Manage My Practice

U.S. Department of Health and Human Services

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Medicare Learning Network (MLN) just released MM6912, effective August 2, 2010: Mailing To All Individual Practitioners, Medical Groups and Clinics and Independent Diagnostic Testing Facilities (IDTF) Who Are Billing or Have Billed For The Technical Component of Advanced Diagnostic Imaging Services

What exactly is an IDTF?

Some suppliers that perform diagnostic tests, other than clinical laboratory or pathology tests, are required to enroll with Medicare as an Independent Diagnostic Testing Facility (IDTF). Not all suppliers that perform these diagnostic tests are required to enroll as an IDTF.  Generally, entities can bill for the technical component of the diagnostic tests without an IDTF enrollment if it has the following characteristics:

• A physician practice that is owned, directly or indirectly, by one or more physicians or by a hospital
• A facility that primarily bills for physician services and not for diagnostic tests
• A facility that furnishes diagnostic tests primarily to patients whose medical conditions are being treated or managed on an ongoing basis by one or more physicians in the practice
• The diagnostic tests are performed and interpreted at the same location where the practice physicians also treat patients for their medical conditions
• If a substantial portion of the facility’s business involves the performance of diagnostic tests, the diagnostic testing services may be a sufficient separate business to require enrollment as an IDTF. In that case, the physician or physician group practice can continue to be enrolled as a physician or physician group practice but are also required to enroll as an IDTF. The physician or group can bill for professional fees and the diagnostic tests they perform on their patients using their billing number. Therefore, the practice must bill as an IDTF for diagnostic tests furnished to Medicare beneficiaries who are not regular patients of the physician or group practice.

Who will receive a mailing?

Enrolled physicians, non-physician practitioners, including single and multi- specialty clinics, and IDTFs who have billed the Medicare program for the technical component of advanced diagnostic testing services within the preceding six month period and who continue to have Medicare billing privileges with Medicare contractors (carriers and Part A/B Medicare Administrative Contractors (A/B MACs)) are affected.

If you have billed the Medicare program for the technical component of advanced diagnostic testing services within the preceding six month period and continue to have Medicare billing privileges with Medicare contractors, you will receive a letter from your Medicare contractor advising you of the need to become accredited by January 1, 2012, in order to continue to provide these services and bill Medicare.

When more than one physician or non-physician practitioner is operating within a group, such as a single specialty or multispecialty clinic, only the group will receive the letter, not each of the individual physicians or non-physician practitioners working for the group.

What will the mailing say?

You must be accredited by one of the three Centers for Medicare & Medicaid
Services (CMS) approved national accreditation organizations by January 1, 2012,
in order to be eligible to continue to furnish the technical component of advanced
diagnostic testing services to Medicare beneficiaries and submit claims for those
services to your Medicare contractor.

Your contractor will be mailing the letter quarterly beginning with July 2010 through July 2011. If necessary, follow the instructions in the letter to become accredited by January 1, 2012, in order to continue billing for the technical component of advance diagnostic imaging services. Make sure that your office staffs are aware of these new accreditation requirements and begin the accreditation process as soon as possible to protect your Medicare billing rights for these services.

Why do IDTFs have to become accredited now?

Section 135(a) of the Medicare Improvements for Patients and Providers Act of
2008 (MIPPA) amended section 1834(e) of the Social Security Act and required
the Secretary, Health and Human Services, to designate organizations to accredit
suppliers, including but not limited to physicians, non-physician practitioners and
Independent Diagnostic Testing Facilities, that furnish the technical component
(TC) of advanced diagnostic imaging services.

What qualifies as an advanced diagnostic imaging procedure?

MIPPA specifically defines advanced diagnostic imaging procedures as including:
• Diagnostic magnetic resonance imaging (MRI),
• Computed tomography (CT), and
• Nuclear medicine imaging, such as positron emission tomography (PET).

MIPPA expressly excludes from the accreditation requirement x-ray, ultrasound,
and fluoroscopy procedures. The law also excludes from the CMS accreditation
requirement diagnostic and screening mammography, which are subject to quality oversight by the Food and Drug Administration under the Mammography Quality Standards Act.

How long does it take to become accredited?

Since CMS expects that it may take as much as nine months from the time you initiate the accreditation process to completion, you should begin the accreditation process for advanced diagnostic imaging services as soon as possible, but not later than March 2011.

Who are the accrediting organizations?

