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Q&As about PECOS and Physicians

Homecare Insider, August 9, 2010

Homecare providers have been scurrying to comply with the requirement that physicians signing plans of care must have a valid record in the Provider Enrollment, Chain, and Ownership System (PECOS) by July 6, 2010.  Here are some quick questions about physicians and this requirement.

Are physicians who work at Veterans Administration hospitals subject to PECOS enrollment?  I know of many who are not enrolled in Medicare. 
Physicians employed by Department of Veterans Affairs, Department of Defense Tricare program, or the Public Health Service must be enrolled in PECOS.  A recent memo (http://www.cms.gov/MedicareProviderSupEnroll/Downloads/SpecialEnrollmentFactsheetInfrequentPhysicianReimbursement.pdf) notes there is an abbreviated enrollment process and documents.  However, the on-line enrollment process will not accommodate the abbreviated forms.

Is it true that there are no repercussions for the physician if he or she does not enroll in PECOS?
That is mostly true.  The Centers for Medicare and Medicaid Services (CMS) has encouraged physicians to update their provider files in PECOS.  However, at this time, there are no repercussions for a physician who doesn’t enroll.  Physicians can still bill Medicare for services and certification and recertification of homecare plans of care whether or not they are enrolled in PECOS.

Physicians not enrolled in PECOS by September 1, 2010, will not be eligible for incentive payments under the Health Information Technology for Economic and Clinical Health (HITECH) Act for meaningful use of certified information systems and electronic health records when that comes into play next year.

What if a physician has opted out of the Medicare program?
CMS says that physicians who have an approved opt-out record in PECOS can still order and certify homecare services. 

What about residents who order homecare services?  Can they enroll in PECOS?
At this time, residents are not allowed to enroll in PECOS.  If a resident ordered the services, the claim must identify the teaching physician as the ordering or referring physician and include his or her legal name and National Provider Identifier.  The teaching physician must have an approved enrollment record or a valid Medicare opt-out record in PECOS. 

The audio recording, “PPS Challenges,” answered several questions about PECOS.  Learn more about this educational program at — cgi-bin/ccp51/cp-app.cgi?pg=prod&ref=J071510A.