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| July 16, 2010
To: RHC Community and Friends From: Bill Finerfrock Re: PECOS and CMS Deactivation – Important Information
NARHC has been working with the CMS enrollment staff to address this issue. Because many RHC providers do not submit individual Medicare claims, they would annually be faced with the deactivation problem. Yet, because of the new ordering/referring policy, these same RHC providers need to be enrolled in PECOS or the providers to whom they refer will not get paid at some point.
Yesterday, in response to our work (and some others as well), CMS released a new policy (see announcement below). Specifically, CMS is creating a new enrollment option for physicians, PAs, NPs, CNMs who work in RHCS who only need to enroll in PECOS for the purpose of ordering or referring. CMS had previously announced this option for physicians working in DOD or VA facilities and NARHC requested that the same option be made available to providers working in RHCs.
There are a couple of things you need to take note of with regard to the announcement below and the new policy:
1. Although the information below refers to “Physicians employed by Federally Qualified Health Centers (FQHCs), Rural Health Clinics (RHCs) or Critical Access Hospitals (CAHs)” the policy is also applicable to other RHC personnel (i.e. PAs, NPs, CNMs, etc.) who order or refer Medicare patients. 2. The abbreviated enrollment paper form available for physicians is NOT currently available for the non-physicians. CMS is still working out some unique technical issues in order to make this shortened version available to PAs, NPs, CNMs, etc. working in RHCs. 3. PAs, NPs and CNMs wishing to enroll for purposes of ordering or referring can use the on-line enrollment option but must complete all appropriate information. When you print out your certification statement for your signature, you should attach your ordering/referring letter to this certification document when you mail this to the appropriate contractor. The documents you can link to below will explain the letter and what it must say. 4. If an RHC provider enrolls in PECOS exclusively for the purpose of ordering or referring and subsequently leaves the RHC and wants to bill Medicare, the provider MUST re-enroll in PECOS in order to effectively rescind the letter indicating that he/she had been enrolled solely for the purpose of ordering or referring. 5. This information has been communicated to your RHC Medicare Contractor (MAC or FI). If you have questions or need any additional information, you are encouraged to contact the Contractor directly and the Contractor should be able to assist you. 6. In the “Special Enrollment Fact Sheet” linked below, you will find a link to a document that purportedly addresses some RHC/FQHC/CAH specific issues.
http://www.cms.gov/Transmittals/downloads/R328PI.pdf
Although this document is not RHC/FQHC or CAH specific as suggested, it does answer many of the questions you will have. We have brought this to the attention of the CMS staff and we are working with them to get this corrected. Again, even though the document does not specifically reference RHC personnel who only want to order or refer, the guidance provided in this transmittal is still relevant
NARHC is hopeful that this new option will be of help to the RHC community.
We continue to be in close contact with the CMS enrollment staff. Should there be a need for additional changes related to RHC providers, we will bring those to the attention of the CMS enrollment staff and see what can be done to fix any on-going RHC related problems.
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Medicare Enrollment Guidance for Physicians that Infrequently Receive Reimbursement from the Medicare Program
Traditionally, most physicians have enrolled in the Medicare program to furnish covered services to Medicare beneficiaries. However, with the implementation of Section 6405 of the Affordable Care Act, some physicians will need to enroll in the Medicare program for the sole purpose of certifying or ordering services for Medicare beneficiaries. These physicians do not send claims to a Medicare contractor for the services they furnish.
In the process of implementing the provisions contained in the Affordable Care Act, CMS has become aware of several unique enrollment issues for certain types of physicians or practitioners. Specifically, CMS modified the process of enrollment to accommodate the special circumstances of the following individual physicians and practitioners:
• Physicians employed by the Department of Veterans Affairs • Physicians employed by the Public Health Service • Physicians employed by the Department of Defense Tricare program • Physicians employed by Federally Qualified Health Centers (FQHCs), Rural Health Clinics (RHCs) or Critical Access Hospitals (CAHs) • Physicians in a Fellowship • Dentists, including oral surgeons
For details on the modifications to the enrollment process for these special circumstances, visit the Special Enrollment Fact Sheet for Physicians with Infrequent Reimbursements on the CMS website. Universal American Corp and Rural Health Clinics Join Forces
To Improve Care for Underserved Populations
Washington, DC, May 26, 2010– In announcing its historic partnership,Universal American Corp. (NYSE: UAM) and the National Association of Rural Health Clinics (NARHC) today remarked on their collaboration to deliver quality health care to our nation’s Medicare beneficiaries who live in rural communities through a coordinated care system embraced by their providers, noting “we wanted to marry the medical conveniences of living in a big city with the trust, comfort and neighborly support systems inherent to small towns and rural areas.”