CMS approved three national accreditation organizations — the American College
of Radiology, the Intersocietal Accreditation Commission, and The Joint
Commission — to provide accreditation services for suppliers of the TC of advanced diagnostic imaging procedures. The accreditation will apply only to
the suppliers of the images themselves, and not to the physician interpreting
the image. All accreditation organizations have quality standards that address the safety of the equipment as well as the safety of the patients and staff.

If you have questions, contact your Medicare carrier and/or A/B MAC at
their toll-free number, which may be found here (zip file.)

Image via Wikipedia

The letter will look like this:

[DATE]

[Supplier Name and Address]

Dear Physician/Non-Physician Practitioner/IDTF owner:

In accordance with Section 135(a) of the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA), suppliers, including but not limited to physicians, non-physician practitioners and Independent Diagnostic Testing Facilities that furnish the technical component (TC) of advanced diagnostic imaging services must be accredited by January 1, 2012 in order to continue to furnish these services to Medicare beneficiaries.

Our records indicate that you have furnished advanced diagnostic imaging procedures such as diagnostic magnetic resonance imaging (MRI), computed tomography (CT), and nuclear medicine imaging such as positron emission tomography (PET) within the last six months.  If you are not accredited by one of the organizations shown below by January 1, 2012, you will not be eligible to bill the Medicare program for advanced diagnostic imaging services.  This letter requests that you take the necessary action to become accredited by the January 1, 2012 deadline.  Since we expect it can take up to nine months from the time you initiate the accreditation process to completion, we urge you to begin the accreditation process for advanced diagnostic imaging services as soon as possible.

MIPPA expressly excludes from the accreditation requirement x-ray, ultrasound, and fluoroscopy procedures.  The law also excludes from the CMS accreditation requirement diagnostic and screening mammography which are already subject to quality oversight by the Food and Drug Administration under the Mammography Quality Standards Act.

The Centers for Medicare & Medicaid Services (CMS) approved three national accreditation organizations – the American College of Radiology, the Intersocietal Accreditation Commission, and The Joint Commission – to provide accreditation services for suppliers of the TC of advanced diagnostic imaging procedures.  The accreditation will apply only to the suppliers of the images themselves, and not to the physician interpreting the image.  All accreditation organizations have quality standards that address the safety of the equipment as well as the safety of the patients and staff.  The accrediting organization that issues your accreditation will notify Medicare once your accreditation is complete and approved.

To obtain additional information about the accreditation process, please contact the accreditation organizations shown below.

American College of Radiology (ACR)
1891 Preston White Drive
Reston, VA 20191-4326
1-800-770-0145

Intersocietal Accreditation Commission (IAC)
6021 University Boulevard, Suite 500
Ellicott City, MD 21043
1-800-838-2110

The Joint Commission (TJC)
Ambulatory Care Accreditation Program
One Renaissance Boulevard
Oakbrook Terrace, IL 60181
1-630-792-5286

If you have questions about this letter, contact [carrier or A/B MAC phone number/contact person].

Sincerely,

[Name of carrier or A/B MAC]

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Supplier Billed Advanced Medical Imaging CPT codes for Section 135 (a) of the MIPPA to Receive Accreditation Requirement Notification Letter

70336  70540  71250  72125  73200  74150
70450  70542  71260  72126  73201  74160
70460  70543  71270  72127  73202  74170
70470  70544  71275  72128  73206  74175
70480  70545  71550  72129  73218  74181
70481  70546  71551  72130  73219  74182
70482  70547  71552  72131  73220  74183
70486  70548  71555  72132  73221  74185
70487  70549    72133  73222
70488  70551    72141  73223
70490  70552    72142  73225
70491  70553    72146  73700
70492  70554    72147  73701
70496  70555    72148  73702
70498  70557    72149  73706

70558    72156  73718

70559    72157  7371972158  73720
72159  73721
72191  73722
72192  73723
72193  73725
72194
72195
72196
72197
72198
72200
75557  76360  77011  78000  78811
75559  76376  77012  78001  78812
75561  76377  77021  78003  78813
75563  76380  77058  78006  78814
76390  77059  78007  78815
76497  77078  78010  78816
76498  77079  78011  78891
78015
78016
78018
78020
78070
78075
78099

Report by Frank Cohen
Frank Cohen, MPA, MBB
The Frank Cohen Group, LLC

As many of you may already know, July 1, 2010 CMS released yet another RBRVS (Resource Based Relative Value Scale) data set that will be used to pay physicians under Medicare effective June 1, 2010. This data set includes the 2.2% increase in the CF. This puts the current conversion factor at $36.8729.

