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Retroactive Enrollment Periods and Claims Reprocessing

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The Texas Medicaid & Healthcare Partnership (TMHP) and the Texas Health and Human Services Commission (HHSC) have developed a process to modify enrollment period effective dates for providers that meet the following criteria:

  • Have been disenrolled from Texas Medicaid for failing to revalidate on-time between November 1, 2023, and December 12, 2024.
  • Successfully reenroll or revalidate in Texas Medicaid by May 31, 2025.

This process will be implemented in two phases.

Phase 1 Overview

Beginning January 17, 2025, for providers that meet both the criteria listed above, Phase 1 will result in their National Provider Identifier (NPI) enrollment period begin date in the Provider Enrollment and Management System (PEMS) to be backdated up to 365 calendar days. This will reduce or eliminate the provider’s enrollment gap impacted by status code 66, “Provider Is Not Enrolled, Failed To Re-Validate.”

Providers will receive an email notification with their new NPI enrollment period begin date. For any providers with draft or in-flight revalidation or reenrollment requests that are approved after January 17, 2025, the following will apply:

  • Their NPI enrollment period begin date in PEMS will be backdated up to 365 calendar days to reduce or eliminate their enrollment gap.
  • Status code 66 will be removed up to 365 days after the revalidation or reenrollment is in “closed-enrolled” status.

Phase 2 Overview

Beginning February 22, 2025, Phase 2 will result in shifting the enrollment period end date back the same number of days that the enrollment period begin date was shifted back. The change to the enrollment period end date will also be reflected as a new revalidation due date to align with state and federal revalidation frequency requirements. Providers will receive an email notification with their new NPI enrollment period end date.

Important: Providers should continue to submit all claims during the gap period and during their reenrollment phase. TMHP will be processing claims as normal for services delivered during the gap period.

Retroactive Enrollment Period Examples

To learn more about how these modifications affect enrollment periods, refer to the following examples:

  • Example 1: Provider’s enrollment period gap exceeds 365 calendar days.

    In this scenario, the provider’s enrollment period end date and revalidation due date was November 1, 2023, and the provider was disenrolled for failing to revalidate on-time effective November 2, 2023. The provider successfully reenrolled on November 27, 2024. In Phase 1, the NPI enrollment period begin date in PEMS will be backdated 365 calendar days to November 28, 2023. In Phase 2, the enrollment period end date and revalidation due date will be shifted back to November 27, 2028.
    • Current enrollment periods:
      • February 1, 2019 – November 1, 2023
      • November 27, 2024 – November 26, 2029
    • Revised enrollment periods after Phase 1 and Phase 2:
      • February 1, 2019 – November 1, 2023
      • November 28, 2023 – November 27, 2028
  • Example 2: Provider’s enrollment period gap is less than 365 days, and entire gap closure occurs.

    In this scenario, the provider’s enrollment period end date and revalidation due date was March 31, 2024, and the provider was disenrolled for failing to revalidate on-time effective April 1, 2024. The provider successfully reenrolled on June 5, 2024. In Phase 1, the NPI enrollment period begin date in PEMS will be backdated to April 1, 2024, because the enrollment gap is less than 365 calendar days. In Phase 2, the enrollment period end date and revalidation due date will be shifted back to March 31, 2029.
    • Current enrollment periods:
      • April 1, 2019 – March 31, 2024
      • June 5, 2024 – June 4, 2029
    • Revised enrollment periods after Phase 1 and Phase 2:
      • April 1, 2019 – March 31, 2024
      • April 1, 2024 – March 31, 2029

Grace Period to Submit Acute Care FFS Claims Impacted by Enrollment Gap

Starting January 1, 2025, providers will no longer receive claim rejections for “Provider Is Not Enrolled, Failed To Re-Validate” for acute care fee-for-service (FFS) claims submitted to TMHP. TMHP has made an update to allow claims to be submitted and accepted into the claims system while the provider is going through the revalidation or reenrollment process. However, claims submitted before the revalidation or reenrollment request is approved will be denied because the provider was not enrolled or failed to revalidate.

To ensure timely reprocessing, any held claims impacted by the enrollment gap must be submitted to TMHP by February 28, 2025.

Acute Care FFS Claims Reprocessing for Retroactive Enrollment Period Effective Date Updates

Beginning February 2025, TMHP will start reprocessing claims that were denied with explanation of benefits (EOB) 01215, “Provider is not enrolled, failed to re-validate,” or that were denied for lack of timely filing during the provider’s gap. This will occur on a monthly basis.

TMHP will waive the timely filing deadline requirement for claims that fall within the retroactive grace period by extending the 95-day claims and 120-day appeals filing deadlines for submitted claims.

If providers have not revalidated or reenrolled in PEMS, their claims will be denied, and reprocessing of their claims will not occur until the provider’s enrollment status in PEMS reflects “Approved.” When the claims are reprocessed, providers may receive additional payment, which will be reflected on the Remittance and Status (R&S) Report two to three weeks after the start of the claims reprocessing.

For more information regarding the gap closure or acute care FFS claims reprocessing, call the TMHP Contact Center at 800-925-9126.

Managed Care Claims

HHSC has worked with managed care organizations (MCOs), and each MCO will have its own claims reprocessing process. Providers should contact members’ specific MCO for details regarding claims submitted to the MCO.

LTC Claims

Long-term Care (LTC) billing providers must rebill claims that previously rejected due to attending or referring providers not being enrolled. Rebilling should occur after the attending and referring providers have completed revalidation or reenrollment and the necessary updates have been made.

If claims exceed the 365-day timely filing deadline, they will be denied. Providers can call HHSC-LTC Provider Claims Services at 512-438-2200 to request consideration for claims reprocessing, and select the appropriate option:

  • Option 1 for Nursing Facilities, Hospice, and Intermediate Care Facilities for Individuals with an Intellectual Disability or Related Conditions (ICF/IID).
  • Option 5 for Home and Community-based Services (HCS) and Texas Home Living (TxHmL).

For more information regarding the gap closure, call the TMHP LTC Help Desk at 800-626-4117 (select option 1).