CMS Announces Intent to Change the Date for Rejecting Claims Containing Ordering/Referring NPIs Lacking an Enrollment Record in PECOS to July 6, 2010

In the May 5, 2010 Federal Register, 42 CFR Parts 424 and 431, CMS announced that the implementation of the requirement to be enrolled in the Medicare program with an approved enrollment record in the Provider and Supplier enrollment in the Provider Enrollment Chain and Ownership System (PECOS) may be moved from January 3, 2011 to July 6, 2010, pending any changes resulting from the comment period. 
To summarize, effective July 6, the Interim Final Rule requires:

  1. Providers with a National Provider Identifier (NPI) must include it on their Medicare and Medicaid enrollment applications and claims.
  2. Providers of medical items/other items/services and suppliers that qualify for a National Provider Identifier (NPI) must include their NPI on all applications to enroll in the Medicare and Medicaid programs AND on all claims for payment submitted under the Medicare and Medicaid programs.
  3. The ordering/referring supplier must be a physician or an eligible professional with an approved enrollment record in the PECOS thus changing the previously reported January 3, 2011 date given by CMS.
  4. Claims that do not meet these requirements will be rejected by Medicare contractors after July 6, 2010.

Medicare contractors shall initially process the claim and add remark messages (RARC codes) N264 (missing/incomplete/invalid ordering physician provider name) and N265 (missing/incomplete/invalid ordering physician primary identifier) to the remittance advice if the ordering/referring provider is not found on the PECOS file.
Comments on this IFC will be accepted through July 6, 5 p.m. ET. See the interim final rule  for commenting instructions.

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