Despite Delay, PECOS Remains 'Mission Critical'

COLUMBIA, S.C. — Even though CMS has delayed the PECOS physician registration requirement until April 5, 2010, industry consultant Andrea Stark is counseling HME companies not to slow down on educating referral sources about the new rule.

"Don't change anything that you're doing," said Stark, founder of MiraVista LLC. "Proceed as if this is Mission Critical, because rejections are ultimately inevitable if you do nothing."

During a Nov. 19 teleconference on the PECOS sponsored by the American Association for Homecare, Stark told listeners to "proceed as if this is going to happen and rejections are going to take place." A few days later on Nov. 23, CMS sent notice of the three-month delay, but Stark said that's still her advice.

"There is not enough driving force on physicians to get it done without an external influence," she said. And come April 5, DMEPOS claims will reject unless the ordering physician is registered in the system.

The phase-in grace period for the new policy would have ended on Jan. 4, but CMS said extending the implementation date would give physicians and others eligible to order/refer sufficient time to enroll, or re-enroll, in Medicare. According to Stark, thousands of physicians enrolled in Medicare before PECOS became available.

She speculated that a number of those physicians haven't registered in the Internet-based system simply because they are already registered with Medicare. "They think they're fine," Stark said. "Most are enrolled with Medicare and on file with Part B and they've got NPI numbers," so many doctors may not understand there's a reason to register in the system, she said.

"CMS has tried to put some skin in the game for doctors," Stark noted. "They are contacting the top 50 doctors in every state if they are actively billing and they are not in PECOS. There is also a mass mailing to every doctor in every state reminding them of their onus to keep their information updated."

If that letter, a special mailer addressed to the individual physician, gets returned "for whatever reason," Stark said, "the contractors have been instructed to revoke billing privileges for that physician."

Even so, she said, "You have to keep that in perspective. The [special mailer] helps to deliver the message that CMS is serious about this enrollment initiative … and it will help providers to deliver the message." But the number of doctors who are actually going to have returned correspondence will be limited, Stark pointed out, and the number of doctors who are currently not in the system is high (the AMA estimates more than 200,000). So providers must continue to make sure their physicians and other referrers get registered.

"It buys us some time," Stark said of the delay, "but it's not perfect. That's why providers cannot afford to be lackadaisical about it."

Stark added that for physicians completing enrollment applications online, 90 percent are usually processed within 45 days. If the application is on paper, it takes an average of 90 days for processing. That's another reason for HME providers not to let up on their efforts with physicians, she said.

"Depending on how the doctors are going to submit their applications will determine how many more we can get into the system [by April 5]. I don't know that the contractors have ever had a deluge of applications come in like this before," Stark said. "We could be looking at a 90-day best-case scenario assuming they are on top of things."

Providers are currently receiving warning edits on claims if the ordering physician is not enrolled in the PECOS. If a physician is still not registered as of the cutoff date, Stark said, those claims "will be unprocessable" and will reject. If the physician gets his or her enrollment updated in PECOS after April 5, then the doctor "will be valid as if there was never a problem, so any claims that were rejected can be resubmitted as clean claims."