Optometry Coding & Billing Alert

Published on Tue Jan 27, 2009 PDF

CMS institutes a 30-day billing window for 2009.

New optometrists just lost 26 months of billing privileges, as of January 1.

You'll be able to retroactively bill Medicare for services an optometrist rendered up to 30 days prior to the date he received his Medicare credentialing status, according to the 2009 Medicare Physician Fee Schedule. Medicare will consider the optometrist's effective credentialing date as the "date of filing," according to the Fee Schedule -- meaning "the date that the Medicare FFS [fee-for-service] contractor received a signed provider enrollment application that the Medicare FFS contractor is able to process to approval" (emphasis added). So make sure the application is complete, and submit any additional information the contractor requires for enrollment.

That's a huge difference from the 2008 rules, which gave you a full 27-month window during which you could retroactively bill. Despite several comments from medical practitioners requesting more than the allotted 30 days, CMS stood firm in its decision.

For example: Suppose your practice hires a new optometrist who recently applied for Medicare status but has not yet received his credentials. He sees several patients each day over a three-month period, at the end of which he receives his credentials.

Outcome: You'll only be able to retroactively bill for the work the optometrist performed during the final 30 days prior to his credentialing. The other two months of work will not be billable.

"You can no longer just bill Medicare while waiting for your credentialing approval, unless the services were performed 30 days prior to the Medicare approval," says Barbara J. Cobuzzi, MBA, CPC-OTO, CPC-H, CPC-P, CPC-I, CHCC, president of CRN Healthcare Solutions. "And you have no way of knowing when your approval will happen; it's a guessing game."

Fast forward: If you've seen credentialing drag on for months, you may benefit from a new government program.

You may be able to speed up your credentialing by using the Provider Enrollment, Chain, and Ownership System (PECOS) system, says Quinten A. Buechner, M.S., M.Div., CPC, ACS-FP/GI/PEDS, PCS, CCP, CMSCS, with ProActive Consultants.

PECOS is currently established in 44 states and Washington D.C., and CMS says it cuts enrollment time to half of what it was with paper enrollment. For more information, visit https://pecos.cms.hhs.gov.

To review the fee schedule and learn how to submit comments, visit the CMS Web site at www.cms.hhs.gov/physicianfeesched/downloads/CMS-1403-FC.pdf.