The link to the CMS file is here.

The good news is that the Conversion Factor (CF) increased by 2.2%.

The bad news is that for 2,226 procedure code/modifier groups within the database, the RVU (Relative Value Unit) values decreased by anywhere from 0.65% to 50% (or 0.01 to 2.04 RVUs). The median change was only 0.12 RVUs, which in and of itself doesn’t seem like much, but if you add them up, you get a total reduction of 492.95 RVUs for just these procedure codes.

This doesn’t consider frequency of use. For example, procedure code 75825 26 saw a reduction in RVUs of 1.16. In 2008, this procedure was reported to Medicare 60,864 times. That results in a net decrease in RVUs to those practices of 70,602 RVUs. At the current conversion factor, that is a payment reduction of $2.6 million.

In addition to the RVU changes, there were 180 non-RVU changes, including changes to the PC/TC (Professional Component/Technical Component) policies, new records, modified status, etc.

Note: Frank ran a side-by-side analysis of the changes for these procedure codes. If you would like a copy of his worksheet, go to his site and click on the Download tab. Even if you don’t want this file, he has lots of other goodies on his site for free.  As always, thanks Frank!

email Frank

visit Frank’s site

I don’t know about you but I am emotionally exhausted thinking about and worrying about the on-again off-again cuts in Medicare fees for physicians.

Here’s the scoop: late Thursday evening, June 24, 2010, the House of Representatives passed the ” Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010 (H.R. 3962)” which includes a delay in the 21+% fee cut. Because the same legislation was already passed by the Senate, it now goes to the President for his signature and it becomes law.  It is anticipated that this will happen quickly and CMS will have the MACs start processing new claims with dates of service of June 1, 2010 and later at the 2009 fee schedule plus a 2.2% increase.  The MACs will also have to reprocess the claims already paid for dates of service June 1, 2010 and later that were processed with 2010 fee schedule and that big fat cut.

Q: What should we be doing for the next 5 months and 6 days?

A: Have someone in your practice take a video of your providers introducing themselves, telling how many Medicare patients they have and how they can’t afford to see Medicare patients unless the SGR formula is replaced with something that works. The video doesn’t have to be slick – just real.  Send it to your senators and representatives.  Send it your local TV news.  Post it on YouTube.  Imagine hundreds of thousands of providers introducing themselves and talking about their patients.  It would be powerful.

Nurse, Practice Administrator and now Consultant Donna Izor, MS, FACMPE blogs about her trip to Haiti to provide medical relief.

As medical practice managers, we experience the challenge of providing care to patients each day. The success of our daily work depends upon our knowledge and experience and occurs within the constructs of policies and regulations.

Now imagine working in an environment without job descriptions, JCAHO or HIPAA. It is also without a facility, water or electricity. Patient care demand is high and access is limited or non-existent. Sound interesting?  Then consider medical relief work.

The timing had never been right for me, but I was captivated by the stories of others providing needed medical care, doing jobs that may not be their expertise, struggling with a new language and learning about a new culture.  Resigning a position as VP of Physician Services to begin my own consulting firm provided the opportunity to fill this dream.   I had no idea when I would go, or where, but knew I wanted it to be within the next six months.  I started speaking to friends who had gone on missions and asked they keep me in mind for future trips.

One friend emailed others and asked if they knew of relief missions going out within the next few months.  Within a week I received an email that a medical team would be going from the Dominican Republic into Haiti and they were looking for workers.

I contacted the coordinator, a nurse practitioner located in the DR, and told her I was an administrator but had been a nurse though I hadn’t used my skills in 20 years.

She said my nursing skills would be helpful and I agreed to go.  Hearing this my husband decided to join in and they were happy to have his skills as an engineer as part of our team.

Within one week I was able to collect over 70 pounds of the requested over the counter medications and dressings from friends, former practices and a local drugstore.  People were very willing to help.  Others gave us old scrubs that we could use then leave behind.  There were some challenges – finding a mosquito net in March when there is still snow on the ground but the planning went well and even the airline helped by allowing additional luggage. In less than two weeks from the initial email we were on our way to join medical teams for one week in Haiti and a second week in bateyes (sugar workers’ town) of DR.

