For a long time, home health agencies have been tasked with confirming that any referring or certifying physician was registered in the PECOS system. The PECOS system, standing for Provider Enrollment Chain Ownership System, is essentially the Medicare enrollment platform where all providers offering Medicare services and billing Medicare are enrolled. Starting May 2024, hospices will be mandated to ensure all certifying physicians and attending physicians are registered in the PECOS system.  

Hospices must comprehend the severe consequences of non-compliance with this requirement. If the attending or certifying physicians mentioned on your claim are not registered in the PECOS system at the time of claim processing, your claims will be rejected, and if the physician had never been registered in PECOS there will be no opportunity for recovery. It’s vital to start incorporating this PECOS verification immediately, despite the official implementation not being required until May 2024, because it’s not feasible to simply start on May 1 and expect everything to fall into place.  

Being part of the PECOS system requires certain steps. For instance, if you’re working with a doctor who doesn’t currently bill Medicare, they can choose not to do so and by completing the required opt out form, they’ll be added to the PECOS system. The main aim of this process is to verify that permissible practitioners are certifying your patients. This practice has been followed in home health for years, but it hasn’t been without issues. There have been instances when the patient or the physician was registered in PECOS at the time of eligibility verification, but they weren’t at the time the claim was processed. However, according to the final rule for hospices, there should be no issue if the physician becomes unenrolled in the PECOS system between your initial confirmation of their enrollment and the billing period.  

Contrarily, we have certainly faced problems with this in home health, so it remains to be seen how this will unfold. However, you must ascertain that they are registered in PECOS at the start of a patient’s admission, and it is also highlighted that this verification needs to occur at every recertification stage.  

We have included links that will direct you to the PECOS section of the CMS website that will guide providers or physicians who may not be currently enrolled through the enrollment process. To access this, please click here.

Several home health and hospice EMR systems are already designed to automatically verify the PECOS system once a physician’s details are entered. If your EMR doesn’t have this feature, it’s crucial that you manually carry out each check. 

If there is anything HPS can ever do for you, don’t hesitate to reach out and let us know.

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