NCPA has submitted comments to the Centers for Medicare and Medicaid Services regarding its interim final rule for the Internet-based Provider Enrollment, Chain and Ownership System (PECOS) program, an electronic system that can be used in lieu of the Medicare paper enrollment application. Community pharmacies that sell Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS), including items such as diabetes testing strips, are required to verify provider/referrer enrollment prior to receiving Medicare reimbursement. NCPA's comments detail the PECOS program's current shortcomings and offer constructive solutions to help ensure that the PECOS transition does not disrupt patients' access to DMEPOS products at their independent community pharmacies.

"Community pharmacies appreciate and support the PECOS program's effort to reduce waste, fraud and abuse in Medicare," said Douglas Hoey, RPh, NCPA acting executive vice president and CEO. "However, the slow pace of enrollment and database updates, along with other deficiencies, creates headaches for community pharmacies and could limit access to Medicare Part B medical supplies for seniors, especially in underserved areas. That's why NCPA offered five recommendations that could strengthen the implementation process." They are:

• Delay the implementation of the Phase 2 PECOS edits and administrative review and recoupment of PECOS-based claim rejections until at least Jan. 3, 2011.
• Require pharmacy access to nightly provider/referrer enrollment updates to PECOS.
• Develop more granular common electronic data interchange (CEDI) error codes for pharmacists to identify and resolve Part B claims denials.
• Allow one year for Part B suppliers to re-bill claims denied due to PECOS edits.
• Remove requirements to include the teaching physician as the ordering or referring supplier and the legal name of the physician or eligible provider on the claim.