December 2009 Client NewsletterHOLIDAY SCHEDULE
CPB will be closed at 1:00 on Christmas Eve, Christmas Day and New Years Day. We hope you enjoy the holidays! We will also close at noon on Wednesday, December 2nd for our Annual Employee Appreciation Day.
AUDITS â€“ PRE-PAYMENT, CERT OR RAC
If you receive an audit request, whether prepayment, CERT, or RAC, we suggest that you notify CPB immediately before responding and let us look at the documentation to ensure it is complete. It is far better to make sure it is right the first time than to have the money taken back (or not paid) then file an appeal. Plus, a timely response is required or the claim is also denied for lack of documentation.
2010 PART B DEDUCTIBLE
The Centers for Medicare & Medicaid Services (CMS) announced the Part B annual deductible for 2010 is $155.00 (it was $135 in 2008 & 2009). With the poor economy, it is more important than ever to make every effort to collect all co-pays, deductibles (if known), and co-insurances on the date of service. The key is getting the payment before they receive your services, or at worst, before they leave your office.
Also, just a reminder that cash flow will be slow for the first 2-3 months of the year due to the current economy and patients showing greater reluctance to visit their physicians.
2010 MEDICARE PHYSICAL, OCCUPATIONAL & SPEECH THERAPY CAP
The Therapy Cap for 2009 is $1,860 through December 31, 2010. However, the Medicare Cap Exceptions process for independently practicing physical, speech and occupational therapists does not appear to have been extended beyond December 31, 2009. A copy of the CMS article has been included for our PT/OT clients.
Medicare PROVIDER Participation Status
As you are probably aware the current Medicare Fee Schedule is set to decrease by 21% unless Congress acts to change it. One option that providers have is to change from participating to non-participating status. If you wish to consider becoming non-par due to the potential fee decrease and, for physician, the elimination of consults, it can be done until 1/31/10. Call me if you want to discuss financial ramifications. Non-par status offers about a 9-10% increase in what patients can be charged compared to the par fee schedule. There are some caveats to consider and patients will need to be notified ASAP.
NEW PROVIDER ENROLLMENT REQUIREMENTS FROM CMS â€“ DATE CHANGE
Effective October 1, 2009 CMS is expanding the claim editing requirements in claims for ordering/ referring physicians for DMEPOS products and services. The claim editing is being added to verify that the ordering/referring provider on a claim is eligible to order/refer and is enrolled in Medicare by comparing enrollment in Medicare's PECOS software. This affects both physician and nonphysician practitioners. Until April 5, 2010 this will only be a warning but after that date if the ordering/referring provider is not on the national PECOS file, claims will not be paid.
A partial list of providers who can order/refer are:
Doctor of Medicine or Osteopathy;
Certified Clinical Nurse Specialist;
Clinical Psychologist; and
Clinical Social Worker.
We strongly advise that you verify you are current on the PECOS database as soon as possible since we fully expect long delays getting approved after January 1. To verify with PECOS that you are setup, you can call 866-484-8049. If you filed a new enrollment application and were approved within the last two years or so, you should be fine. If not, and you are the ordering or referring physician for any DMEPOS provider (including your own claims), after January 4 that provider will not be paid.
To login to PECOS, use your NPI user name and password. Go to:
https://pecos.cms.hhs.gov/pecos/login.do on the CMS website.
Providers can read the educational material about Internet-based PECOS that is available at
Once at that site, scroll to the â€œDownloadsâ€ section of that page and click on the materials that apply to you and your practice.
RED FLAG RULES DELAYEd AGAIN!
As announced by the FTC on November 2, 2009:
â€œAt the request of Members of Congress, the Federal Trade Commission is delaying enforcement of the â€œRed Flagsâ€ Rule until June 1, 2010, for financial institutions and creditors subject to enforcement by the FTC.â€
Also in the same announcement:â€œOn October 30, 2009, the U.S. District Court for the District of Columbia ruled that the FTC may not apply the Red Flags Rule to attorneys.â€