The Centers for Medicare & Medicaid Services (CMS) will delay, until April 5, 2010 implementation of phase 2 of two change requests that would have blocked funding for DME ordered from physicians and other healthcare professional not registered with CMS’s Provider Enrollment, Chain and Ownership System (PECOS).
The two change requests were:
CR 6417, Expansion of the Current Scope of Editing for Ordering/Referring Providers for Claims Processed by Medicare Carriers and Part B Medicare Administrative Contractors (MACs).
CR 6421, Expansion of the Current Scope of Editing for Ordering/Referring Providers for Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Supplier Claims Processed by Durable Medical Equipment Medicare Administrative Contractors (DME MACs).
The delay in implementing Phase 2 of these CRs will give physicians and non-physician practitioners who order DME from providers sufficient time to enroll in Medicare or take the action necessary to establish a current enrollment record in Medicare prior to Phase 2 implementation. Other non-physician practioners include nurse practitioners, physician assistants, social workers, psychologists, and physical therapists.
This comes as a relief to providers who were somehow left holding the bag in terms of trying to get physicians to register in the system, as their funding was at stake.
Starting Oct. 5 providers began receiving warnings that physicians not registered in PECOS by Jan. 4, 2010, but were still making DME orders or referrals would cause those Part B claims to be rejected. So it was left to HMEs to ensure physicians and other referring healthcare professionals are registered in PECOS in order for DME claims coming from those referral sources to be approved.
Industry Pushback
Last month, the American Association for Homecare (AAHomecare) joined with the American Medical Association and more than two dozen physician associations and other clinical and healthcare organizations to express grave concerns regarding CMS’s new Provider Enrollment, Chain and Ownership System (PECOS) enrollment policy.
AAHomecare drafted a letter to CMS Acting Administrator Charlene Frizzera that stated that the Jan. 4 deadline wouldl have a harmful affect on both providers and Medicare users of medically required durable medical equipment and services. Also, more than 50 physician and clinical organizations also sent a letter to Frizzera requesting that CMS take action to, among other steps, “ensure that otherwise acceptable claims are paid without delay or need for appeals” and “indefinitely suspend the plan to deny these claims and instead wait at least until all practicing Medicare physicians …can be revalidated and reenrolled or enrolled for the first time.”
AAHomecare followed up with another letter last week calling on CMS to indefinitely suspend implementation of Phase 2 of the change request for ordering/referring providers in DMEPOS claims to avoid unnecessary claims denials for legitimate services being provided to Medicare beneficiaries.
It also called for a dealy in implementation of the Phase 2 edits and claims rejections for a minimum of six months, given that provisions in House and Senate health reform legislations would require physicians who order/refer DMEPOS and home health services to be enrolled in Medicare with a July 1, 2010 implementation date.
It also called for CMS to develop and publish a corrective action plan that outlines how it intends to have physicians enroll with PECOS; and to release the list of physicians enrolled in the PECOS database to the DMEPOS community so that HMEs would have sufficient time to review, analyze, offer recommendations to CMS, and program their billing systems to accommodate the applicable information accordingly.