We landed in the DR and traveled to the mission home location in La Romana to meet other team members and to learn about the work in Haiti.  Our team consisted of two physicians, two medical students, a pediatric resident, several senior nursing students and their instructor, a pastor, a marketing executive, two nurses from Maine, a nurse from Nebraska and one from Alabama and several staff members of the mission living in the DR.  Under the leadership of the coordinator, Kristy, we learned to work together and trust each other.

Image via Wikipedia

We spent the first day repackaging medications into small bags for patient distribution and organizing the food donations that we would also be bringing.  A human chain made quick work of loading the two trucks.  At 10pm we climbed into a bus to begin our trip.   By 8 am were at the Haitian border, joining long lines of waiting trucks.  We spent over 6 hours at the border while our coordinator worked hard to gain entry for us.   The president of Haiti had declared that the disaster was over and the country was poised to manage the aftermath on its own.  Send money, he’d direct it.  Kristy knew how dire the circumstances were for the people of Haiti and persevered.  We were allowed to enter and our “real” journey began.

There is nothing to prepare you for seeing the effects of an earthquake in a country little able to deal with it.

My husband described it as the difference in seeing a picture of the Grand Canyon and being at the Canyon looking over the rim. The vastness and sense of awe is little served by the picture.  Port au Prince had been on the news in the three months since the quake yet the expanse of destruction, the poverty and lack of services for the people, and the sheer amount of rubble and garbage filling the streets was confounding.

We arrived in Port au Prince late in the afternoon and settled into the walled compound that would be our home for the week.  On the grounds were a church, school, dormitory, kitchen, locked storage building used by the relief mission teams and several tents, home to the workers there.  A generator provided electricity to run the fans and the water pump.  Regretfully, it was old and often broke down meaning no showers and a very hot sticky night of sleeping.

Donna is on the right in the back of the truck (with glasses.)

Our days began early.  After breakfast we loaded the open backed trucks with food, medicines, and tarps and then put in church pews to sit on before climbing in.  Interpreters joined us for the rides.  At that time, we were the only relief agency going into the neighborhoods to provide care.  Because there was concern for the safety of relief workers, Kristy arranged to hire two off duty Haitian police officers for protection.  We would ride through the city in amazement at the destruction, surprised not to see any other relief workers.

Huge water bladders from the Red Cross were located on several streets as well as temporary showers and port-o-lets.   Any available space was occupied by a family with a make shift tarp or tent.  Houses that had fallen down three months before were still spilled into the street with people walking through the debris.

People dug in the rubble of homes to release rebar so that it could be resold.  This was hard to watch knowing that there were still bodies located there.

Reaching our destination, Kristy and the lead support person from DR would decide how the clinic would be set up while we waited in the truck, protecting the contents.
It took less than 30 minutes to unload the truck and set up the clinic with the entire team helping.  Patients would be given a “ticket” allowing them to be seen.  Then they would provide their name, age, and describe their current symptoms to a Haitian worker who put it on a yellow card that traveled with the patient.  There were many who came because they knew that we had food and water but they were turned away.  Hundreds waited in 90+ degree heat in the sun for the opportunity to be seen by the medical team.

After entering the clinic area, patients had their weight and blood pressure taken.  The clinic area was a large space with providers sitting on benches next to their interpreter.  Each provider had a box of “usual” medications including antacids, multi vitamins and acetaminophen for each age group.  Patients waited quietly until they were escorted to a provider.  With little examination, the provider indicated the likely diagnosis, gave medications from his box, and indicated the prescriptions to be given.  The patient would move to the pharmacy where nurses and an interpreter completed the order.  Then would then go to the de-worming station for all who were over 6 months old and not pregnant.  Finally they moved to the gift station where a bag of food (2 pounds rice, 2 cans beans, and 1 can tomato sauce) was given to each family as well as soap and donated clothing while it lasted.

Providers are on one side with their interpreters and patients on the other. Kristy, our leader, is in yellow.

Each day nurses rotated through the various duties of taking vital signs, the pharmacy, the de-worming station and the gift station. Everyone took time to play with the kids and to live the motto we had been given,

“Do what you can, with what you’ve got, in the moment you’re given”.

We knew that many would not make it back to where they were living with the food they were given, but some would.  That the 30 days of medications would run out, but for 30 days it would be all right.  That the smiles we were seeing would fade to despair as the rain began, but for today the sun was shining.

