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Update - Expansion of Editing for Ordering/Referring |
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Update: Expansion of Editing for Ordering/Referring Physicians and Non Physician Practitioners on DMEPOS Claims
The Centers for Medicare and Medicare Services (CMS) Reviews PECOS Enrollment Process - Important Dates
The Centers for Medicare & Medicaid Services issued an interim final regulation on May 5, 2010 implementing provisions of the Affordable Care Act (ACA) that permit only a Medicare enrolled physician or eligible professional to certify or order home health services, durable medical equipment, prosthetics, orthotics and supplies (DMEPOS), and certain items and services under Medicare Part B. The new law applies to orders, referrals and certifications made on or after July 1, 2010. The comment period for the regulation closed on July 6, 2010. The comments will be reviewed and considered before a final regulation is issued. This has prompted numerous questions from the DMEPOS supplier community regarding when claims will start rejecting if the ordering/referring physician or non physician practitioner does not have a current enrollment record in PECOS. While the regulation took effect on July 1, 2010, CMS will, for the time being, not implement changes that would automatically reject claims based on orders, certifications, and referrals made by physicians and non physician practitioners that have not yet had their applications approved. Medicare Learning Network Matters Article 6421 indicates these edits will not be implemented until January 3, 2011. Medicare Ordering and Referring Report DMEPOS suppliers should continue to utilize the Ordering Referring Report to determine if the ordering referring physician or non physician practitioner is enrolled in PECOS, this report can be downloaded from the CMS Web site at: http://www.cms.gov/MedicareProviderSupEnroll/06_MedicareOrderingandReferring.asp#TopOfPage and contains the National Provider Identifier (NPI) and the legal name (last name, first name) of all physicians and non-physician practitioners who are of a type/specialty that is legally eligible to order and refer in the Medicare program and who have current enrollment records in Medicare (i.e., they have enrollment records in PECOS). A new file will be made available periodically and will replace the posted file; at any given time, only one file (the most recent) will be available. The CMS has also made available a list of pending initial applications currently in process in the PECOS system. Suppliers should not utilize this listing to determine if an ordering/referring physician or non physician practitioner has a current enrollment in PECOS and is eligible to order or refer but instead should simply use this report to verify that an ordering/referring physician or non physician practitioner is in the process of enrolling in PECOS. This report can also be found on the CMS Web site at: http://www.cms.gov/MedicareProviderSupEnroll/06_MedicareOrderingandReferring.asp#TopOfPage. Medicare Enrollment Guidance for Physicians that Infrequently Receive Reimbursement from the Medicare Program DMEPOS suppliers have also expressed concerns regarding orders they receive from physicians that infrequently receive reimbursement from the Medicare program, (i.e., dentists, physicians in a fellowship program). Are these providers eligible to order DMEPOS items for their patients? If so, do these providers need to enroll in the Medicare program (i.e., PECOS) for the sole purpose of ordering/referring items or services for Medicare patients? Traditionally, most physicians enroll in the Medicare program to furnish covered services to Medicare beneficiaries. However, with the implementation of Section 6405 of the ACA, some physicians need to enroll in the Medicare program for the sole purpose of certifying or ordering services for Medicare beneficiaries. The physicians do not send claims to a Medicare contractor for the services they furnish. In the process of implementing the provisions contained in the ACA, the CMS has become aware of several unique issues for certain types of physicians or practitioners. Specifically, the CMS has modified the process of enrollment to accommodate the special circumstances of the following individual physicians and practitioners:
Physicians employed by the Department of Veterans AffairsPhysicians employed by the Public Health ServicePhysicians employed by the Department of Defense Tricare programPhysicians employed by Federally Qualified Health Centers (FQHCs), Rural Health Clinics (RHCs) or Critical Access Hospitals (CAHs)Physicians in a FellowshipDentists, including oral surgeons
If DMEPOS suppliers receive questions from the aforementioned providers concerning enrollment in the Medicare program they can refer them to the Medicare Enrollment Guidance for Physicians that Infrequently Receive Reimbursement from the Medicare Program Fact Sheet for additional information. This fact sheet can be located on the CMS Web site at: http://www.cms.gov/MedicareProviderSupEnroll/Downloads/SpecialEnrollment
FactsheetInfrequentPhysicianReimbursement.pdf
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