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Say What about the PECOS?









      
  
  

BALTIMORE — The question has been asked any number of times now in any number of ways: What exactly is the deal with PECOS compliance regarding DME claims?

The industry's latest attempt at getting a straight answer came from the American Association for Homecare's Walt Gorski, vice president of government affairs, on a CMS Open Door Forum July 7.

The background:

The deadline for physician and other prescriber enrollment in the Provider Enrollment, Chain and Ownership System was Jan. 3, 2011, but in order to be compliant with the new health reform law (Affordable Care Act, or ACA), CMS pushed that deadline up to July 6 in an interim final rule.

In a June 30 announcement, the agency said it would "for the time being not implement PECOS edits that would automatically reject claims based on orders, certifications, and referrals made by providers that have not yet had their applications approved by July 6, 2010."

But the announcement gave providers no assurance that, in future audits, they wouldn't have to give back their Medicare reimbursements based on claims submitted from July 6 to Jan. 3 if the ordering physician was not enrolled in PECOS.

So, AAHomecare's Gorski asked:

"Will [you] address that specific issue, that CMS and its contractors will not seek recoupment from claims that are receiving warnings during this period?"

Jim Bossenmeyer, CMS director of provider enrollment, responded this way:

"There are a number of reasons why Medicare may recoup money."

He added that DMEPOS suppliers should:

  • Make sure their claims contain the legal name of the physician or other eligible professional along with their Type 1 NPI;
  • Make sure the individual is licensed to practice in the state and has not been excluded from the program by the Office of Inspector General;
  • Keep documentation from orders for services referred to them; and
  • Work with their referral sources to make sure they know there is a requirement for PECOS enrollment.

Gorski tried again: "If we do that and a ZPIC or RAC audit occurs in 2012 and they look and see the effective date of the IFR and see that the referring physician was not enrolled in PECOS, you are telling the supplier community that the money will not be recouped?"

To which Bossenmeyer replied: "I have not said that. I understand what you would like me to say, but I cannot give you that answer today."