Recently, Ginny Tritschler communicated a very troubling development from the Federal Government that could significantly and negatively impact our ability to care for a large proportion of our patients. The physician enrollment system (called PECOS) mandated that physicians referring to home health agencies for their Medicare patients be fully enrolled in the system so that the home health agencies could be reimbursed for those services. Although the impact of that regulation was directed toward physicians, their non-compliance would result in our not getting paid for services provided and/or our patients being unable to receive the critical health care services they require.
I’m very happy to report a positive outcome. The regulation will NOT go into effect this month, but rather has been postponed to October. For more details, please see my email to the Board below.
Ginny Tritschler, Mary Campbell, Bryan Kaplan, Keith Giannelli, and Jean Clive all deserve a special pat on the back. They all went way above and beyond in helping us to respond to this serious challenge. So… thank you to Ginny, Mary, Bryan, Keith and Jean. Feel free to flood their inboxes with notes of appreciation!
And if you ever wonder whether writing to your senator or representative actually makes a difference, know this: it does make a difference! Thank you to all of you who took the time to send an email or call. The voice of the VNA of Boston was loud and clear… and it was heard.
Finally, all of the professional associations to which we belong have been actively engaged in this effort, but a special acknowledgement of the National Association for Home Care (NAHC) should be made. NAHC took the lead and actively worked with the Federal Government to make this change possible.
Much work remains to be done on this issue and we all need pledge our support to those who are completing the critical next steps. Expect further updates whenever there’s anything worth communicating.
A holiday weekend is coming. I hope you have a great one.
EMAIL TO THE BOARD:
The VNAB has been notified that CMS will implement a review of the PECOS enrollment process, thus postponing the immediate issue of caring for patients whose physician is not enrolled in the PECOS system. Based upon a Press Release distributed by CMS and discussions that we have had with representatives from the National Association of Home Care (NAHC), our understanding of the CMS PECOS review process is:
• CMS will not reject claims for home health services where the ordering/certifying physician is not currently found in the PECOS record.
• Home health agencies will not be subject to a risk that the claim will later be reopened and retroactively denied because the physician was not in PECOS.
• Serving home health patients following the orders of a physician not in the PECOS record will not be considered a violation of any Medicare rule until such time as the CMS editing process is fully operational and public notice to that effect is given.
• This approach will hold providers harmless for PECOS-related matters until such time as CMS implements its editing and automatic rejection process (approximately October, 2010).
We are relieved that CMS has taken this position, however the VNAB will continue to implement a formal internal process to assure that referring physicians are enrolled in the PECOS system and that those who are not obtain information from the VNAB on how to successfully enroll.
Much work remains to be done on this issue, but the immediate threat has been thwarted. A special thank you to Ginny Tritschler for coordinating the many activities associated with our response. An acknowledgement to NACH is in order for the critical role they played as well. Finally, thank you for writing to our delegation and for your ongoing support of the VNA of Boston.
Have a wonderful holiday weekend.