Phase Two Edits - Temporarily on Hold

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Explore:  CMS Medicare PECOS

In its April 25, 2013 Medicare FFS Provider e-News, CMS announced that due to “technical issues” it would be delaying the implementation of the Phase 2 claims edits. This is the CMS initiative where claims for certain defined services would result in claim denials if the ordering or referring physician or non-physician practitioner did not have an enrollment record in PECOS or had not validly opted out of Medicare. CMS noted it would advise providers of the new Phase 2 implementation date in the near future.

Prior to CMS’ announcement of the implementation delay, two associations attempted to block this CMS initiative. On March 13, 2013, the Association of American Physicians & Surgeons, Inc. and the Alliance for Natural Health USA filed an emergency motion [PDF] for injunctive relief urging the court to stop the May 1, 2013 implementation of the Phase 2 edits. On April 17, 2013, the United States Circuit Court for the District of Columbia denied the motion.

For more information about the two-phase claims edit initiative, refer to the March 21, 2013 Payment Matters article, "Ordering / Referring Phase 2 Begins May 1st - Claims Will Be Denied."

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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