Subject	PECOS Rule Delayed Again
Source	Coding Corner May/June 2010
Publication	Coding Corner May/June 2010
Effective Date	Jun 1, 2010
Publish Date	Jun 1, 2010

The Centers for Medicare and Medicaid Services (CMS) has delayed, until January 3, 2011, a rule(http://www.cms.hhs.gov/MedicareProviderSupEnroll/06_MedicareOrderingandReferring.asp) requiring all physicians and non-physician practitioners who are eligible to order items or services, or refer Medicare beneficiaries to other Medicare providers or suppliers for services, to have current enrollment records in Medicare.  This is the third postponement of Phase 2 of CMS Change Requests (CR) 6417 (http://www.cms.hhs.gov/Transmittals/downloads/R572OTN.pdf) and 6421(http://www.cms.hhs.gov/Transmittals/downloads/R480OTN.pdf) which were initially scheduled to take effect January 1, 2010 and later postponed until April 5, 2010.

CMS has stated the delay will give physicians and non-physician practitioners who order items or services for Medicare beneficiaries or who refer Medicare beneficiaries to other Medicare providers or suppliers sufficient time to enroll in Medicare or take the action necessary to establish a current enrollment record in Medicare prior to Phase 2 implementation.

A current enrollment record is one that is in the Medicare Provider Enrollment, Chain and Ownership System (PECOS) and also contains the physician/non-physician practitioner's National Provider Identifier (NPI). A physician or non-physician practitioner who orders or refers and who does not have a current enrollment record that contains the NPI will cause the claim submitted by the Part B provider/supplier who furnished the ordered or referred item or service to be rejected. 

OMSs and general dentists will in fact be required to enroll in Medicare and be registered in PECOS in order to refer and / or order services, when those services are of the kind requiring ordering / referring provider information.  AAOMS is encouraging all members to verify their enrollment information in the Internet-based PECOS system (https://pecos.cms.hhs.gov/), regardless as to when enrolled in Medicare.

CMS has made available a downloadable PDF file  (http://www.cms.hhs.gov/MedicareProviderSupEnroll/06_MedicareOrderingandReferring.asp) of National Provider Identifiers (NPIs) and names (last name, first name) of all physicians and non-physician practitioners who are of a type/specialty that is legally eligible to order and refer in the Medicare program and who have current enrollment records in Medicare (i.e., they have enrollment records in PECOS).  It is a PDF file containing approximately 800,000 records and will be updated periodically to include changes in enrollment records.  Providers are encouraged to check this list to see if those from whom referrals for services are received, are in fact listed. 

AAOMS members are encouraged to continue watching the latest news section of the Practice Management and Allied Staff pages of the AAOMS web site

(http://www.aaoms.org/practice_mgmt.php), monthly AAOMS Advocacy e-Newsletters

 (http://www.aaoms.org/advocacy_enews.php), the AAOMS Today

 (http://www.aaoms.org/aaoms_today.php) and other AAOMS news vehicles for updates on this issue as they become available.