> ## Documentation Index
> Fetch the complete documentation index at: https://mso.getlemma.com/llms.txt
> Use this file to discover all available pages before exploring further.

# Timely filing limits by payer

> How filing limits are set, the ones fixed by regulation, what to record per contract, and the evidence that wins a CARC 29 appeal.

**Timely filing** is the deadline by which a claim must reach the payer. Miss it and the claim is generally unpayable, CARC 29, with no clinical or coding defect involved.

**Your contract governs, not this page.**

Commercial timely filing limits are **contractual**, and they vary by payer, by product line, and by individual negotiated agreement. Two practices can have different limits with the same payer.

Publishing a table of "commercial payer X = N days" would be wrong for a meaningful share of readers, and a wrong deadline is worse than no deadline. **Record each limit from your own executed contract**, into your enrollment grid, when you sign.

What follows is what is fixed by regulation, the typical ranges, and how to work the problem.

## Fixed by regulation

| Payer                        | Initial filing limit                                     | Basis                                |
| ---------------------------- | -------------------------------------------------------- | ------------------------------------ |
| **Medicare fee-for-service** | **12 months from the date of service**                   | Statutory and regulatory<sup>1</sup> |
| Medicare Advantage           | Set by the plan's contract, **not** Medicare's 12 months | Plan contract                        |
| Medicaid                     | State-specific; commonly 90 days to 12 months            | State regulation                     |
| TRICARE                      | Set by program rules                                     | Program                              |
| Workers' compensation        | State-specific                                           | State regulation                     |

**Medicare Advantage plans are not bound by Medicare's 12-month limit.** Practices routinely assume they are and lose claims. MA plans set their filing limits by contract, and they are frequently far shorter.

## Typical commercial ranges

Directional only, **confirm each from your own contract**.

| Product type           | Commonly seen                                                               |
| ---------------------- | --------------------------------------------------------------------------- |
| Commercial PPO/HMO     | 90 to 180 days                                                              |
| Some national carriers | Up to 12 months on some products                                            |
| Medicaid MCO           | Frequently short, sometimes 90 days                                         |
| Secondary / COB claims | Often measured from the **primary's remittance date**, not the service date |

## The three windows to record

Each payer has **three** deadlines, and they differ:

| Window              | What it governs                      | Typical relationship                                    |
| ------------------- | ------------------------------------ | ------------------------------------------------------- |
| **Initial filing**  | Original claim submission            | The longest                                             |
| **Corrected claim** | Resubmitting a claim with fixed data | Often **shorter** than initial                          |
| **Appeal**          | Contesting an adjudication           | Runs from the **remittance date**, not the service date |

Record all three per payer when you sign the contract.

## Proving you filed on time

**Clearinghouse acceptance reports are the standard evidence.** A 277CA showing payer acceptance on a specific date, or a clearinghouse transmission report, is what wins a CARC 29 appeal.

A screenshot of your PM system showing "submitted" is **not** evidence — it proves you pressed a button, not that the payer received anything.

Retain acceptance reports for at least the longest appeal window across your payer mix.

## The exceptions

| Exception                          | Basis                                                                                                                                  |
| ---------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------- |
| **Proof of timely submission**     | The claim was filed on time; the payer lost or misprocessed it. Strongest argument.                                                    |
| **Retroactive eligibility**        | Coverage backdated after service; the clock generally runs from when eligibility was established                                       |
| **Coordination of benefits delay** | The secondary's clock typically runs from the primary's remittance                                                                     |
| **Payer error**                    | The claim was rejected in error and promptly resubmitted                                                                               |
| **Provider enrollment delay**      | Where a retro-effective date was granted, ask how the payer measures filing from it                                                    |
| **Catastrophic circumstances**     | Disaster or systems outage. The **2024 Change Healthcare outage** produced widespread accommodations, a useful precedent if it recurs. |

Each has a documentation requirement. Assemble it with the appeal.

## The guardrails that get write-offs to zero

<Steps>
  <Step title="Enter charges within one business day">
    The clock starts at the date of service.
  </Step>

  <Step title="Work rejections same-day">
    **The most common cause of a timely-filing loss is a claim stuck in a rejection loop.** A 277CA rejection means nothing was filed as far as the payer is concerned, while your system shows it as "submitted." A rejected claim sitting for two months has consumed two months of a 90-day window.
  </Step>

  <Step title="Run a weekly no-acceptance report">
    Every claim submitted more than three days ago with no 277CA acceptance. This catches claims lost between your system and the payer, the failure nothing else surfaces.
  </Step>

  <Step title="Track held claims against their limits">
    Claims held during credentialing, awaiting authorization, or pending COB need an aging report with the deadline attached.
  </Step>

  <Step title="Set an internal deadline inside the contractual one">
    If the limit is 90 days, escalate anything unfiled at 45. The buffer absorbs the rejection loop.
  </Step>

  <Step title="Alert on approaching deadlines">
    Weekly, by payer.
  </Step>

  <Step title="Track timely-filing write-offs as a metric, targeting zero">
    Any non-zero number gets a root cause and a process change.
  </Step>
</Steps>

## The grid template

| Field                                          |
| ---------------------------------------------- |
| Entity                                         |
| Payer, and product line                        |
| **Initial filing limit**                       |
| **Corrected claim window**                     |
| **Appeal window** (and from what date it runs) |
| Contract effective date                        |
| Where the limit is stated in the contract      |
| Date recorded / verified                       |

Verify annually and on every contract renewal or amendment — unilateral amendment clauses mean a limit can change without your signature.

## Sources

1. Medicare timely filing: Social Security Act § 1842(b)(3)(B); 42 C.F.R. § 424.44. See CMS, [Medicare Claims Processing Manual](https://www.cms.gov/regulations-and-guidance/guidance/manuals/internet-only-manuals-ioms-items/cms018912), ch. 1. Confirm current rules and any exception provisions with CMS.


## Related topics

- [Beat timely filing limits](/guides/billing/beat-timely-filing.md)
- [File appeals](/guides/billing/file-appeals.md)
- [Enroll and contract with commercial payers](/guides/enrollment/enroll-with-commercial-payers.md)
- [Claim denials, explained](/concepts/payments/claim-denials.md)
- [Underpayments, fee schedules, and payer contracts](/concepts/payments/underpayments-and-contracts.md)
- [CARC codes (Claim Adjustment Reason Codes)](/reference/edi/carc-codes.md)
- [Payer enrollment & submission links](/reference/payers/enrollment-links.md)
