As if physicians didn’t have enough to worry about with the perennial cliffhanger of Medicare pay cuts — this year’s 21% reduction is only on hold — many of them were at risk of not being paid at all starting on Jan. 1.
That’s why the Centers for Medicare & Medicaid Services did the right thing by postponing a deadline for physicians to make sure they are signed up properly with Medicare’s newest enrollment system. Doctors who order Medicare services or refer patients for such services now have until April 5 to determine whether they are up to date in the program’s Provider, Enrollment, Chain and Ownership System, known as PECOS. CMS had warned that it would stop paying claims at the beginning of the year for those who had not complied with the new enrollment policy.
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It’s not enough that practices have their own records in order. If a doctor lists a referring physician on a claim for a particular patient and that referring physician is not in PECOS, the billing doctor will not get paid.
If a physician has never heard of PECOS, there’s a good chance that he or she will need to contact the appropriate Medicare contractor or visit the PECOS Web site to re-enroll. The American Medical Association and dozens of other physician organizations who argued for the delay estimated that as many as 200,000 doctors fit into that category — about 30% of those to whom the directive applies. Many of these physicians enrolled in Medicare before 2003, when CMS started using the new system.
CMS says the re-enrollment process is simple, but the penalty for not updating the records with Medicare can be severe.
Starting in October 2009, Medicare contractors began including informational edits on claims listing physicians who were not properly enrolled in PECOS, letting the billing physicians know that they had until the end of 2009 to fix the issue or risk seeing their Medicare cash flow dry up.
But those who did not see or did not understand the informational notes on their claims were left in the dark about what to do. And physicians hardly can be blamed for overlooking Medicare’s own housekeeping issues with so much at stake in the national debate over health system reform and the threatened draconian cut to physician pay.
Quick action by the AMA and other members of organized medicine prevented a potential New Year’s disaster for many billing Medicare for services or listing referring physicians on their claims. But while an additional three months might seem like plenty of time for one doctor to file a paper Medicare application or use Internet-based PECOS enrollment, that might be a tight timeline for a larger practice that needs to sign up multiple doctors. The AMA already has asked CMS for additional time to comply and will continue to monitor the situation closely.
With a few exceptions, doctors who are not signed up with PECOS will need to re-enroll with Medicare. That includes pediatricians, dentists and others who may see few Medicare beneficiaries. Those who see or refer patients through the Dept. of Veterans Affairs, the Public Health Service or Tricare also will need to comply.
CMS is recommending that all physicians ensure that their enrollments are up to date and compliant by contacting their Medicare contractors or viewing their records online. A current record is one that is in the PECOS database with all the correct information, including National Provider Identifier, or NPI.
Physicians also can obtain more Medicare enrollment information on the AMA’s regulatory advocacy Web site (www.ama-assn.org/go/regrelief).
With some advance planning — and if Medicare contractors and CMS meet their own responsibilities — doctors can ensure that the government keeps paying them, on time, for all the work they do for their patients.