Checklist for Timely Filing Extension

Published 09/23/2021

In accordance with Medicare guidelines, Medicare systems will reject/deny claims that are not received within one year from the date of the service. When a claim is denied for having been filed after the timely filing period, such denial does not constitute an 'initial determination'. As such, the determination that a claim was not filed timely is not subject to appeal, and redetermination requests for timely filing denials will be dismissed. Therefore, providers should not submit a request for a redetermination to the Appeals department.

There are four exceptions where providers can request an extension on the time limit for claims:

Administrative Error

  • Failure to meet the filing deadline was caused error or misrepresentation of an employee, the Medicare contractor or agent of the Department of Health and Human Services (DHHS) that was performing Medicare functions and acting within the scope of its authority
  • In these cases, Medicare will extend the timely filing limit through the last day of the sixth month following the month in which the beneficiary, provider or supplier received notice that an error or misrepresentation was corrected

Retroactive Medicare Entitlement

  • Beneficiary receives notification of Medicare entitlement retroactive to or before the date the service was furnished
  • In these cases, Medicare will extend the timely filing limit through the last day of the sixth month following the month in which the beneficiary, provider or supplier received notification of Medicare entitlement retroactive to or before the date of the furnished service

Retroactive Medicare Entitlement Involving State Medicaid Agencies

  • A state Medicaid agency recoups payment from a provider or supplier six months or more after the date the service was furnished to a dually eligible beneficiary
  • In these cases, Medicare will extend the timely filing limit through the last day of the sixth month following the month in which a state Medicaid agency recovered Medicaid payment from a provider or supplier

Retroactive Disenrollment from a Medicare Advantage (MA) Plan or Program of All-inclusive Care of the Elderly (PACE) Provider Organization

  • A beneficiary was enrolled in an MA plan or PACE provider organization, but later was disenrolled from the MA plan or PACE provider organization retroactive to or before the date the service was furnished, and the MA plan or PACE provider organization recoups its payment from a provider or supplier six months or more after the date the service was furnished
  • In these cases, Medicare will extend the timely filing limit through the last day of the sixth month following the month in which the MA plan or PACE provider organization recovered its payment from a provider or supplier

Written Request for a Timely Filing Extension
When evidence supports one of the above criteria exists, providers may submit a written request for an extension. Each provider request for exception will be evaluated individually based on the evidence submitted with the request.

Requests for a timely filing exception must be submitted to Railroad Medicare in writing. We encourage you to use the Railroad Medicare Provider Contact Center-Written Inquiry Form (PDF, 367 KB). Palmetto GBA eServices portal users can submit a request online using the Provider Contact Center General Written Inquiry Request eForm.

The request must contain the following elements:

  • If submitted on the provider’s letterhead, the address on the company letterhead must match the address in the provider’s Railroad Medicare enrollment record
  • The provider’s Provider Transaction Access Number (PTAN)
  • The provider’s National Provider Identifier (NPI)
  • The last five digits of the provider’s Federal Tax Identification (ID) number
  • Beneficiary’s name
  • Beneficiary’s Medicare number
  • Dates of service for the claim(s) in question
  • Supporting evidence (see below for acceptable examples)

Fax written requests and supporting evidence to (803) 264–9844 or mail to the following address:

Palmetto GBA Railroad Medicare
Provider Contact Center
P.O. Box 10066
Augusta, GA 30999

Examples of Supporting Evidence

Administrative Error

  • Written report by the agency (Medicare, Social Security Administration (SSA), or Medicare Administrative Contractor (MAC)) based on agency records, describing how its error caused failure to file within the usual time limit
  • Copy of an agency (Medicare, SSA, or MAC) letter reflecting an error
  • Written statement of an agency (Medicare, SSA, or MAC) employee having personal knowledge of the error
  • Palmetto GBA Claims Processing Issues Log (CPIL) article showing the system error
  • There must be a clear and direct relationship between the administrative error and the late filing of the claim(s)
  • Note: The provider must demonstrate that they submitted the claim within six months after the month in which they were notified that the system error was corrected

Retroactive Medicare Entitlement

  • Copy of an official Railroad Retirement Board (RRB) letter notifying the beneficiary of Medicare entitlement and the effective date of the entitlement
  • Retroactive Medicare Entitlement Involving State Medicaid Agencies;
  • Copy of a state Medicaid agency letter reflecting retroactive disenrollment; and 
  • Proof of Medicaid recoupment of a claim

Retroactive Disenrollment from a MA Plan or PACE Provider Organization

  • Copy of an MA plan or PACE provider organization letter reflecting retroactive disenrollment, and
  • Proof of MA plan or PACE provider organization recoupment of a claim
  • Note: Each provider request for exception will be evaluated individually based on the evidence submitted with the request. 

Reference: IOM Publication 100-04, Medicare Claims Processing Manual, Chapter 1 (PDF, 4.25 MB), Section 70.7.