The people we took care of were inspirational.  If they were living in plastic covered tents, they were lucky.  Many were still living under sheets held up by sticks. Their lives were a mess but they easily shared their smiles.  The kids loved the attention, and getting them to leave the clinic was often difficult.

Not everyone is lucky enough to have a tent and have made do with what they have. Note the large amount of garbage.

The most common reason for being seen was grippe, a diagnosis that included any respiratory symptom and fever.  Without an x-ray for confirmation, all patients were treated with antibiotics.  We saw wound infections from surgery or treatments that occurred after the earthquake but had not been treated since.  Dehydration, malnutrition, starvation, scabies, high blood pressure, upper gastric pain, and vaginal infections were some of the other diagnoses.

Treatment was basic.  We had limited medications so routinely substituted others as inventory ran out.  The clinic was loud but ordered.  The organization that was developed by running these clinics over time was amazing given the conditions.  What became hardest was leaving.  We had to be back to the compound by dark and often this meant we had to pack up and leave a site before everyone could be seen.

Adults asked for care, children begged for water and food, yet many stayed to say thank you.

Our ride back to the compound included a stop at the General Hospital in Port-au-Prince where patients with severe illnesses were taken.  You must realize that part of the hospital had collapsed and it did not have running water or electricity.  The doctor who had seen them in the clinic accompanied Kristy into the ED to discuss the case with the physicians there.  Often, the doctors at the hospital were from the US or Canada but doctors from there and many other nations were said to be working together.   Once such case was a 5-month-old infant who had returned to birth weight.  Another woman had an infection at a surgical site that would probably require amputation of her foot; another was a 3 year old with cellulitis surrounding her eye.  We left them knowing that family members may not know where they were and that a ride back to where they were living would be difficult to come by.

Fallen house, one of many.

Our trip back to the compound again brought us through the streets of Port-au-Prince.  We saw downed houses, people selling anything and everything under colorful umbrella, and the mounds of plastic water bottles and Styrofoam containers garbage from the initial relief after the earthquake but now filling the canals meant to drain the city during the rainy season.  We saw tent cities in areas that would be flooded with no place for these people to go.  Others had set up their shelters in the median of the road.  People shouted out to us for water and food, or just a greeting.  We passed armed UN soldiers driving in jeeps through the city.  The devastation was everywhere you looked.

When we returned, it was time to unload the trucks.  If there was water, the lines for the shower began.  People worked to repack the supplies for the next day and to enjoy a mango from one of the many trees on the compound.  Dinner was always delicious and followed by a group meeting to discuss what we had seen and done for the day.

People shared their thoughts and some cried when discussing the level of illness, the people not able to be seen, or what we had seen on the ride to or from the clinic.

Several evenings the church came alive with music and prayer.  I worked on a project to collect age, diagnosis and medications data to be used for Kristy to write grants and try to gain additional monies for future trips.  Bedtime was early, and we were ready to sleep, as we would have an early start the next day.   It was hot, especially when the fans were not working, but we had food, water and a roof over our heads.  So much more than those we had cared for.

Leaving Haiti was difficult.  There was so much more to do.  There would always be so much more to do until the structure of the country became stable and one that would support all of its’ people.  The ride back to the DR was much quieter.  The border crossing into the DR was quick and easy.  Only a flat tire slowed our travels.

Once back we unloaded the trucks, took long showers, and continued to debrief from the experience.  Only my husband and I would be staying an additional week to work in the bateyes, so we began saying our good-byes to our teammates.  I know that we will keep in contact with many as the years go by and our hope is to come together again in the future for another relief mission.

So can an administrator with past nursing experience learn from a relief mission?  Yes, first about yourself and how you will endure conditions that you could only imagine.

Second you learn about others and the real meaning of doing what you can, for those that you see, with what you have and for that moment.  I encourage each of you to embark on your own journey.  You don’t need to leave the United States, there are many organizations that need help right here and I’m sure some right in your town.  Be it a medical relief mission or participation on the local level, you will learn so much and it is so worth it.

Donna Izor, MS, FACMPE recently started West Pinnacle Consulting, LLC after 20 years as a medical practice executive.  Her experience includes responsibility for primary care and specialty practices, employed inpatient physicians, regulatory oversight, facility design, physician compensation and relations, and new program development. She has worked with academic, community hospital, and private practices.  You can contact Donna at donna.izor@gmail.com.

