CMS is sending Medicare participating physicians a not-so-gentle reminder: If you haven't enrolled in the program's Provider Enrollment, Chain and Ownership System, or PECOS, you have until July 6 to do so. If you want to continue to order or refer items or services for Medicare beneficiaries, that is.
According to an interim final rule(edocket.access.gpo.gov) published May 5 in the Federal Register, July 6 is also the deadline for physicians to begin maintaining and, upon request, provide access to documentation on referrals to "programs at high risk of waste and abuse," such as durable medical equipment, prosthetics, orthotics and supply programs, as well as home health services.
CMS previously had established a deadline of Jan. 3, 2011, for all ordering and referring physicians to be enrolled in PECOS. But when President Obama signed the Patient Protection and Affordable Care Act into law on March 23, CMS was forced to shift its enrollment deadline to meet the requirements of the reform legislation.
Physicians who enrolled in Medicare before 2003, the year PECOS was implemented, and who have not updated their enrollment information since -- a process also known as "revalidating" -- are considered to not have a current Medicare enrollment record and are at risk of being dropped by their Medicare carriers.
If you have not updated your information, complete a CMS-855I form(www.cms.gov), sign and date the form (blue ink is recommended), and mail the application -- along with any supporting documentation -- to your Medicare carrier or Part A/Part B Medicare administrative contractor. If you reassign benefits to a clinic or group practice other than your own, you'll also need to complete and submit a CMS-855R form(www.cms.gov).
According to AAFP coding specialist Cynthia Hughes, C.P.C., it pays to be extra careful when completing your application to avoid having to resubmit missing or unclear information. "If you don't cross a 't' or dot an 'i,' the form is likely to be sent back to you," she says.
But that's not the end of the process, Hughes adds. To ensure that your application is received and processed in a timely fashion, "Keep following up," she recommends. "Make sure it's getting done; make sure it doesn't sit on somebody's desk for any reason."
Also know that the time it takes to process your request can vary from contractor to contractor, says Hughes. "Some are better than others," she warns. So physicians shouldn't put off starting the process.
To learn more about the physician revalidation process, consult the "Medicare Program Integrity Manual."(www.cms.gov)