BALTIMORE - Coming off last week's confusing Open Door Forum, HME News called Jim Bossenmeyer, director for the division of provider and supplier enrollment at CMS, for clarification on the Provider Enrollment, Chain and Ownership System (PECOS). For better or worse, here's what he had to say this morning:
When's the deadline: July or January?
CMS made some decisions prior to the implementation of the Patient Protection and Affordable Care Act. At the time, we delayed the implementation of CR 6421 until January 2011. Subsequent to that decision, the act was enacted on March 23. What the statute says is it shall apply to written orders and certifications made on or after July 1, 2010. We have to look at that statute and the regulations we published in the interim final rule on May 5 as far as an implementation date. The compliance date is July 6, consistent with the statute.
When will CMS begin rejecting claims?
CMS is in the process of implementing edits associated with the ordering and referring providers for DMEPOS claims that don't comply with the statute requirements. In addition, CMS may conduct administrative review of claims submitted by DMEPOS providers that are not in compliance on or after July 6.
When will CMS implement the edits?
We are currently in the comment period and we encourage people that have comments to submit those comments as soon as possible. We are going to carefully review those comments and we'll provide additional information regarding when we will begin the editing process at a later date. But clearly we are going to be looking at the claims that are coming in where they are not compliant.
July is not far away; is the system running smoothly enough to handle a significant uptick in PECOS applications?
We've been educating physicians since last October and the system is operating at full capacity. Our contractors are processing applications as they receive them. One of the advantages of using Internet-based PECOS is it reduces the common errors in the application process. The applications are processed much faster. If the contractor requires documentation from a physician's office, whether it's submitted by paper or electronically, the physician or designee needs to respond to the request ASAP. That will facilitate the enroll process.
For physicians who are not compliant by July, is there a penalty?
Does CMS know how many physicians are still non-complaint?
I don't have that number for you.