UPDATE: On June 25, 2010, President Obama signed into law the “Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010 (H.R. 3962)” which includes a delay in the 21+% Medicare fee cut until November 30, 2010. CMS will have the MACs start processing new claims with dates of service of June 1, 2010 and later at the 2009 fee schedule plus a 2.2% increase.  The MACs will also have to reprocess the claims already paid for dates of service June 1, 2010 and later that were processed with 2010 fee schedule and that big fat cut.

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Note: On June 16, 2010 the Senate failed to pass a proposal that would increase the Medicare reimbursement for physicians by 2.2% for the balance of calendar year 2010 and by 1% for calendar year 2011.   Senate leadership is now working on a plan to extend the freeze until year-end.  The following statement was released by the state medical societies of all 50 states and the District of Columbia, as well as 41 specialty physician organizations.

Statement of the State and Specialty Medical Societies on the Medicare Physician Payment Crisis

Failure by Congress to fulfill its responsibilities is undermining patient care in America.  Three times this year, Congress has missed a deadline for dealing with Medicare’s sustainable growth rate (SGR) formula, raising the specter of a 21 percent payment cut for physician services.  The disruption and uncertainty for patients and physicians has made Medicare an unreliable program.

If Congress does not act this week, Medicare physician payments will be cut 21 percent.  These cuts will also extend to the TRICARE program which serves military families, as well as some Medicaid programs, workers compensation programs and private insurance plans.  The ripple effect of the 21 percent Medicare cut will be devastating to physician practices.

Congressional mismanagement of the Medicare program will force more physicians to stop accepting new Medicare and TRICARE patients; lay-off staff; and defer investment in new medical equipment, health information technology, and other innovations that improve patient care.

Patients and physicians should not become collateral damage in a Congressional stalemate on budgetary matters.  We expect our elected officials to resolve the budget issues without punishing physicians, seniors and military families.

Past actions by Congress created the current budgetary challenge.  Further, since 2003, Congress has compounded this problem by employing budget gimmicks that defer immediate cuts by stipulating deeper cuts in future years.

Democrats and Republicans agree that the flawed Medicare formula that is responsible for pending cuts should be repealed.  The annual SGR battle diverts attention from more productive delivery and payment reform initiatives.  We must move to a payment system that fosters innovation and rewards physician efforts to lower the rate of growth in Medicare spending across the existing silos in the program.

Medicare must adequately cover the cost of care and close an existing 20 percent gap as measured by the government’s own conservative measure of annual increases in medical practice costs.

We must also allow seniors who wish to contract directly for their care with a physician of their choice to do so without foregoing the Medicare benefits for which they paid during their working years.  Medicare benefits were earned by and belong to Medicare beneficiaries.  They must be allowed to assign these benefits as they see fit.

Playing brinksmanship with the health care of seniors and military families is inexcusable and represents a dereliction of duty.  We urge Congress to honor its obligation to provide access to quality care to America’s seniors and military families by taking action to fix the Medicare physician formula problem now!

American Academy of Dermatology
American Academy of Facial Plastic & Reconstructive Surgery
American Academy of Family Physicians
American Academy of Hospice & Palliative Medicine
American Academy of Neurology
American Academy of Ophthalmology
American Academy of Pain Medicine
American Academy of Pediatrics
American Academy of Physical Medicine & Rehabilitation
American Academy of Sleep Medicine
American Association for Hand Surgery
American Association of Clinical Endocrinologist
American Association of Clinical Urologist
American Association of Neurological Surgeons
American Association of Neuromuscular & Electrodiagnostic Medicine
American Association of Public Health Physicians
American College of Cardiology
American College of Emergency Physicians
America College of Gastroenterology
American College of Obstetricians & Gynecologists
American College of Occupational & Environmental Medicine
American College of Rheumatology
American College of Surgeons
American Gastroenterological Association
American Institute of Ultrasound in Medicine
American Medical Association
American Orthopaedic Foot & Ankle Society
American Society for Clinical Pathology
American Society for Reproductive Medicine
American Society for Surgery of the Hand
American Society of Addiction Medicine
American Society of Cataract & Refractive Surgery
American Society of Cytopathology
American Society of Ophthalmic Plastic & Reconstructive Surgery
College of American Pathologists
Congress of Neurological Surgeons
Heart Rhythm Society
North American Spine Society
Renal Physicians Association
Society of American Gastrointestinal Endoscopic Surgeons
Society of Nuclear Medicine

