PECOS ACTION ALERT
UPDATE: 10/12/10
PECOS
Update: Edits Delayed
The Affordable Care Act (ACA) included a
provision requiring physicians ordering home
health services to be enrolled in Medicare. The
Centers for Medicare & Medicaid Services (CMS)
published an interim final rule in May 2010 to
implement the ACA provision by requiring orders
for home health services from physicians
enrolled in Medicare and in the Medicare
provider electronic data base, PECOS. CMS
established two distinct phases for
implementation of edits for PECOS enrolled
physicians.
In Phase 1 of claims edits, which is now delayed
until November 8, 2010, HHAs will receive an
informational message when the physician’s legal
name and NPI does not match the information in
PECOS. The informational messages will let
providers know that were CMS to turn on the
edits, the service for which they are billing
would be denied because the ordering or
referring physician is not enrolled in Medicare.
However, there is no denial associated with
these notices. They are informational only and
are designed to let providers and suppliers know
about whether the eligible professionals who are
ordering and referring are enrolled in Medicare.
Not until Phase 2 is implemented will CMS
conduct editing that will result in claim
denials. CMS sent word to the National
Association for Home Care & Hospice that they
“will not be denying any claims simply because
the ordering and referring physician is not
enrolled—until such time as we make sure the
system to enroll is working properly and the
backlog of applications has been dealt with.”
The Phase 2 implementation date has not been
scheduled since CMS is still reviewing comments
from the regulation that was published in May
2010.
According to a CMS representative, “CMS has
promised to let the industry—including Medicare
beneficiaries who depend on the services of your
members—know well in advance of taking action to
turn on edits that could result in claim
denials.”
UPDATE: 6/30/10
We
received notice from NAHC this afternoon that
CMS will not reject claims for home health
services where the ordering/certifying physician
is not currently found in the PECOS record.
Click here for the news release. NAHC
assures CMS that we (Home Health Agencies) can
be counted on to help get physicians properly
enrolled on an expedited basis. This action is
due in no small part to the diligence of our
staff at the National Association of Home Care
and Hospice. Please stay tuned for continuing
updates.
Jane Kelly
KHCA Executive Director
6/29/10 -- The
National Association for Home Care & Hospice (NAHC)
continues to urge CMS and Congress to refrain
from implementing the enrolled physician
provision of the Affordable Care Act on July 6th.
Please find details about this requirement and
its impact on your agency and patients in the
PECOS ACTION ALERT.
In
order to assist you with the implementation of
the steps outlined in the “Immediate Action
Required” section of the ACTION ALERT , NAHC has
also developed model letters to send to
physicians and
discharge planners. Please feel free to
tailor these letters to meet your needs.
We urge you to contact your members of Congress
by phone or email in accord with the following
instructions:
Call
your Senators and Representative in Congress to
ask that they:
1)
Urge CMS to delay implementation of the rule
requiring that physicians ordering home health
care be enrolled in the PECOS data base.
Further, CMS should hold harmless home health
providers until such time as physicians have had
a reasonable opportunity to enroll, and
2)
Urge Congressional leaders to intervene with CMS
to resolve this issue. Let them know that this
is an important issue for you and your state as
patients otherwise eligible for Medicare
services will be denied care.
Click here to use the NAHC Legislative
Action Network to look up the phone numbers of
your senators or representative. When calling, ask
the Congress
member's receptionist to connect you with the
staffer who handles Medicare issues.
You
may also send an email to your legislators
Click here
to use a special action alert we've
added on the NAHC Legislative Action Network. A
sample message is provided, which you can then
personalize by adding information about your
background as a constituent and the importance
in your locality of providing a reasonable time
for physicians to enroll in PECOS in order to
maintain access to Medicare home health services
and DME.
Finally, we urge every home health agency to
submit formal comments to the CMS Interim Final
Rule that contains these new requirements and
the July 6th deadline. The notice can
be found at:
http://edocket.access.gpo.gov/2010/pdf/2010-10505.pdf.
Instructions for submitting comments can be
found on page 24437.
Mary
St.
Pierre
NAHC
228
7th Street, SE
Washington, DC 20003
202
547-7424
