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Medicare Timely Filing Exceptions

The Medicare regulations at 42 Code of Federal Regulations (CFR), Section 424.44, specify the time limits for filing Part A and Part B Fee-For-Service claims. Section 424.44 also identifies certain exceptions to the claims filing time limit. If the requirements for satisfying a timely filing exception are met, an extension to file the claims may be granted.

Section 6404 of the Affordable Care Act reduced the maximum period for the submission of all Medicare Fee-For-Service claims to no more than 12 months, or one calendar year, after the date a service is furnished. Section 6404 also gave the Secretary of Health and Human Services the authority to create exceptions to the 12 month timely filing limit.

The Medicare Claims Processing Manual currently requires that, in order to be granted a timely filing extension, the provider, supplier, or beneficiary must furnish an official letter from the Social Security Administration (SSA) to the beneficiary in order to meet one of the conditions that the beneficiary was retroactively entitled to Medicare on or before the date of the furnished service.

Change request (CR) 7834 revises sections of the manual to specify that, if an official SSA letter to the beneficiary is not submitted, Medicare contractors must check the common working file (CWF) database and may interpret the CWF data in order to verify that the beneficiary was retroactively entitled to Medicare on or before the date of the furnished service.

Contractors may interpret the CWF data in order to verify retroactive Medicare entitlement that may permit a claim to be processed after the 12-month timely filing limit.

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