The Patient Protection and Affordable Care Act (PPACA), signed into law March 23, 2010, establishes new timely filing provisions for filing Medicare fee-for-service (FFS) claims (including Medicare Part A and Medicare Part B services), which could significantly affect health care providers.

Under the new law, claims for services furnished on or after January 1, 2010, must be filed within one calendar year of the date of service.  The law also mandates claims for services furnished before January 1, 2010, must be filed by December 31, 2010.

Claims with dates of service before October 1, 2009, must follow the pre-PPACA timely filing rules, which allowed claims for services furnished during the first nine months of a calendar year to be filed on or before December 31 of the following year.  Claims for services furnished during the last three months of a calendar year were to be filed on or before December 31 of the second following year.  Claims with dates of service October 1, 2009, through December 31, 2009, must be submitted by December 31, 2010.

Examples include:

• A claim with dates of service from September 1, 2009, through September 27, 2009, must be submitted by December 31, 2010.
• A claim with dates of service from November 3, 2008, through November 20, 2008, must be submitted by December 31, 2010.
• A claim with dates of service from November 3, 2009, through November 20, 2009, must be submitted by December 31, 2010.
• A claim with dates of service from February 4, 2010, through February 28, 2010, must be submitted by February 28, 2011.

Although PPACA does allow for very limited exceptions to the one-year filing deadline, as a practical matter, fee-for-service providers should plan to file all claims with pre-January 2010 dates of service by December 31, 2010.

BKD can assist skilled nursing facilities, home health agencies and hospice providers with accounts receivable analysis and recovery.  The firm also can provide billing outsourcing services; we have successfully assisted numerous providers with collection of aged third-party accounts receivable balances.

For further information or assistance, please contact your BKD advisor.