In late January 2023, the Centers for Medicare and Medicaid Services (CMS) issued two updates relevant to provider and supplier organizations enrolled in Medicare: (1) a redesign to the Provider Enrollment, Chain and Ownership System (PECOS) with several new features intended to ease the initial application and administrative upkeep of Medicare enrollments; and (2) CMS expects providers and suppliers to confirm that their ownership information is consistent for all enrollment records under a particular Tax Identification Number (TIN). CMS also added revised standardized nondiscrimination language to three newly renewed and required hospital notices to beneficiaries.
1. PECOS REDESIGN
The PECOS redesign (PECOS 2.0) aims to simplify provider and supplier enrollment in several ways:
- Applicants will be able to enroll in multiple states or update information across multiple enrollments with a single application.
- PECOS 2.0 will use pre-existing information to complete enrollments faster.
- The enrollment application will adapt based on the application reason.
- More efficient management of group members with the easy addition and removal of members as well as the option to download the complete list of group members.
- An easier revalidation process with reminders for renewal due dates and more clear signposting of information that the applicant needs to review and confirm.
- More rapid application processing through a smart error-checking feature that will validate information throughout the application process.
- Real-time status checking for submitted applications in one view.
According to the published PECOS FAQs, the redesign should not interrupt PECOS availability for an extended period of time and PECOS users can expect access to a robust Knowledge Base interface that will teach users how to navigate PECOS 2.0. Login information, current Medicare Administrative Contractors and current data in PECOS will remain the same and transfer to PECOS 2.0. Records transferred from the existing PECOS to PECOS 2.0 will be noted as such to make them easily identifiable. Applications that were previously closed in PECOS will be available in PECOS 2.0 but will include only limited information. It is unclear at this time what information will and will not transfer over from previously closed applications.
CMS expects to launch PECOS 2.0 in June 2023 and will provide regular updates on the PECOS redesign over the coming months through Medicare Learning Network® announcements.
2. CONSISTENT ENROLLMENT INFORMATION UNDER TIN
In a push to ensure consistency in provider and supplier ownership information in Medicare enrollment records under a single TIN, CMS will send a letter to each provider or supplier that has inconsistent ownership information. The letter will explain that CMS will apply the ownership information from the most recent Medicare enrollment application with an ownership change to all of the enrollment records registered under the provider or supplier’s TIN. If the information in the letter from CMS is correct, then the provider or supplier does not need to do anything further. If the information in the letter from CMS is incorrect, then the provider or supplier must update each of its individual enrollments. Going forward, CMS will apply owner changes to all enrollment records under a particular TIN.
This push for consistency in enrollment information together with the PECOS redesign aligns with CMS’s efforts to promote and practice data transparency, including making enrollment data, such as ownership information, public and subject to increased CMS—as well as third-party—review and scrutiny.
3. UPDATE TO BENEFICIARY NOTICES INITIATIVE
The CMS Office of Management and Budget approved the following hospital-required notices and instructions for renewal:
- Important Message from Medicare, Form CMS 10065
- Detailed Notice of Discharge, Form CMS 10066
- Medicare Outpatient Observation Notice, Form CMS-10611
In their renewed iteration, CMS added revised standardized nondiscrimination language and kept all other information the same. More specifically, the notices listed above have been updated with the addition of the following statement: “You have the right to get Medicare information in an accessible format, like large print, Braille, or audio. You also have the right to file a complaint if you feel you’ve been discriminated against. Visit Medicare.gov/about-us/accessibility-nondiscrimination-notice or call 1-800-MEDICARE (1-800-633-4227) for more information. TTY users can call 1-877-486-2048.” This updated language supports transparency in beneficiary rights and protections and furthers CMS’s efforts to reduce beneficiary confusion regarding admission, discharge and observation status.
These three updated notices and instructions can be found on the CMS Beneficiary Notices Initiative webpage. Hospitals must use the new forms and instructions starting April 27, 2023.
Benjamin Glass, a law clerk in the New York office, also contributed to this article.