Author Topic: Medicare Re-enrollment and Billing Older Claims  (Read 4230 times)

Scott

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Medicare Re-enrollment and Billing Older Claims
« on: August 21, 2014, 07:24:47 PM »
Hi.  I have a new client who's prior biller failed to submit even 1 Medicare claim in a very long time - so long that Medicare recently dropped the provider.  I have two questions:

1) Should I be aware of any issues that Medicare will have in this situation?  I.e., will the provider have any problems reactivating?

2) Will Medicare allow me to rebill those older services that were technically rendered while he was still enrolled?  Or is he just out of luck?

Thanks so much for your help.

kristin

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Re: Medicare Re-enrollment and Billing Older Claims
« Reply #1 on: August 21, 2014, 09:01:15 PM »
1. I don't think the provider will have any problems reactivating, but I am not positive...have never dealt with that before.

2. Medicare has a 365 day timely filing limit, and they do not budge on it. Anything over 365 days is a loss.

Michele

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Re: Medicare Re-enrollment and Billing Older Claims
« Reply #2 on: August 22, 2014, 02:31:13 PM »
It depends on how much time has passed since they deactivated.  If you can reactivate then you can back bill until the number was deactivated howeve, as Kristin said, they won't go back over 365 days.
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PMRNC

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Re: Medicare Re-enrollment and Billing Older Claims
« Reply #3 on: August 22, 2014, 05:41:57 PM »
If Medicare deactivated I'm thinking claims are WAY past timely filing. 
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kristin

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Re: Medicare Re-enrollment and Billing Older Claims
« Reply #4 on: August 22, 2014, 06:14:48 PM »
That is exactly what I was thinking...and also wondering why the biller didn't bill the claims, and the provider didn't notice. It had to have been going on for more than a year.

Michele

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Re: Medicare Re-enrollment and Billing Older Claims
« Reply #5 on: August 22, 2014, 06:47:39 PM »
What amazes me is that this is not an unusual situation.  How do you not notice no Medicare payments for over a year??   :o
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kristin

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Re: Medicare Re-enrollment and Billing Older Claims
« Reply #6 on: August 22, 2014, 07:50:17 PM »
Right? I guess if the billings to Medicare are minimal, it could escape notice. But still...kind of odd. And unfortunately, as you say, not an unusual situation, although it should be, as far as I am concerned. You run a business, you stay on top of your income/cash flow.


PMRNC

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Re: Medicare Re-enrollment and Billing Older Claims
« Reply #7 on: August 23, 2014, 10:06:56 AM »
You also want to go and get a clear audit of those claims JUST in case... :o  I would do a report and audit of all Medicare patients. That could come back to bite you in the butt later.
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Scott

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Re: Medicare Re-enrollment and Billing Older Claims
« Reply #8 on: August 25, 2014, 12:23:26 AM »
I know.  When the dr told me I couldn't believe it.  I didn't want to say too much because I was trying to land the account, but I blame the dr as much as the biller.  He wasn't paying attention.   Provider was deactivated recently.  My goal is to bill as many of the claims as I can that are less than 365 days old, starting with oldest first.  What I don't know is if Medicare will allow it since the account is deactivated, even if I reactivate it.

PMRNC

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Re: Medicare Re-enrollment and Billing Older Claims
« Reply #9 on: August 25, 2014, 08:34:13 AM »
http://www.aapcps.com/news-articles/Timely-Medicare-Revalidation-May-Prevent-Deactivation-or-Revocation.aspx



Certain Changes Require Revalidation
Certain enrollment information changes, such as a change in practice location or a change in the special payments and correspondence address on file with Medicare, may affect timely compliance with revalidation requests. Medicare sends its revalidation letters and other correspondence to the special payment and correspondence address on file with Medicare. If a correspondence is returned to Medicare marked undeliverable, or if a provider does not respond to Medicare's request within the time specified in the notice, the provider's billing privileges will be deactivated or revoked.