Medical Association of the State of Alabama
Alaska State Medical Association
Arizona Medical Association
Arkansas Medical Society
California Medical Association
Colorado Medical Society
Connecticut State Medical Society
Medical Society of Delaware
Medical Society of the District of Columbia
Florida Medical Association, Inc.
Medical Association of Georgia
Hawaii Medical Association
Idaho Medical Association
Illinois State Medical Society
Indiana State Medical Association
Iowa Medical Society
Kansas Medical Society
Kentucky Medical Association
Louisiana State Medical Society
Maine Medical Association
MedChi, The Maryland State Medical Society
Massachusetts Medical Society
Michigan State Medical Society
Minnesota Medical Association
Mississippi State Medical Association
Missouri State Medical Association
Montana Medical Association
Nebraska Medical Association
Nevada State Medical Association
New Hampshire Medical Society
Medical Society of New Jersey
New Mexico Medical Society
Medical Society of the State of New York
North Carolina Medical Society
North Dakota Medical Association
Ohio State Medical Association
Oklahoma State Medical Association
Oregon Medical Association
Pennsylvania Medical Society
Rhode Island Medical Society
South Carolina Medical Association
South Dakota State Medical Association
Tennessee Medical Association
Texas Medical Association
Utah Medical Association
Vermont  Medical Society
Medical Society of Virginia
Washington State Medical Association
West Virginia State Medical Association
Wisconsin Medical Society
Wyoming Medical Society

See story here.

Note: MLN Matters published this link on June 9th that was inadvertently left out of the June 8th notice: http://www.cms.gov/MLNMattersArticles/downloads/MM6842.pdf

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On May 28, 2010, CMS in Change Request 6842 notified Medicare Part A & B Administrative Contractors (A/B MACs) of their responsibility to facilitate a “One-Time Mailing” to all physicians and non-physicians who are currently enrolled in Medicare but who do not have an enrollment record in PECOS.

This mailing is to take place no later than 30 days after the date of the issuance (May 28th), therefore no later than June 28, 2010, leaving only six business days before the July 6 date for PECOS enrollment.

Additionally, the Change Request states:

A provider education article related to this instruction will be available at http://www.cms.hhs.gov/MLNMattersArticles/ shortly after this CR is released.  You will receive notification of the article release via the established “MLN Matters” listserv.  Contractors shall post this article, or a direct link to this article, on their Web site and include information about it in a listserv message within one week of the availability of the provider education article.  In addition, the provider education article shall be included in your next regularly scheduled bulletin.  Contractors are free to supplement MLN Matters articles with localized information that would benefit their provider community in maintaining Medicare provider enrollment data correctly.

As of Tuesday evening when I posted this article, the MLN Matters article referred to had not been published.

Interestingly, there is no mention of the July 6, 2010 date that is the so-called compliance date for all providers to have an enrollment record in PECOS.  As of the last CMS open door forum (my notes here) there was a lack of clarity surrounding the July 6, 2010 date versus the original January 1, 2011 date. The speaker would not definitively say that providers without a PECOS enrollment record as of July 6, 2010 would not receive Medicare payments.  Given the short time frame between the MAC letters and the July 6 date, one would assume providers will have a grace period before CMS shuts off reimbursement for services rendered and/or refuses stimulus money for meaningful use of an EMR.

More information on the Stimulus Money here:

FAQ on HITECH, Meaningful Use, Eligible Providers, and the Stimulus Money

ARRA Eligible Providers: Who Is Eligible to Receive Stimulus Money and How Much is Available Per Provider?

If you are not enrolled in PECOS,

this is what your letter will look like:

[DATE]

[Physician/Non-Physician Practitioner Name and Correspondence Address]

Dear Physician/Non-Physician Practitioner:

Our records indicate that you do not have an enrollment record in the Medicare Provider Enrollment, Chain and Ownership System (PECOS) because you enrolled in Medicare prior to the implementation of PECOS and you have not submitted any updates to your Medicare enrollment information in the past 6 (or more) years.  PECOS is the enrollment system for Medicare providers and suppliers.

