Timely filing extension renewed alongside National Emergency declaration

March 1, 2021

Timely filing extensions for claim submissions that were instituted by the IRS/DOL last March as part of a Covid-19 National Emergency declaration will be extended after President Joe Biden said he would extend the emergency in a Feb. 24 letter to Congress.

After the Trump Administration issued the emergency declaration on March 1, 2020 (keep in mind this is distinct from the HHS Public Health Emergency), the Internal Revenue Service (IRS) and Department of Labor (DOL) issued a regulation that paused the timely filing requirements clock for claims that would have exceeded filing limitations during the national emergency period. Once the declaration is allowed to expire, a corresponding
“outbreak period” extends 60 days past the end of the national emergency, at which time the timely filing exception expires.

For example, if the national emergency had expired on March 1, 2021, the outbreak period would have ended 60 days later on April 30, 2021, at which time timely filing rules would go back into effect.

Commercial payers were not required to implement this policy, although many have. This includes Aetna, UnitedHealthcare, Cigna, and several BCBS products. Most payers typically allow a 180-day timeframe from the date of service for a provider to submit a claim and be eligible for payment.

“When an end date for the national emergency period has been declared, there will be an additional 60-day extension of timely filing requirements for claim submissions following the last day of the national emergency period,” UHC clarified on its website.

If you need assistance understanding a particular payer’s policy in regards to this regulation, don’t hesitate to reach out to us at 517-486-4262.

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