Greater Houston Radiology Associates, P.A.--TX

Document ID: CMS-2010-0187-0003
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: May 13 2010, at 12:00 AM Eastern Daylight Time
Date Posted: August 10 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: May 5 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: July 6 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80aeccfd
View Document:

This is comment on Rule

Medicare and Medicaid Programs: Changes in Provider and Supplier Enrollment, Ordering and Referring, and Documentation Requirements, etc.

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I am the Practice Administrator for Greater Houston Radiology Associates in Houston TX. We submit claims to government health plans under CMS rules. The changes announced by CMS, regarding the Patient Protection and Affordable Care Act (Affordable Care Act or PPACA) has provisions to move the effective date requiring all provider to enroll in PECOS to July 6, 2010, only weeks away. The effective date was to be January 3, 2011, previously announced by CMS. COMMENT: Per PPACA, If a referring provider is not enrolled in PECOS, the provider performing the service for which a patient is referred will not be paid. As hospital based radiologists, 100% of our services are referred. We have no way within the short time left to inform and verify that referring providers are enrolled in PECOS. IMPACT: Huge reduction in payments, the possibility of missing filing deadlines with insurance plans, and the Patient will not be protected. Providers such as our group will not be practicing -- no income, no payroll, no ability to maintain services for patients. Please rescind the July 6 deadline and revert to the original January 3, 2011 start date. We must verify that the referring doctors have enrolled in PECOS so that all concerned will be paid.