What started as a friendly conversation about how best to accomplish this quickly materialized into a multi-year agreement to align resources and provide rural health clinics the ability to use Universal American’s model of care coordination, Healthy Collaboration, to better serve this population. Through Healthy Collaboration, members have an advocate looking at their continuum of care and ensuring they have access to the resources they need to stay healthy, including their doctors, hospitals, pharmacists and other healthcare professionals.
“Universal American already works with 50,000 seniors in rural communities around the country,” said Richard Barasch, Chairman and CEO of Universal American, “so this is not new terrain to us. We know what works and we have a successful track record using A Healthy Collaboration as the framework to provide the best level of care for our patients, regardless of their zip code. We’re excited to work more closely with rural health clinics. They have deep roots in communities across America and care for more than 7 million people every year. More importantly, we share a common goal: to provide a level of care coordination among providers that will best meet the needs of our seniors.”
Bill Finerfrock, Executive Director of the National Association of Rural Health Clinics said, “For too long, providers working in rural underserved areas have been on the outside looking in as innovative programs aimed at improving the quality of healthcare have been adopted and implemented in urban areas but been unavailable in rural underserved communities. Now, in collaboration with Universal American and the commitment they are making, we have an opportunity to bring the same types of quality, cost-effective programs typically available in urban areas, to patients residing in rural underserved communities served by federally certified Rural Health Clinics.”
Barasch noted that rural areas struggle with three primary obstacles when it comes to meeting their health needs: the need to drive long distances to receive care, health personnel shortages, and a lack of access to advanced technology.
“This partnership will address these and other barriers to care in tangible and specific ways,” said Barasch. “One example is Universal American’s initiative with Public Health Television (PHTv), which is a communications system geared for rural providers. It will allow them access to in-service training and educational programs, as well as the ability to dialogue on the latest aspects of advanced care delivery. Instead of expending time and resources to seek out such resources – or worse yet, go without – Healthy Collaborations brings it to them and makes it easy for them to use. It’s a win-win for everyone, especially beneficiaries.”
Finerfrock concurred. “Improving the care-delivery system in rural areas throughout the United States is of upmost importance to our members. If we didn’t believe that partnering with Universal American – including tapping its model of care coordination and know-how in building provider networks to best serve rural communities -- would not translate to profound and positive impacts on patient outcomes across our network of rural clinics, we wouldn’t have signed on the dotted line.”
The three-year partnership signed by Universal American, NAHRC and Public Health Television (PHTv) puts patients first. NAHRC will educate its clinics about Universal American’s Healthy Collaboration model; in turn, Universal American will provide education seminars and training programs to rural providers to ensure patients experience all the benefits Healthy Collaboration has to offer.
“This partnership enables us to offer the very model of care that was envisioned by policy makers in thinking through how best to meet the health care needs of Medicare beneficiaries,” added Barasch. “Our collaboration with the Rural Health Clinics and PHTv and our provider partners on the ground will translate into improved wellness and enhanced quality of care for seniors in rural areas, as well as lowered healthcare costs overall.”
About NARHC
The National Association of Rural Health Clinics (NARHC) is non-profit national organization dedicated exclusively to improving the delivery of quality, cost-effective health care in rural underserved areas through the Rural Health Clinics (RHC) Program. The Rural Health Clinics program was begun in 1977 (Public Law 95-210) and is the oldest federal program aimed at improving access to healthcare in rural underserved areas. RHCs rely upon a team approach to the delivery of quality, cost-effective healthcare using physicians, physician assistants and nurse practitioners. There are more than 3,400 federally certified RHCs located in rural communities designated by either the federal or state government as underserved.
About Universal American Corp.
Universal American (NYSE: UAM), through our family of healthcare companies, provides health benefits to more than two million people with Medicare every day. We are dedicated to working collaboratively with healthcare professionals in order to improve the health and well-being of our members. Universal American is a Fortune 500 company and the third largest Medicare plan sponsor in the nation.
About Public Health Television (PHTv)
PHTv is a private media network that uses internet protocol television (IPTV) technology to reach underserved populations with targeted, culturally and linguistically appropriate programming. Public Health Television is installed in the reception areas of federally certified rural health clinics (RHCs), federally qualified community health centers (FQHCs) and critical access hospitals. The network effectively reaches patients / viewers at the point-of-care with targeted health education, wellness and lifestyle programming that can improve health outcomes and ultimately reduce healthcare spending. For informationwww.publichealthtelevision.com
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