This Rule Takes Effect Next Week.
Act Now to Protect Your Patients and Your Industry.
As of July 6, 2010, up to 40% of doctors who order home health services may no longer be able to do so. For years, the Centers for Medicare & Medicaid Services have urged doctors to enroll in PECOS (Provider Enrollment Chain and Ownership System). CMS has repeatedly delayed implementation of a rule stating that only doctors enrolled in PECOS can order or refer services for Medicare beneficiaries. Until recently, the latest postponed deadline was January 3, 2011. However, the Patient Protection and Affordable Care Act signed into law on March 23, 2010 moved the deadline to next week, July 6, 2010. The National Association for Home Care & Hospice (NAHCH) reviewed home health agency audits and found that 24% to 40% of ordering physicians did not meet the PECOS enrollment requirements.
The PECOS rule will not affect immediately every type of service ordered by a physician. As of July 6, 2010, CMS will reject claims from DMEPOS providers if those claims show an authorizing physician who is not PECOS enrolled. DMEPOS providers are durable medical equipment, prosthetics, orthotics, and supplies. NAHCH states that home health bills will also be checked against PECOS enrollment starting July 6. Bills you have already entered may also be affected if they have dates of service on or later than July 6. Laboratory services, imaging services, and specialist services may also be affected. The physician’s ability to bill for their own services and to order Part B drugs may not be affected until 2011.
When a doctor enrolls in PECOS, it typically takes up to 90 days for that doctor to appear on CMS’s verification list. With the upsurge of enrollment applications CMS is likely to receive in the near future, it may take even longer for doctors not currently enrolled to become verifiable on the list.
This article details several steps that home health agencies should implement to protect themselves and their patients. These steps will be labor intensive. Before reviewing these steps, please take a moment to notify your federal legislator about this problem. Even if you are not a provider directly affected by the PECOS enrollment rules, please contact your congress people to urge better protection for your community’s elderly. Forward the email you received or a link to this article to all your employees and patient/families who might help bring this impending crisis to the attention of your legislators.
- Go to www.VoteSmart.ORG.
- Enter your zip code at the top left of the page.
- Find a list of your congressional representatives.
- Click each representative.
- Their contact information will appear at the bottom right.
- Call each office or click through to each congress person’s website.
- Advise your policy makers that a new deadline regarding CMS PECOS enrollment threatens to cut short the home health episodes of 40% of patients who need home health. Most of these patients are not only elderly, but they are also ill or injured. They are among the most vulnerable in our society. We must give doctors more time to enroll in PECOS before throwing their patients into nursing homes. We must enact the PECOS deadline in a way that does not retroactively penalize home health agencies for bills that were correct at the time of submission.
This PDF shows relevant passages of the Federal Register. The first page gives additional means for commenting on this rule.
http://edocket.access.gpo.gov/2010/pdf/2010-10505.pdf
Action Steps for Home Health Agencies and DME Providers:
See if your referral sources are PECOS enrolled
- Go to this page on the CMS website: http://www.cms.gov/MedicareProviderSupEnroll/06_MedicareOrderingandReferring.asp
- Download the list of PECOS enrolled doctors. This list is a 13,000 page PDF document or a CSV with 72,000 lines. It will tie up significant resources on your computer. Use a newer, faster computer in your office for these processes. Microsoft Excel and other spreadsheet programs can open the CSV. If possible, use the CSV instead of the PDF. The internal search features in Microsoft Excel and Microsoft Access are much faster than the search feature in Adobe Acrobat.
- Sit down with a list of your doctors, use the search features in your software to find each of your doctors, and highlight referring physicians not enrolled in PECOS.
- If you cannot find your physician, verify that you have the physician’s correct legal name and correct NPI number.
Contact Physicians
- Contact physicians who do not appear in PECOS.
- Ask them for a copy of PECOS verification for your records.
- If necessary, inform them that Medicare is poised to suspend their rights to order home health, DME, lab services and other important services effective July 6, 2010.
- For more information, send doctors to the website of the American Association of Family Practitioners. This page contains a good article on PECOS from the physician’s perspective: http://www.aafp.org/online/en/home/publications/news/news-now/practice-management/20100624pecosdeadline.html
- They can also simply visit www.AAFP.org and search on PECOS.
Contact Patients
- After contacting physicians, contact all patients who are under the care of doctors not enrolled with PECOS.
- Make arrangements for getting orders from a different doctor, private billing, and/or discharge.
- Review your state and federal regulations regarding proper notice for early discharge and proper notice for changing billing practices.
Contact your Medicare fiscal intermediary (e.g. Cahaba, Palmeto)
- Contact your Medicare fiscal intermediary to ask about bills you have already submitted under the orders of non-enrolled physicians. Will you be penalized retroactively? Can these bills be re-submitted with the authorization of a different doctor treating this patient? How should you go about getting new orders to continue services? Will a discharge and a new plan of care be required?
New Internal Policies
If these rules take hold, DME and home health care agencies must create new policies to check all physicians against the PECOS list before taking orders. CMS updates the list periodically, so the policy must also include a system for regularly updating your information.
Finally, let us tip our hats to the state and national associations who have been instrumental in notifying DME providers and home health agencies about this impending crisis. Please consider joining these organizations to avail yourself of the latest important information and to support the lobbying efforts necessary to protect your industry and your patients.
Home Health Care and Hospice: National Association for Home Care & Hospice
Durable Medical Equipment and Supplies: American Association for Homecare
this Pecos ordeal is an unfortunate and disturbing turn of events. It is so evident that the legislature does not have a clue when it comes enacting new legislation. I hope we can scream loud enough to get some help from our elected officials. We shall see…
The VGM Group has created an online PECOS database look-up system that will spare home health providers the trouble of constantly downloading those cumbersome PDF and Excel files from the CMS website. You simply type the physician’s name and click search.
Link: http://www.vgm.com/npi/