Home Health and Durable Medical Equipment Prosthetics and Orthotics Suppliers

As a follow-up to the May News Update, providers are increasing their efforts to have their voices heard regarding the requirement for physicians to enroll in the Provider Enrollment, Chain, and Ownership System [PECOS] database.  The Provider Enrollment, Chain and Ownership System is the system that physicians and other practitioners are required to enroll in, in order that their patients can continue to receive HH and DMEPOS Medicare-reimbursed services.  Providers are being instructed to check on the enrollment or application status, as well as to validate that enrollment information is present.  If the ordering/referring physicians or other non-physician practitioners listed on HH and/or DMEPOS claims are not in PECOS, those claims will be rejected http://homecaremag.com/news/pecos-july-deadline-20100601/.

The time frame for meeting this enrollment requirement has been somewhat of a moving target, with the original date set as January of this year, which subsequently was moved back to April, then to January 2011.  However with the health care reform law passage in May, the Centers for Medicare and Medicaid Services [CMS] has moved up the compliance date and issued an interim final rule stipulating that physicians and other eligible professionals who order items and/or services for Medicare beneficiaries must have an approved enrollment in PECOS by July of this year.

This requirement is anticipated to negatively impact the delivery of home care and equipment and supply services to beneficiaries in need of care.  Many physicians, including licensed doctors of medicine, osteopathy and podiatric medicine, already have valid National Provider Identification [NPI], but up to 40% of ordering physicians have not met the newly-required PECOS enrollment. 

While the process for enrollment has become more efficient, it can still take from 2-3 months.  With the fast-approaching July deadline, valid concerns have been raised relative to continuity and continued access to Medicare for patients receiving home health care and durable medical equipment and supply services.

HH and DMEPOS providers cannot bill Medicare for services ordered by individuals not enrolled in PECOS and should the provider inadvertently do so, it could be considered fraudulent billing and would result in non-payment for billed services.

Providers must continue to verify physician/practitioner enrollment and are encouraged to send reminders to physicians/practitioners regarding the date for meeting this requirement.  In addition, it is recommended that providers send reminders to referral sources of the regulation and potential impact on services.  Medicare beneficiaries need to be notified that Medicare will not reimburse Medicare services until their physician/practitioner has enrolled in the PECOS system.

Should it become necessary to terminate services to patients, providers are cautioned to follow agency policies and state and federal laws regarding the termination of services process.  Beneficiaries will need to be provided with a Medicare Expedited Determination Notice and a Home Health Advance Beneficiary Notice [HHABN] prior to service termination.

Hospice

Hospice providers are also continuing to express concerns regarding the upcoming Face-to-Face Recertification requirement.  As noted in the May News update, this would be required prior to the hospice patient's 180th-day recertification and would take effect on the first day of January in 2011.  At this time, CMS does not appear to have an implementation plan for this regulation and one suggestion, made by providers and national associations, is that this requirement be phased in and that it begin with hospices that have a high number of long-stay patients.  Published implementation regulations are expected later this summer, with a comment period to follow.  It is important that providers advocate regarding this regulation’s impact on service delivery and costs.  In addition to the phase in suggestion, other recommendations include providing payment to hospice providers for the required face-to-face encounter/visit, by the practitioner under contract to the hospice and/or by the attending physician.

Among other proposed suggestions is that a telehealth encounter be considered a face to face encounter.  It is imperative that providers receive clear guidance from CMS relative to the elements that must be included in the face-to-face encounter, who can conduct the face-to-face encounter and how patient days will be calculated prior to the proposed January 2011 date.

Electronic Records

The Office of the National Coordinator for Health Information Technology (ONC) has released the final rule for temporary certification for programs and organizations to follow in order for the ONC to test and certify electronic health record (EHR) technology.  This certification process establishes a structured approach for products and services and includes tools for participation in the Medicare and Medicaid EHR incentive programs.  This certification program final rule builds upon the interim final rule, which established standards, implementation specifications and certification technology parameters.  One goal of the certification program is to establish that providers are technically capable to support and meet standards.  With these newly established certification program standards, it is anticipated that the incentive programs currently in place can be expanded to include the establishment of certified EHR technologies for home care and hospice providers.

The Certification Commission for Health Information Technology [CCHIT] has been certifying electronic health record technology since 2006.  The Commission lists system goals as widespread adoption of healthcare information technology, as well as fostering improvements in quality, safety, efficiency and access to information [ http://www.cchit.org/about].  Tools, resources and work group minutes are available by accessing the Commission’s website at http://www.cchit.org/.

Resources:

About the Certification Commission for Health Information Technology. Retrieved on June 28 2010 from http://www.cchit.org/about

PECOS Registration Scramble Resumes. Retrieved on June 28 2010 from http://homecaremag.com/news/pecos-july-deadline-20100601/