Submitting Part A to Part B Claims (Rebilling) Submissions

Administrator’s Ruling CMS 1455-R

The Administrator’s Ruling CMS 1455-R, issued on 3/13/2013 established an interim process for hospitals to use to submit claims for Part B services when an IP stay is denied under Part A as not R&N by the MAC or by a MRC. The Administrator’s Ruling was effective beginning 3/13/2013 with regard to IP claims denied:

• While CMS 1455-R is in effect (effective 3/13/2013)
• Prior to effective date of CMS 1455-R (3/13/2013) but timeframe to file an appeal has not expired as of 3/13/2013
• Prior to effective date of CMS 1455-R (3/13/2013) but for which an appeal is pending
• Under this Ruling, hospitals must submit eligible claims within the following timeframes:
  • If not appealing denied IP claim, submit within 180 days from remittance advice date
  • If appealing denied IP claim, submit within 180 days from date of final appeal decision (letter date)
  • If appealing the denied IP claim but withdrawing appeal, submit within 180 days from dismissal acknowledgement (letter date)

Final Rule CMS 1599-F

CMS issued on 8/19/2013 a final rule CMS-1599-F but not a final CR. However, CMS has issued temporary instructions, in MLN Matters article SE1333 Revised, for hospitals to use for submitting eligible Part B claims with admission dates on or after 10/1/2013. CMS has applied the one-year timely filing requirement to eligible claims and they are allowing hospitals to submit eligible claims when the hospital denies the IP stay as not R&N (self-audit).