Medicare: Delays, Documentation, and an Update Reminder

These tips can help you get your Medicare revalidation application approved with the minimum delay possible, be prepared if Medicare asks for ordering/certifying documentation, and stay on top of claim adjustment reason codes and remittance advice remark codes.

 Medicare Revalidation Delays

Novitas Solutions reports it is experiencing delays in processing revalidation applications, with an average processing time of 100 calendar days. However, no punitive actions will occur (i.e., deactivation of billing privileges) as a result of delayed processing, the payer says. Novitas expects to complete processing of Phase 3 revalidation applications by the end of 2015. All Phase 3 revalidation requests were mailed by March 18, 2015.

 Follow these steps to make sure you remain enrolled in the Medicare system with the minimum delay possible.

Don't Toss Out Ordering/Certifying Documentation

Medicare requires physicians who order or certify durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS); clinical laboratory services; imaging services; or home health services to maintain documentation of their action for seven years after the date of service and, upon request of the Centers for Medicare & Medicaid Services (CMS) or a Medicare contractor, to provide access to that documentation.

In a recent article, CMS clarified that each physician is individually responsible for maintaining these records and providing them upon request.

"CMS recognizes that providers and suppliers often rely upon an employer or another entity to maintain these records on their behalf. However, it remains the responsibility of the individual or entity upon whom/which the request has been made to provide documentation," the article said.

The consequence of noncompliance may be revocation of Medicare billing privileges.

Documentation that practices need to maintain includes written and electronic documents (including the National Provider Identifier of the ordering/certifying physician) relating to written orders, certifications, and requests for payments for DMEPOS items and clinical laboratory, imaging, and home health services.

Mind Your CARCs and RARCs

Changes in claim adjustment reason codes (CARCs) and remittance advice remark codes (RARCs) usually come in conjunction with a Medicare policy change and thus can be important sources of current billing and coding information. CARCs indicate why a claim or service line was paid differently from how it was billed. RARCs typically provide additional explanation for an adjustment already described by a CARC. The codes are updated three times per year.

CMS published a list of recent CARC and RARC additions, modifications, and deactivations in MLN Matters No. MM9125. The Washington Publishing Company maintains a complete, definitive list of CARCs and RARCs on its website.

If your billing staff uses the Medicare Remit Easy Print or PC Print software, be sure to stay current with software updates so you can access current CARC and RARC information.

If you have questions about coding or billing, contact the TMA Knowledge Center at (800) 880-7955 to reach a TMA expert. Visit TMA's Medicare Resource Center for Medicare information and resources.

 Also note: Attend the 2015 Novitas Solutions Medicare Symposium and get all your Medicare questions answered by Novitas staff! Registration is open for sessions in Austin on Aug. 5 and in Frisco on Nov. 5.

Published May 27, 2015

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Last Updated On

May 13, 2016

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