Death By Paper Cut

PECOS and claim documentation requirements stand to bleed HMEs’ time.

Do you ever get the feeling that CMS simply has it in for the HME industry? The latest example is the Provider Enrollment, Chain and Ownership System (PECOS).

Beginning on Oct. 5, providers began getting warnings on claims from physicians that were not registered to the PECOS system. PECOS is an Internet registry to which all physicians and most other care professionals, such as nurse practitioners, physician assistants, social workers, psychologists, and physical therapists, must register. The warnings said that those professionals referring DME claims to HME providers must be registered in PECOS by Jan. 4, 2010 in order for any DME claims coming from those referrals after the deadline to be approved.

Most providers were taken completely by surprise. According to an online poll of HMEBusiness. com readers, more than 91 percent of respondents said they hadn’t even heard of PECOS before Oct. 5.

Let’s review: CMS is telling providers that if they want to continue to get funded, they must ensure physicians register into a system that it hadn’t adequately publicized to either camp. That doesn’t make any sense. Why is the responsibility for physicians to register into PECOS sitting on the HME providers’ shoulders? Did HME providers become employees of CMS all of a sudden?

Yet somehow, providers must ensure their physicians register. That’s an especially scary prospect given that nearly 20 percent of readers responding to a later poll said that none of their physicians were registered in PECOS. Moreover, 44 percent of respondents said less than a quarter of their physicians were registered and 23 percent voted that between a quarter and a half of their physicians were registered. And the deadline is Jan. 4? With the holidays coming up, getting physicians registered will be a monumental task.

The one piece of leverage that providers have to convince physicians to register in PECOS is to simply tell them that they cannot provide DME to their patients if they are not enrolled in the registry. Hopefully, the thought of their patients going without the required DME will be enough incentive to get providers to register.

Another paperwork challenge providers are facing is the requirement to provide documentation of ongoing medical need for DME claims. Letters were sent to all DME MAC medical directors saying that Medicare needs them to tighten up claim documentation. As part of that tightening up, providers must show that within six months of a claim that a patient went to the doctor, and that the doctor wrote something in his notes about the patient’s continuing use and need for oxygen so that the claim can be approved.

Once again, CMS is putting providers in the position of having to tell physicians what to do. (Not exactly ideal from a referral partner, relationship- building point of view … )

Like PECOS, this has the potential for disaster for providers, and could be a particular problem for claims for patients with life-long conditions, such as mobility patients or oxygen patients. (Read our cover story “Oxygen Access,” on page 14 to learn more about other issues oxygen providers are experiencing.) I don’t think that anyone in the industry would deny that paperwork and process are expected elements of providing healthcare products and services. Documentation and procedures can help ensure quality of care. What isn’t expected is for CMS to use paperwork and process as a way to stymie providers’ ability to make a living.

Requiring providers to ensure physicians enroll in a CMS system when it isn’t their responsibility, or for providers to continually re-acquire physicians’ orders for lifelong medical conditions are clearly tactics to stymie providers’ ability to get funding. CMS can call it process and documentation, but to me, it looks like death by a thousand paper cuts.

This article originally appeared in the December 2009 issue of HME Business.

About the Author

David Kopf is the Publisher HME Business, DME Pharmacy and Mobility Management magazines. He was Executive Editor of HME Business and DME Pharmacy from 2008 to 2023. Follow him on LinkedIn at and on Twitter at @postacutenews.

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