Can you retroactively bill Medicare after credentialing is complete?

Answer: The short answer is Yes, but there are some specifics that you need to be aware of. Retroactively billing Medicare is critical for most organizations as providers often start without having a Medicare number. This is in large part due to how long the provider enrollment process takes with Medicare. Your retroactive period begins once an application has been submitted but the application submitted must be approved. If the application is denied due to incomplete data or rejected because a provider doesn’t meet Medicare standards, you will lose the retroactive billing date and must start the application process over. This is why it’s so critical to stay on top of the Medicare enrollment process and ensure your application is processed without any issues. If mailing anything to Medicare, be sure to send certified and keep a copy of the tracking certificate.

Do I need to submit the claims with a special modifier?

Answer: No, you would submit the claims the same way you would any other time. You would code the visit the same way you would if you were already participating.

Do I have to worry about timely filing guidelines for retroactive billing?

Answer: For Medicare claims, the timely filing rules are waived during the enrollment period as they understand that the application is in process. It’s possible that you would receive a denial and need to submit documentation including your approval letter from Medicare, but this is rare. Make sure to keep copies of all approval letters and applications.

Here is an excerpt from one of the Medicare administrator websites:

The effective date is the later of the following two dates:

• The filing date of an enrollment application that was subsequently approved, or

• The date the provider first began furnishing services at a new practice location.

The provider may bill retrospectively for services when:

• The supplier has met all program requirements, including state licensure requirements, and

• The services were provided at the enrolled practice location for up to

1. 30 days prior to their effective date if circumstances precluded enrollment in advance of providing services to Medicare beneficiaries, or

2. 90 days prior to their effective date if a presidentially-declared disaster precluded enrollment in advance of providing services to Medicare beneficiaries.

Example:

Suppose that a non-Medicare enrolled physician began furnishing services to beneficiaries at her office March 1. She submitted the CMS-855I initial enrollment application May 1, and the application was approved June 1. The physician’s effective date of enrollment would be May 1, which is the later of: (1) the date of filing, and (2) the date she began furnishing services. The retrospective billing date is April 1 (or 30 days prior to the effective date of enrollment).

Source: https://medicare.fcso.com/faqs/answers/268685.asp