BALTIMORE — HME providers aren't the only ones worried about physician registration in CMS' new Provider Enrollment, Chain and Ownership System (PECOS) database. On Monday, the American Medical Association and more than 50 other physician and related organizations requested that the agency delay its plan to deny claims if the referring/ordering physicians are not in the system.
According to CMS’ current schedule, any DMEPOS claims from non-enrolled physicians will reject come Jan. 4, 2010. Some HME providers have reported receiving warning messages for as many as 80 percent of their claims noting that those claims would not pass muster once the deadline kicks in.
The physician groups estimated that, based on data from an October OIG report, "as many as 200,000 or 30 percent of all Medicare physicians and other health care practitioners are not in PECOS and will need to re-enroll.
"The repercussions for this ill-advised policy are enormous," the groups said.
In their letter, addressed to CMS Acting Administrator Charlene Frizzera, the organizations said, "Implementing this policy as scheduled will cut off access to care for millions of Medicare beneficiaries, interrupt reimbursement for legitimately provided items and services, interrupt care coordination, and add unfunded administrative mandates on a significant portion of physicians and other health care practitioners who provide care to Medicare beneficiaries.
"The impact of this policy has not been adequately considered by the Centers for Medicare and Medicaid Services (CMS) or explained to contractors, physicians, other health care practitioners, and beneficiaries."
The groups asked CMS to take the following "immediate" steps to address the situation:
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Take action to ensure that otherwise acceptable claims are paid without delay or need for appeals;
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Indefinitely suspend the plan to deny these claims and instead wait at least until all practicing Medicare physicians, other health care practitioners, and residents can be revalidated and reenrolled or enrolled for the first time;
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Focus its efforts on ensuring a smooth and efficient revalidation process, which will require physicians and other health care practitioners to re-enroll in Medicare if they have not done so since 2003; and,
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Convene a high-level meeting with stakeholders to discuss concerns about ordering and referring physicians and other health care practitioners, and collaboratively develop a feasible and appropriate plan and timetable for addressing these concerns.
"We understand that CMS is under considerable pressure to reduce fraud and abuse in the Medicare program and support those goals. However, we do not believe the new policy to be consistent with statutory authority, nor is it an effective or appropriate approach to achieve its desired goal …" the letter continued. "Orders and referrals are fundamental components of quality health care delivery that should not be discouraged or hamstrung merely for administrative needs that do not justify the corresponding administrative and financial burden on physicians and other health care practitioners.
"We believe the new policy impedes patient access to care, bogs down the enrollment system further, and presents significant workflow challenges to physicians and other health care practitioners who will have little way to be sure whether another physician is in the PECOS database."
On Monday (Nov. 16), CMS sent out a notice that it had scheduled an Open Door Forum call for physicians and other health care practitioners on the PECOS for this afternoon (Nov. 17).