Deactivation vs. Revocation
Deactivation of a provider's Medicare billing privileges is distinct from revocation of Medicare enrollment and billing privileges.

Deactivation is minor. Medicare may deactivate a provider's Medicare billing privileges if the provider does not report a change to the information supplied on the enrollment application within a specified time.

Significant changes include:

    a change in ownership or control (report within 30 days)
    a change in practice location (report within 30 days)
    a change in billing services (report within 90 days)
    a change in special payments and correspondence address (report within 90 days)

View the complete list of reportable changes. Additional information can be found in CFR, 424.520(b) and 424.550(b) (use your favorite online search engine to find Code of Federal Regulations, Section 424).

A provider's billing privileges will remain deactivated until the provider either:

    submits a new enrollment application (CMS 855); or
    when deemed appropriate, at a minimum, recertifies that the enrollment information currently on file with Medicare is correct. (The provider or supplier must meet all current Medicare requirements in place at the time of reactivation, and be prepared to submit a valid Medicare claim. Best practice is to contact your Medicare carrier for guidance.)

Claims for services from the date of deactivation to the date of reactivation may not be payable.

Revocation is far more serious. Revocation occurs for noncompliance, misconduct, felonies, falsifying information, and other such conditions set forth in 42 CFR, 424.535.

Revocation has devastating consequences for providers. According to CFR 424.535(a)(6)(i):

    Medicare payments will be halted and providers will be in limbo until the corrective action plan or request for reconsideration process is complete.
    The provider is barred from participating in the Medicare program from the effective date of the revocation until the end of the re-enrollment bar. What's worse, a provider may not receive the notice of revocation until months later and may continue to treat patients for a period of time, unaware that they will be forced to forfeit income when revocation is applied retroactively.
    Any provider agreement in effect at the time of revocation is terminated effective with the date of revocation.
    The re-enrollment bar is a minimum of one year, but not greater than three years, depending on the severity of the basis for revocation. (The re-enrollment bar may be waived if a provider is revoked based on failure to submit an application fee, or a hardship exception is requested with an enrollment application upon revalidation.)
    A provider or organization may be placed on the List of Excluded Individuals and Entities. (This will affect contracting with other government programs.)
Linda Walker
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Michele

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Re: Medicare Re-enrollment and Billing Older Claims
« Reply #10 on: August 25, 2014, 08:39:47 AM »
When they reactivate it is as if there was never an interruption in the provider's enrollment so yes, you can go back and rebill all claims under 365 days.
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PMRNC

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Re: Medicare Re-enrollment and Billing Older Claims
« Reply #11 on: August 25, 2014, 09:46:01 AM »
That's not what it says..

Nevertheless, the effect of the process that CMS has
instructed MACSs to follow denies the suppliers the right to bill
for services even though their Medicare Participation
Agreement remained in effect. Claims for services from the date of deactivation to the date of reactivation may not be payable.
42 CFR 424.540 (as adopted 71
Fed. Reg. 20776 (4/21/2006).
Linda Walker
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Michele

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Re: Medicare Re-enrollment and Billing Older Claims
« Reply #12 on: August 25, 2014, 10:02:28 AM »
I am basing my comments on our experiences.  We have had to reactivate several providers and they were allowed to bill all dates in between.  Not surprised that Medicare has one thing in writing but says another.  I haven't done one in a year or two so maybe they are not allowing that anymore.
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PMRNC

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Re: Medicare Re-enrollment and Billing Older Claims
« Reply #13 on: August 25, 2014, 10:12:16 AM »
It's possible they are allowing the MAC their own discretion? I've never had a deactivation at all. Maybe that's why it says "May not be covered".
Linda Walker
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Michele

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Re: Medicare Re-enrollment and Billing Older Claims
« Reply #14 on: August 26, 2014, 06:54:42 PM »
Maybe, not sure.   :)
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