Home Health & Hospice Week

Your cash flow could be in serious jeopardy in the new year unless you take some vital steps starting this month.

Why: If physicians who referred your patients haven't enrolled in Medicare's PECOS system or if you haven't included the correct physician information on your claims, your claims still will pay. But starting Oct. 4, home health agencies will receive a remark code that informs them that the physician information isn't correct. Starting Jan. 3, the edits will reject such claims instead of informing HHAs that they have a physician PECOS error. "It could be a significant problem come January for any claims that reject for this issue," warns consultant M. Aaron Little with BKD in Springfield, Mo. That's "because any delay in cashin today's environment is troublesome. Especially one such as this that requires coordination with the physician or physician personnel to remedy."

There was significant confusion over the PECOS edits this summer. The Centers for Medicare & Medicaid Services issued a transmittal indicating that informational edits would start this month and edits rejecting claims would start in January. But then a CMS representative told providers in Open Door Forum calls that the PECOS rules took effect in July and providers had to adhere to them. CMS retained the right to edit retroactively for the PECOS information and recoup funds, the CMS rep said.

Providers have protested having their Medicare payments held hostage by a rule that applies to physicians, when those docs' own reimbursement is completely unaffected by the new requirement.

Now that the informational edits are beginning, HHAs have something concrete to deal with on the matter. (Informational edits for durable medical equipment suppliers began last January.)

But the remark code that indicates a physician PECOS enrollment problem is easy to overlook, Little cautions. "It's likely that billing personnel may not actually notice the informational edits unless they are actively looking for them," he tells Eli.

How you'll know: Claims missing a PECOS- enrolled referring/ordering physician will pay, but will include remittance advice remark code N272: "Missing/incomplete/invalid other payer attending provider identifier."

"Unless agencies utilize software that helps direct the users' attention to the remark codes and that actually defines the codes, it will be very easy to overlook the fact that the attending physician

billed on the claim is not registered in PECOS," Little believes.

The PECOS physician edit "on paper ... sounds like a good and reasonable idea," Little notes.

"But it could be a real challenge to implement." The bottom line: "Personnel responsible for posting payment and/or doing other work with the remittance advices should closely monitor any claims paid with the N272 remittance advice remark code," Little advises. Then they should take action on those claims (see related story, this page). HHAs that run into cash flow problems due to the issue in January may not get a sympathetic ear from the feds. "Providers have had plenty of warning" about the edits, especially with the three-month information period, points out Lynn Olson with billing company Astrid Medical Services in Corpus Christi, Texas.