The deadline for physicians and non-physician practitioners to register in the Internet-based provider enrollment system, Provider Enrollment Chain and Ownership System (PECOS), has been changed from January to April 5. Starting April 5, claims will only be paid by Medicare if the referring physician is enrolled in PECOS. The additional 4 months will allow for more physicians who may not have been aware of the requirement, to enroll either by paper application or Internet-based PECOS.
In January 2009, the Centers for Medicare & Medicaid Services (CMS) made PECOS available to physicians and non-physician practitioners in the hopes of simplifying the enrollment process. In April 2009, Internet-based PECOS was made available to all other provider and supplier organizations except for Durable Medical Equipment Orthotic and Prosthetic Supplies (DMEPOS) suppliers. Most O&P practitioners were unaware of the changes implemented by CMS despite the fact that information regarding PECOS was posted on CMS’ Web site since January 2009, according to Jim Bossenmeyer, director for the division of provider and supplier enrollment at CMS.
“For O&P people, we probably did not know about PECOS or pay attention when our organizations mentioned it to us because it did not effect us directly,” Jim Rogers, CPO, FAAOP, immediate past president, American Academy of Orthotists and Prosthetists (the Academy) told O&P Business News.
In October 2009, CMS began sending informational messages to DMEPOS suppliers whose referring physician was not enrolled in PECOS. The messages stated that the claim would be paid, but starting in January, the claim would be rejected because the referring physician was not enrolled in PECOS.
“The claim submitted by the DMEPOS supplier would be rejected not denied,” Bossenmeyer explained. “In that case, once the physician has updated their information, the claim can be resubmitted.”
Although these messages were only meant to warn DMEPOS suppliers, confusion and panic quickly spread through the O&P industry.
Many practitioners were unaware of PECOS and were ill-prepared for the administrative work that was ahead. Practitioners were also afraid that if a referring physician did not enroll in PECOS by the CMS deadline, the claim would not be paid and the practitioner would lose patients and business.
“It just really was unfair and implementation had the potential to create some real economic hardships, at a time when we don’t need anymore economic hardships,” Rogers said. “And it was putting the administrative burden of notifying the physicians on the O&P practitioner and that has a tendency to further erode our relationship with our physician referral sources.”
The growing confusion and frustration regarding Internet-based PECOS was a result of a communication breakdown between CMS, the O&P industry and referring physicians. To combat this, O&P practitioners were in need of a way to research a referring physician’s PECOS enrollment status. Because most physicians were unaware of the changes made by CMS, most were not enrolled, causing a large number of informational messages sent to DMEPOS suppliers.
CMS will, according to Peter Ashkenaz, deputy director of media relations at CMS, automatically add the National Provider Identifier (NPI) to enrollment records for any physician or non-physician practitioner who has enrolled or updated their enrollment records in the past 6 years, but was not contained in the PECOS enrollment record. This change is scheduled to occur within ten days of press time and is believed to reduce the number of informational messages.
According to Bossenmeyer, CMS is also in the process of making available ba downloadable file that will allow O&P suppliers to check whether a physician has an enrollment record in the PECOS system. The downloadable file will contain the name and NPI of physicians and non-physician practitioners enrolled in PECOS. As of press time, the Internet database downloadable file has not been created.
For CMS, the creation of such a database has been complicated by physicians not updating their information in several years. The problem, according to Rogers, is that the database should have already been created and the administrative burden has been put squarely on the O&P field’s shoulders.
“I think the fundamental issue is that CMS can not ask our industry to do their administrative due diligence and they can not ask one industry to police another industry,” Rogers said. “Especially for a government agency possessing the resources of CMS compared to our industry. CMS should have added the NPI data to the PECOS enrollment system before rejecting claims and threatening denial of these claims.”
On Nov. 13, 2009, a letter expressing concern and remedies for CMS’ Internet-based enrollment policy was sent and signed by 25 medical organizations including the Academy and the American Medical Association (AMA). The letter was sent to Charlene Frizzera, acting administrator of CMS.
The letter stated that implementing the 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 healthy care practitioners who provide care to Medicare beneficiaries.”
It is unclear whether the letter persuaded CMS to push back the requirement date, however the new date has given practitioners desperately needed time to notify their referring physicians about PECOS.
b“It really hinges upon whether internet access is going to be available for O&P providers and whether the NPI data is going to be imported into PECOS,” Rogers said. “If the Internet access is available, the NPI’s are imported and the awareness in the physician community has increased, then it may not be a big burden on O&P. If April comes around and the Internet data is still not available, then the burden is essentially the same on O&P, just delayed.”
Bossenmeyer noted the feedback he has received has been positive and the public appreciates the simplicity of Internet-based PECOS.
“We will continue to enhance PECOS to add more functionality and further reduce the administrative burden on the public” Bossenmeyer said. — Anthony Calabro
As with the rest of O&P, if PECOS was implemented as scheduled, it would have caused chaos for pedorthics. PFA believes that CMS failed in its physician outreach attempt and then attempted to shift their responsibility for communicating information on PECOS to the OP&P community. To PFA, this is another example where CMS has attempted to implement a requirement before they have all of the logistical arrangements in place, have tested them and have properly notified the appropriate parties.
— Brian Lagana
Executive director, Pedorthic Footwear Association
For more information:
- Centers for Medicare & Medicaid Services. Internet-based PECOS. Available at: www.cms.hhs.gov/MedicareProviderSupEnroll/04_InternetbasedPECOS.asp. Accessed Dec. 9, 2009