Effective Billing Date Determination

The Centers for Medicare & Medicaid Services' (CMS) instructions for determining the effective billing date on Medicare enrollment applications differ, depending on the specialty of the provider submitting the enrollment application.

  1. For physicians, physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists, certified nurse midwives, clinical social workers, clinical social workers, clinical psychologists, registered dietitians/nutrition professionals, and organizations/group practices of these individuals:

    The effective billing date is the later of the filing date, i.e., the date the application is received in our office, or the date the physician or non-physician practitioner began furnishing services at the practice location. Retrospective billing is allowed prior to the filing date only if the provider has met all Medicare program requirements and the services were provided at the enrolled practice location for up to:

    • 30 days prior to the filing date if circumstances precluded enrollment in advance of providing services to Medicare beneficiaries; or,
    • 90 days prior to the filing date if a Presidentially declared disaster under the Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. §5121-5206 (Stafford Act) precluded enrollment in advance of providing services to Medicare beneficiaries.

    Example 1: Dr. X established a new practice on February 15, 2012, and his application was filed on February 1, 2012. The effective billing date is February 15, 2012. There is no period of retrospective billing because the filing date was prior to the beginning date of the practice, and the effective billing date cannot be prior to the date the provider began furnishing services.

    Example 2: Dr. Y started working at her new practice on February 1, 2012, and her application was filed on February 15, 2012. The effective billing date is February 1, 2012. Retrospective billing is allowed prior to the filing date but cannot be prior to the date the provider began furnishing services.

    Example 3: Dr. Z started working at his new practice on December 15, 2011, and filed his enrollment application on February 15, 2012. The effective billing date is January 16, 2012. Retrospective billing is allowed for a maximum of 30 days prior to the filing date.

  2. For independent diagnostic testing facilities (IDTFs): The effective billing date is the later of the filing date of the Medicare enrollment application that was subsequently approved by Medicare; or the date the IDTF first started furnishing services at the practice location
  3. For all other providers: The effective billing date is the date the provider began furnishing services to Medicare beneficiaries or the date all of Medicare's eligibility requirements were met, whichever is later

If it appears that an error may have been made in the effective billing date determination, providers should contact our Provider Enrollment Department. A correction will be made if the effective billing date was not determined in accordance with CMS instructions.

Enrollment applications can be submitted no more than 60 days in advance of the provider's beginning date of practice. This is the case regardless of the provider's specialty.

Note: All claims for services provided to Medicare beneficiaries must be filed within 12 months of the date of service.

Page Last Updated: Sunday, 13-May-2012 10:35:51 CDT