04.30.12 Since 2009, the AMA has strongly advocated to the Centers for Medicare and Medicaid Services (CMS) that its proposal to require ordering and referring physicians to enroll in Medicare via the Provider Enrollment, Chain, and Ownership System (PECOS), or experience rejection of such claims, would cause workflow problems for physicians. In 2010, Congress passed a statutory provision to require physicians who order or refer to enroll in Medicare and to list their National Provider Identifier (NPI) on all such claims. Later that year, CMS again proposed instituting edits to reject claims if ordering and referring physicians did not have an enrollment record in PECOS and meet the other statutory requirements. At that time, the AMA argued successfully that many physicians did not have enrollment records in PECOS and cited other operational concerns, leading CMS to delay the edit implementation.
In direct response to ongoing AMA advocacy and comments submitted by the AMA and 42 medical specialty societies, CMS has now published a final rule on these requirements that makes significant improvements to CMS’ prior interim final rule and proposals on the subject.