There are three important reasons why you should take the necessary action to establish an enrollment record in PECOS as soon as possible.  First, updating your Medicare enrollment record will assist us in ensuring payment accuracy for the services you furnish to Medicare beneficiaries.  Second, you will need an approved enrollment record in PECOS to continue to order or refer items or services for Medicare beneficiaries.  Finally, in accordance with the American Recovery and Reinvestment Act of 2009, Title XIII, known as the “HITECH Act,” incentive payments may be made by Medicare and Medicaid to enrolled “eligible professionals” and certain hospitals that meet the HITECH requirements.  More information on Medicare HITECH incentive payments can be found at http://www.cms.hhs.gov/Recovery/11_HealthIT.asp under “Related Links Outside CMS” on the CMS web site.  The Centers for Medicare & Medicaid Services (CMS) will use the PECOS enrollment records to verify Medicare enrollment for HITECH incentive payments.  Therefore, you will not be eligible to receive incentive payments from Medicare for meaningful use of certified electronic health records if your enrollment information is not maintained in PECOS by CMS.

Since you do not have a current Medicare enrollment record, it is imperative that you immediately begin the process to establish your enrollment record in PECOS.  CMS expects you to do this as soon as possible after receiving this letter.  If you have already submitted an enrollment application within the last 60 days, and your enrollment application has been accepted for processing by the carrier or A/B MAC, you need not take any additional actions based on this letter.

You can submit your enrollment application in one of two ways:

(1) Use Internet-based PECOS

• Step 1.  Before you begin, be sure you have a National Provider Identifier (NPI) and have created a User ID and password in the National Plan and Provider Enumeration System (NPPES).  You will need the NPPES User ID and password in order to access Internet-based PECOS.  If you need help creating an NPPES User ID and password, or if you are not sure you ever created them or cannot remember what they are, you may contact the NPI Enumerator for assistance at 1-800-465-3203.

• Step 2.  Read the documents that are available about Internet-based PECOS on the CMS Provider/Supplier Enrollment web page www.cms.hhs.gov/MedicareProviderSupEnroll/

• Step 3.  Once you have completed and submitted your enrollment application using Internet-based PECOS, be sure to print the Certification Statement, sign and date it, and mail it, along with any required supporting documentation, to the carrier or A/B MAC whose name and mailing address will be displayed to you by the system.

Note:  If you reassign some or all of your Medicare benefits to a group practice, there will be two Certification Statements to print, sign and date, and one of them will also need to be signed and dated by an Authorized Official of the group practice.  The carrier or A/B MAC cannot process your web-submitted enrollment application without having the signed and dated Certification Statement(s) in hand.

(2) Complete the paper Medicare enrollment application (CMS-855I) as an initial application.

• Step 1.  Complete the CMS-855I (if you reassign benefits to a clinic or group practice other than your own, complete a CMS-855R as well), sign and date (blue ink recommended) and mail the application(s), along with any required additional supporting documentation, to the Medicare carrier or A/B MAC.  These forms are downloadable from the CMS Provider/Supplier Enrollment web page (shown above) or the CMS forms page www.cms.hhs.gov/cmsforms or you may request the necessary forms from the carrier or A/B MAC.

• Step 2.  Once the paper application has been received by the carrier or A/B MAC, the carrier or A/B MAC will begin to process your enrollment application.  If additional information is needed by the carrier or A/B MAC to complete the processing of your enrollment application, they will contact you.

You are strongly urged not to delay in establishing your Medicare enrollment record within PECOS, especially if you plan on applying for incentive payments under the HITECH program. The carriers and A/B MACs are expected to process your enrollment application within 60 days as long as you submit your enrollment application before September 1, 2010.

If you need information about Medicare enrollment or how to use Internet-based PECOS, visit the
CMS Provider/Supplier Enrollment web page at: www.cms.hhs.gov/MedicareProviderSupEnroll/

If you need assistance with your NPPES User ID and password, contact the NPI Enumerator at 1-800-465-3203.

If you have questions about this letter, contact [carrier or A/B MAC phone number/contact person].

Sincerely,

[Name of carrier or A/B MAC]

From the Federal Trade Commission:

“At the request of several Members of Congress, the Federal Trade Commission is further delaying enforcement of the “Red Flags” Rule through December 31, 2010, while Congress considers legislation that would affect the scope of entities covered by the Rule. Today’s announcement and the release of an Enforcement Policy Statement do not affect other federal agencies’ enforcement of the original November 1, 2008 deadline for institutions subject to their oversight to be in compliance.”

Read more here.

My post and resources on Red Flags Rule here and in the Manage My Practice Library.