Part B Insider (Multispecialty) Coding Alert

Published on Wed Apr 14, 2010 PDF

Plus: OIG encourages Medicare contractors to seek overpayments after discovering that it only recovered 7 percent of overpayments identified in 2007.

CMS can't seem to make up its mind regarding when your ordering/referring providers' NPIs must be in PECOS. Just two months after delaying the provision until 2011, the agency has done an about-face, announcing that ordering/referring docs' NPIs must be in PECOS by July 6 of this year.

If your physician performs a service as the result of an order or referral, your claim must include the ordering or referring practitioner's national provider identifier (NPI), and that number must be in the Medicare Provider Enrollment, Chain, and Ownership System (PECOS) or the payer's computer system. Currently, if you submit claims for services or items ordered/ referred and the ordering or referring physician's information is not in the MAC's claims system or in PECOS, your practice will get an informational message letting you know that the practitioner's information is missing from the system. But CMS will start start denying claims that lack this information as of July 6.

You can find all the details of the date change in the May 5 Federal Register, viewable at http://edocket.access.gpo.gov/2010/2010-10505.htm.

In other news: If your MAC identified an overpayment that the Medicare program paid to your practice and you didn't pay it back, don't think they've forgotten about it.

A new OIG report indicates that CMS Program Safeguard Contractors (PSCs) identified 4,239 overpayments in 2007 that resulted in $835 million paid inappropriately during that period. However, claims processors had collected only $55 million as of June 2008 -- which was just 7 percent of the total owed back to contractors.

"CMS should determine what happened to the 1,060 overpayments that PSCs referred to claims processors in 2007, for which claims processors could not provide any collection information," the OIG report advises.

What this means: You may be able to delay repaying your contractor for overpayments, but it will eventually catch up with you. Your best bet is to repay any overpayments that Medicare made to your practice as soon as you identify them. To read the OIG report visit www.oig.hhs.gov/oei/reports/oei-03-08-00030.pdf.