Eli's Rehab Report

Heads up, outpatient rehab providers in private practice: You should think twice before you bill for services retroactively. Reason? The 2009 Medicare Physician Fee Schedule Final Rule dramatically changes the effective date of enrollment for individual therapists or therapy groups acquiring Medicare enrollment status.

Historically, individual practitioners and therapy group practices could retroactively submit Part B Medicare claims for services rendered up to 27 months prior to being enrolled in the Medicare program. But as of Jan. 1, 2009, that 27-month period disappears, according to the final rule.

"You can no longer just bill Medicare while waiting for your credentialing approval, unless the services were performed 30 days prior to the Medicare approval," says Barbara J. Cobuzzi, MBA, CPC-OTO, CPC-H, CPC-P, CPC-I, CHCC,president of CRN Healthcare Solutions in Tinton Falls, N.J. "And you have no way of knowing when your approval will happen; it's a guessing game."

In the MPFS final rule, the Centers for Medicare & Medicaid Services established the initial enrollment date as: "1) the date of filing of Medicare enrollment application that was subsequently approved by the contractor; or 2) the date an enrolled supplier first started rendering services at a new practice location," according to the Nov. 7 edition of PT Bulletin Online, the American Physical Therapy Association's weekly newswire. "The date of filing is the date that the Medicare contractor receives a signed provider enrollment application that the Medicare contractor is able to process to approval," the Bulletin continues.

Careful: You may not, however, want to bank on a 30-day grace period. Some experts interpret the MPFS final rule as saying that CMS will grant a 30-day grace period only for a few special cases, such as when a physician has to do emergency room treatment. (See page 69768 of the final rule, at http://edocket.access.gpo.gov/2008/pdf/E8-26213.pdf,pages69766-69783.)