ATLANTA — Doctors' offices are complaining about the burdens of registering in CMS' Provider Enrollment, Chain and Ownership System (PECOS), with many reporting log-in problems, long telephone waits for help and numerous Web pages to be filled out. But the clock is ticking toward the Jan. 4, 2010, deadline when Medicare will stop paying claims from HME providers unless the ordering physician is registered in the system.
There has been no word on a deadline delay, although an estimated 200,000 Medicare physicians and other health care practitioners still need to enroll as the remaining time dwindles.
On Monday (Nov. 16), the American Medical Association and 56 other physician and clinical associations sent a strongly worded letter to Charlene Frizzera, acting administrator for CMS, about the situation. The letter states: "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."
The letter recommends "indefinitely" suspending implementation of the plan to reject claims and "waiting at least until all practicing Medicare physicians … can be revalidated and reenrolled or enrolled for the first time." The physicians also asked that CMS take action to "ensure that otherwise acceptable claims are paid without delay or need for appeals." (See Docs Ask for PECOS Delay, Nov. 17.)
No new information on the PECOS was given during a Tuesday afternoon Open Door call for physicians. CMS reiterated its intent, previously announced on Oct. 30, to populate existing PECOS enrollment records with missing NPI numbers for physicians, and to make available a national file of practitioners who are eligible to order/refer.
But the problem with that, according to stakeholders, is that the file and the updated database may not be available until mid-December, giving providers only a couple of weeks to use the tools before the claim rejection date.
"It's a good thing they are going to provide the listing [file], but it will be a day late and a dollar short because there will only be a few weeks until the payments stop," said John Shirvinsky, executive director of the Pennsylvania Association of Medical Suppliers. "What has to govern CMS at this point is to make sure they do this right, not do it fast. They may have to extend the deadline. I think they are trying to get a handle on who's in the system [by populating the NPI numbers]."
Providers began to receive CEDI warnings on claims processed on or after Oct. 5 based on an expanded editing process that cross-matches a claim's ordering physician/practitioner against PECOS enrollment. Unmatched claims will be rejected beginning in January.
The AMA letter states the new policy was "quietly announced," and providers have confirmed that many of their referral sources were unaware of the PECOS.
Shirvinsky suggested that the strategy among HME companies is likely to change from trying to educate doctors to reaching out to patients to let them know their options. It would be reasonable for a patient to expect at least a 30-day notification of Medicare payments ending, he said, which would require providers to start making those notifications in early December. "The options for providers have been taken away," said Shirvinsky.
Some members of PAMS have seen a recent decrease in the percentage of claims that receive CEDI warnings, but others have seen an increase; reports range from warnings on 10 percent to 40 percent to 60 percent. "The system is nowhere near ready to roll out," Shirvinsky said. He speculated that some physician offices are hesitant to amend or update the information they have supplied to Medicare on the fear that they will make a mistake that could put their own Medicare status in jeopardy.
"It's an ongoing crisis, and there is a lot of confusion," he said. "We have received calls from physicians who have tried to register. The process is all bollixed up. The concern is that if there is a comma in the wrong place, something not written in all caps, and all of a sudden you lose your ability to participate in Medicare."
The American Association for Homecare also has drafted a letter to Frizzera stating that the timing of the new policy and resulting denial of clams will have a harmful effect on both providers and beneficiaries. "We don't see any way of getting around this without a lengthy delay because the education level of physicians is low, and it's cumbersome to apply because physicians don't have any skin in the game," said the association's Walt Gorski, vice president, government relations.
In a meeting with CMS officials about the problems earlier this month, Gorski said, "CMS was not ready or willing to commit to a delay … Clearly, CMS is finding out the problem [with physician registration] is probably worse than they anticipated."
Physicians Frustrated, Too
Meanwhile, physician office horror stories of trying to interact with the PECOS are common.
"I just had a call from a woman in a physician's office who said she had been on the phone for two-and-a-half hours waiting to ask about her doctor's information in PECOS," said Joan Cross, executive director of the Florida Association of Medical Equipment Services. "When she finally got someone to talk to, she said she was told the physician himself would have to call in. 'Do they want him to sit on the phone for two-and-a-half hours?' the woman asked me."
Kevin Fly Hill, president of CPS Medical, Tyler, Texas, recounted contacting the employee responsible for certifications and paperwork at a large education-based health care system that supports more than 100 doctors.
"As I queried her about PECOS and the potential of problems related to physicians not being properly registered, she assured me that she had all of her information and paperwork up to date," Hill said. But after Hill faxed her a copy of the warnings he had received, she called back. It turns out her doctors were not properly registered and she would "have her hands full for the next week" getting everything done.
Hill said she added: "When I reread my notices from Medicare/CMS they had not stressed the importance or really the need to do this process, but there it was. I don't know whether to hug you or hit you, but I need to get busy and make sure these get processed before the end of the year!"
Hill said it may take as long as four to six weeks "for processing the paperwork that you must download, print, fill out, have signed by the doctor and mail to the carrier for Medicare. Can you imagine the backlog of work this will create when tens of thousands of physicians' paperwork shows up at the various Medicare carriers who will have to physically input all of this information into their systems? That was three weeks ago."
Chris Rice, director of marketing for Diamond Respiratory Care, Riverside, Calif., has created a Web site — www.getpecos.com — to help educate physicians and others about PECOS.
"After speaking with physicians, we found that there was no simple way for them to take action," said Rice. "Finding the pertinent information on CMS' site is difficult, and asking our staff to explain how to find it was nearly impossible. We needed to put all the CMS information in an easy-to-read format in one place with an easy Web name to remember."
The majority of the site's content is taken from CMS bulletins, but it is presented simply and using separate menu items. There are also PDF files of CMS application instructions and screen shots of the PECOS. "It's disheartening to learn that the actual PECOS system is difficult for physicians to navigate," Rice said. "It has over 44 screens."
Leslie Zinn, office manager of Texas DME, Cleburne, Texas, pointed out another problem. "In Texas, if a client has Medicare, private insurance and Medicaid, and receives a product that is not a covered Medicare benefit, it still must be billed to Medicare first, then private insurance and then Medicaid. If a physician is not entered in the PECOS system, the claim cannot be processed by Medicare, and therefore cannot be sent to private insurance, and in turn, cannot be sent to Texas Medicaid."
The AMA letter estimates that as many as 200,000 Medicare physicians and other health care practitioners are not in PECOS and will need to re-enroll. According to the letter, one Medicare contractor "reported 300,000 warning edits were issued the first day of the [Phase 1] policy." The letter also notes that only electronic claims are receiving warnings; paper claims will just stop being paid in January with no effective warning.
"The downstream providers and suppliers ... are at risk of nonpayment, even though they are not responsible for the enrollment/reenrollment [process]," the letter states.
"It is impractical to require potentially hundreds of thousands of physicians and other health care practitioners to reenroll ... by the end of 2009," according to the physician groups. "Medicare enrollment is widely regarded by the physician community as extremely burdensome. We do not believe the new policy to be consistent with [CMS] statutory authority, nor is it an effective or appropriate approach to achieve [the] desired goal."
According to a CMS representative who spoke during the Open Door, there will be more information on the PECOS coming in a new MLN Matters article, which she said should be posted on the CMS Web site within two weeks.
