Ordering/Referring PECOS Edits Won’t Be Instituted Until July

Here comes a late holiday gift for Part B practices. Thanks to a new transmittal on the topic, CMS has announced that MACs won’t institute ordering/referring PECOS edits until July.

Currently, if you submit claims for services or items ordered/referred and the ordering or referring physician’s information is not in the MAC’s claims system or in PECOS, your practice will get an informational message letting you know that the practitioner’s information is missing from the system. It was previously announced that MACs would start denying these claims on Jan. 3, but CMS announced on Dec. 16 that claim denials won’t begin until July 5.

In Part B, MACs will take two steps before denying your claims. First, the carrier will check whether the ordering/referring physician is in PECOS. If not, the MAC will try to find the provider in the Claims Processing System Master Provider File. If the physician is in neither system, the claim will be rejected starting this July.

Even though CMS won’t reject your claims this month, you should still take this time to ensure that you and your ordering/referring providers are in PECOS as soon as possible, just in case the MAC edits become a reality, said National Government Services’ Andrea Freibauer during a Nov. 9 webinar on ordered and referred services.

To read the updated CMS transmittal, visit http://www.cms.gov/transmittals/downloads/R825OTN.pdf.

Hospices benefited from a separate holiday gift that CMS delivered just before Christmas – a delay of the enforcement date for the new face to face encounter requirement.

For weeks, hospices, home care providers, and their representatives had been giving CMS the full court press about the burdensome new physician visit requirement. In a Dec. 15 letter to CMS Administrator Donald Berwick, more than 25 senior and long-term care organizations joined the National...

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HHA Referral: More Documentation Requirements Add to Physician Burden

Agencies will have little control over new physician-related payment condition. Home health agencies are hoping for some big changes to one troublesome provision in the 2011 proposed payment rule – the face-to-face physician encounter requirement.

The mandate for the face-to-face encounter was in the Patient Protection and Affordable Care Act health care reform law enacted earlier this year. But the CMS version of the requirement is even stricter than the law requires.

Example: The proposed rule also requires that the encounter be for the primary reason home care services are required and that physicians furnish “unprecedented” physician documentation about the encounter and why the patient meets homebound criteria. “We believe that CMS has gone beyond statutory intent” in those two provisions, says the National Association for Home Care & Hospice.

The proposed face-to-face encounter requirement is riddled with problems for HHAs, industry experts say. To begin with, agencies have little influence over whether their patients make it to the doctor for a visit.

“It is absolutely ridiculous to place a requirement on home health providers for which they have absolutely no control,” protests consultant Pam Warmack with Clinic Connections in Ruston, La. “How in the world is the staff of the home health provider supposed to ensure that the patient visits the physician and that the physician documents appropriately in his/her office records?” Warmack asks.

“We can make appointments for patients, but we can’t ensure they keep them, that their transportation is reliable, that they feel well enough to make the trip, etc.,” Warmack continues. “There are so, so many reasons that patients fail to see the physician despite the best efforts of the home care staff to make it happen.”

The requirement will be “a particular burden on home health patients who are homebound and have difficulty leaving home,” notes...

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