Home Health & Hospice Week

You now have an extra six months to avert a cash flow crisis brought on by your referring physicians failing to enroll in PECOS.

Old: The Centers for Medicare & Medicaid Services had set the phase 2 PECOS physicianedits to begin in January 2011. The edits verify whether the ordering/referring physician listed on the home health agency claim has a valid National Provider Identifier number and is enrolled in the Internet-based Provider Enrollment, Chain and Ownership System. In phase

1, the edits merely send an informational message telling providers the requirement isn't met. In Phase

2, the edits will reject claims if the listed physician isn't enrolled in PECOS.

New: Now CMS has pushed back the phase 2 edit implementation date to July 5, 2011, according to Oct. 8 Transmittal No. 781 (CR 6856).

"The delay of phase 2 is a good thing," cheers billing consultant M. Aaron Little with BKD in Springfield, Mo. "It should help to reduce potential risk of delayed cash flow."

And it gives physicians extra time for their PECOS applications to process through the system, notes Pat Laff with Laff Associates in Hilton Head Island, S.C.

"Hopefully providers will use this extra time to monitor remittance advices to identify those physicians who aren't registered in PECOS," Little says. They should "initiate communication to the physician to encourage them to get registered as quickly as possible."

The six-month extension "will give the provider the chance to gently push those who are not PECOS-enrolled," agrees Lynn Olson with Corpus Christi, Texas-based billing company Astrid Medical Services.

The delay also will give the physicians more time to initiate and complete PECOS enrollment, Olson says.

Bottom line: If home care providers stay on task and identify their non-compliant referring physicians, they should be safe from PECOS-related cash flow issues other than losing a referral source, Olson predicts.

The extension might not help much with a significant problem home care providers are going to encounter with the PECOS edits, however, Laff expects. That's getting the hospitalist physician to enroll in PECOS. Often "the primary care doc is not giving the referral," Laff tells Eli.

Wait A Bit Longer For Phase 1 Info CMS is also pushing back the implementation date for phase 1 edits, reports the National Association for Home Care & Hospice. However, the date has moved just a month, from Oct. 4 to Nov. 8, NAHC says. CMS hadn't officially announced the delay at press time.

HHAs should be using the informational edits to urge their physicians to enroll in PECOS, industry experts urge (see Eli's HCW, Vol. XIX, No. 35, p. 274). So far billers contacted by Eli haven't seen any informational edit results, they confirm.

Note: The transmittal is at www.cms.gov/transmittals/downloads/R781OTN.pdf.