate because of how much money it ends up costing physicians across the country.  And now, because of only allowing 30 days of retroactive billing, you could find yourself writing off thousands of dollars because of an incorrect enrollment application.