![]() ![]() As proposed, the extended time limit begins when the error or misrepresentation is corrected, without apparent regard to whether the physician is aware of that fact. Consistency with PPACA would suggest that the time to file a claim under each exception should be extended through the last day of the 12th month following the month in which the exception applies.Īlso, as regards the exception due to error or misrepresentation on the part of Medicare, one would think the extended time limit should be based on the month in which the error or misrepresentation is corrected and the physician has been notified of that fact. However, in the exceptions proposed by Medicare, the physician only has six months to file a claim after he or she becomes aware of Medicare’s responsibility. The PPACA provision essentially provides physicians and others with a 12-month period in which to file claims for services for which they have reason to believe Medicare may be responsible. However, one has to question why CMS is only granting six months for the extended time limit that it proposes for each exception. CMS does not propose to define “date of service” and instead intends to provide “sub-regulatory” guidance on what constitutes the date of service for different services.ĬMS's proposals are generally consistent with PPACA, and the proposed additional exceptions are welcome. However, no extension of time will be granted when the request for this particular exception is made to CMS or one of its contractors more than four years after the date of service, consistent with current CMS policy. In the case of the second new exception, the time to file a claim would be extended through the last day of the 6th calendar month following the month in which the state Medicaid agency recovered the Medicaid payment for the furnished service from the provider or supplier.įor the existing exception, the extension of time is the last day of the 6th calendar month following the month in which the error or misrepresentation is corrected. In the case of the first new exception, the time to file a claim would be extended through the last day of the 6th calendar month following the month in which the beneficiary received notification of Medicare entitlement effective retroactively to or before the date of the furnished service.
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