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PECOS Enrollment Requirement for Ordering and Referring Physicians Further Delayed

The Centers for Medicare and Medicaid Services (CMS) announced a further delay until January 3, 2011 in the requirement of ordering or referring physicians be enrollment in Medicare’s Provider Enrollment Chain and Ownership System (PECOS). Initially this requirement was to be met by December 31, 2009. Medicare ran a test on how many claims would be denied if the policy were to go into full effect and found that over one-third of all physicians who are supposed to be enrolled in PECOS had not done so. Medicare delayed the implementation of this requirement until April 5, 2010, however, a large percentage of providers are still not aware of this requirement and have not complied. The ACR has been very concerned of the ramifications this has for its members. The requirement by Medicare is for all physicians who are involved in the Medicare to be enrolled in the PECOS. This means that if a radiologist or radiation oncologist bills Medicare for a service provided and the referring physician who ordered the service is not enrolled in PECOS, then the claim may be denied payment to the radiologist or radiation oncologist.

CMS officials noted that Medicare physicians and other providers need to continue to enroll in the PECOS system. This is in addition to obtaining a national provider identifier (NPI) number. This most recent delay will allow for claims to continue to be monitored, processed and not to be rejected if the referring and ordering physicians on Medicare claims are not enrolled in the PECOS until January 3, 2011. Claims coming from a radiologist where the referring or ordering physicians is not in the PECOS will still be marked with an error message until the referring or ordering physician establishes or updates his or her enrollment record in the PECOS.

CMS pledged to work with the physician community to update all the providers information in the PECOS between now and the implementation date.

CMS has made the names and NPIs of the Medicare physicians and non-physician practitioners who are already enrolled in PECOS publicly available on CMS Web site at Eligible Referring/Ordering Physician List. The ACR recommends to its members that they contact those referring physicians who are not on the list to remind them that they need to enroll in the PECOS by January 3, 2011.

Please contact Helen Olkaba in the Department of Economics and Health Policy with your questions regarding the PECOS enrollment requirements at holkaba@acr-arrs.org.

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