BALTIMORE — While the agency is so far standing firm on its Jan. 4 date — when claims will begin to reject if referring physicians are not registered in the Provider Enrollment, Chain and Ownership System, or PECOS — an Oct. 30 message seems to indicate that CMS is aware of the issues surrounding the controversial deadline.
The problem, according to HME providers, is that many physicians are not registered in the system, and others don't even know about it. That's something they only found out, they said, when they began receiving warnings that their claims would reject come January because the names and NPI numbers of the ordering physicians or non-physician practitioners were not on the PECOS list.
Another problem brought up by HME providers on a recent Open Door Forum call: They don't have access to any information to verify whether physicians are listed in the PECOS. (See Providers Add PECOS to the Worry Pile, Oct. 23.)
According to the listserv notice, CMS will address that issue by making available a national file of Medicare physicians and non-physician practitioners who are eligible to order/refer.
In addition, CMS said, because many DMEPOS providers are receiving warnings with their claims, the agency is taking the following actions:
-
CMS will systematically add the NPIs to the PECOS enrollment records of all physicians and non-physician practitioners whose PECOS records do not contain their NPIs, resulting in the addition of many more physicians and non-physician practitioners to the PECOS List.
-
CMS will make publicly available on the Internet a national file of Medicare physicians and non-physician practitioners who are eligible to order/refer. The file will contain the NPI and the legal name (from the Medicare PECOS enrollment record). This will allow DMEPOS suppliers to determine if the ordering/referring provider has a current Medicare enrollment record and is eligible to order or refer.
-
CMS will issue instructions that will assist Medicare contractors in enrolling licensed residents, Department of Veterans Affairs physicians and Public Health Service physicians. These physicians continue to order DMEPOS but have not enrolled in Medicare because they are not eligible for payments from Medicare.
-
An MLN Matters article (MM6421) about CR 6421 is available on the CMS Web site. To supplement that article, CMS will be preparing a Special Edition Medicare Learning Network (MLN) Matters article about CR 6421.
-
CMS' Medicare contractors have also initiated a revalidation effort (via CR 6574, Transmittal 557) which is designed to update the Medicare enrollment record for 2,500 physicians and non-physician practitioners (50 practitioners per state). "We expect that this revalidation effort will be complete or nearing completion by [Jan. 4]," the notice said.
The CMS notice also offered these "points to remember":
-
As of Jan. 4, only accept and fill orders from eligible Medicare providers.
-
If you submit electronic claims, ensure that the ordering/referring provider name is reported in all uppercase letters.
-
Do not report a nickname in the ordering/referring provider name. For example, a reported first name of "BOB" will result in a non-match to the first name of "ROBERT" (editing includes the comparison of the first initial of the first name), causing the claim to fail the two new edits.
-
Do not use commas, periods or apostrophes within the ordering/referring provider's name. For example, "O'CONNELL" should be reported as "OCONNELL."
-
Ensure that names are reported correctly. For example, do not include credentials in a name field in the name segment for the ordering/referring provider (e.g., do not report a first name as "DR JOHN").
-
Use of the Advance Beneficiary Notice of Noncoverage (ABN) is not appropriate on a rejected claim. An ABN is appropriate only when a provider/supplier expects Medicare to deny coverage for an item or service under the Limitation on Liability provisions of Section 1879 of the Social Security Act.
-
Even though a DMEPOS claim may identify an ordering/referring provider who has a current enrollment record (i.e., in PECOS with the NPI in the record), the date of service could precede the date the ordering/referring provider's information was effective in PECOS. Such a claim would pass the two new edits — Medicare is not comparing the date of service on the claim to the date the ordering/referring provider was effective in PECOS. The claim would not be rejected.