Dear Colleagues and Guests,
As most of you likely know the PECOS regulations go into effect on
January 3, 2011. Our office is still getting warning information from
Medicare (CMS) that does not match either Brightree or oandp.com. Our
latest warning letter stated that a physician was not an approved PECOS
physician, however Brightree and oandp.com both listed the physician as
qualified. Upon further checking, we discovered that the physician’s
name was not spelled correctly in the PECOS listing, but the physician
was an approved physician. The problem is that the national provider
identifier (NPI) listing by Medicare had the physician’s name correct,
but the PECOS list had the physician’s name spelled incorrectly. I can
show you where several names are not spelled correctly by PECOS and that
there are glaring inconsistencies with the spelling methodology and
keyed input used by PECOS. This is particularly true when an apostrophe
is part of a physician’s name.
I believe this will likely turn into a major nightmare for many of us
starting in January. You also know that Medicare will hold the O&P
providers responsible for this information and that the financial
consequences could be devastating for many of us. I personally believe
issues like these can rarely be solved by individual companies. Together
however, I am hopeful that we can get problems like this solved in a
reasonable period of time.
As an example of how I believe important issues can be solved, at the
end of this email I’ve appended text from a letter that is going to Ms.
Julie Boughn, Director of CMS. You can also see a copy of the letter at
this link: http://www.oandp-l.org/shared/oaagq.jpg. This letter in no
way guarantees a favorable reply from CMS. But at least it lets them
know that I intend to follow-up accordingly, based upon their review and
reply. This request is not unreasonable since CMS has evidently not
cross-checked their data and, at a minimum, have not properly proofed
the data that is being provided to providers.
At the first of next year, review of a private letter, such as the one
I’ve attached, this will only be available to those who are interested
in helping a group of us get to the bottom of some of the issues that so
greatly affect our livelihoods. This will likely be accomplished through
a controlled private website that will have some unique controls
incorporated. Our data, along with our efforts, will not be secret, but
sometimes information needs to be held a little closer to the chest than
our present venue can provide. I make no apology for not going to our
national associations first, although they will not be excluded from our
circle of “friends.” In fact, it may turn out that we create a new
alliance of folks who will have unprecedented influence in helping to
get our small O&P world turned right side up, once again.
Wil Haines, CPO
MaxCare Bionics
Avon, IN
Text of PECOS letter follows
November 23, 2010
Ms. Julie Boughn, Director
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244-1849
Dear Ms. Boughn:
I am writing to obtain information regarding the PECOS system which, as
I understand it, goes into effect on January 3, 2011. The database that
is being used by CMS is flawed with numerous errors. As such, CMS should
not go forward with the regulation in January until such time that the
database is corrected and a new corrected listing is published.
Furthermore, it is preposterous that the federal government is making
the official list of PECOS physicians available only in a PDF format
that is not readily search-able without expensive specialized software.
With more than 14,000 pages, the PECOS list, at a minimum, should be
made available in an indexed Excel or comparable database format. To put
it bluntly, the information technology folks at CMS are woefully
careless by their release of this data only in the present PDF format.
PDF in and of itself is fine, but not for companies who quickly want to
verify eligibility of PECOS physicians.
The decision that CMS is making regarding this matter has far reaching
financial implications for our company and for many other companies
around the country. Recently, we received warnings from Medicare Region
B stating that the physicians who wrote prescriptions for prosthetic
devices were not PECOS providers. Had these services been provided after
January of 2011, we would have suffered a complete financial loss for
the services rendered by us, even though the physicians were listed as
PECOS physicians by a company called Brightree and also by oandp.com.
The warning letter that we received most recently was on your claim
control number 10323803100000, dated November 18, 2010. Both Brightree
and oandp.com list this physician as a PECOS physician. Upon further
checking, we found that Medicare rejected this claim (warning only for
now) because the physician’s name has an apostrophe in it and the
official PECOS registry does not. The official government NPI registry,
however, does have the apostrophe in it. How can the government’s data
be inconsistent from one department to another? It is simply
unbelievable. I can sight dozens of names in the official PECOS registry
wherein a similar flaw in the data appears. This is not acceptable.
I am asking for an explanation from your office as to why there are
inconsistencies in the data from one federal department to another and
further why this cannot be corrected prior to implementing the PECOS
system. When may I expect the favor of your reply?
Thank you.
Sincerely,
Wilbur A. (Wil) Haines, CPO
President and Chief Executive Officer
cc: Honorable Senator Richard G. Lugar
Honorable Senator Evan Bayh
Honorable Congressman Steve Buyer
Honorable Congressman Mike Pence
