Practice Management Alert

Question: I work for a billing service for a hospitalist program where the physicians bill under their own tax identification number (TIN). The group brought in new physicians who provided services to Medicare patients without informing us. We discovered the fact 45 days later. We started the credentialing process right away, but can we still submit retroactive bills?

New Jersey Subscriber

Answer: Unfortunately, you have only 30 days to submit a retroactive bill, according to CMS guidelines.

Under normal circumstances, you can retroactively bill Medicare for services your physician rendered up to 30 days prior to the date of filing an approved Medicare enrollment application.

If you file using Provider Enrollment, Chain, and Ownership System (PECOS), you have 30 days from the day you submitted the enrollment application to the Medicare carrier (the date the enrollment department receives your signed certification). If you file a paper application, the filing date is the day the carrier receives your application in the mail.

If you miss the deadline, you cannot bill Medicare beneficiaries, so you would likely have to write off the balance.

Bright spot: You may have some recourse,however. You could contact your carrier's enrollment department and explain the situation. There may be extenuating circumstances for which they will extend the deadline, but those exceptions are not in writing.