The last two weeks of December are the quietest on the schedule and the most expensive on the billing side. Staff take leave, payers close for holidays, and claims that have been sitting in a work queue since the summer cross their timely filing limits without anyone noticing. Then January arrives with new cards, new deductibles and, this year, a Medicaid population that has been churning for eight months.

This is the checklist we run with practices in December. It is not glamorous. It saves money every year.

Key takeaways

  • Sweep every unaccepted 2023 claim and every unworked denial against its filing or appeal limit before December 21, when holiday staffing thins out.
  • Run eligibility for the first two weeks of January in the last week of December, with every Medicaid patient included; more than 12 million people have been disenrolled since April, most for paperwork reasons.
  • Deductibles reset January 1, including the Part B deductible at $240. Tell patients before the visit, with an estimate, not after it on a statement.
  • The federal IDR portal reopened December 15; disputes delayed by the closure must be initiated by January 16, 2024.

1. The timely filing sweep

Pull every claim with no payer acceptance (no accepted 277 and no remittance) with a date of service in 2023, sorted by payer and then by date of service. Then apply each payer's filing limit: Medicare allows one year from the date of service; many commercial contracts allow 90, 120 or 180 days; Medicaid limits vary by state and plan. Anything within 30 days of its limit gets submitted or corrected this week, before the holiday staffing gap. Anything already past the limit needs a decision: appeal with proof of original timely submission if you have it, or write off with a specific reason code so the loss is visible in the January report.

Do the same for denials. Appeal windows run from the denial date, and a denial from early September on a 90-day appeal window expires in early December. The queue of "denials to appeal" that nobody has touched since Thanksgiving is where the December losses live.

A worked example of what the sweep finds. A four-provider practice we worked with ran it for the first time this month and found 212 claims with no acceptance, worth about $61,000 in charges. Of those, 140 had been rejected at the clearinghouse for correctable errors and never resubmitted; 38 were still within their filing limits and went out that week; 34 were already past a 90-day commercial limit and were written off with a timely filing reason code. The write-off was painful, but it was also the first time the practice knew the number, and the rejection queue has been worked daily since.

2. Payer and clearinghouse holiday processing

Most payers and clearinghouses publish holiday schedules. Medicare Administrative Contractors observe the federal holidays, and payment floors mean electronic claims submitted in the last week of December will be paid in January regardless. Commercial payers close on December 25 and January 1 and many run reduced staff the week between. Practical consequences:

  • Submit everything you can by December 21 so it is in the payer's system before the closures.
  • Expect ERAs to arrive in a lump in early January; plan posting capacity for the first full week.
  • Do not schedule payer phone follow-up for December 26 to 29. Use those days for the timely filing sweep and the January preparation below.
  • Check your bank deposits against posted payments before the year closes, so the accountant's year-end revenue number matches what was actually received.

3. The January deductible reset

On January 1, most commercial plan deductibles reset to zero. A patient who paid nothing out of pocket in December because the deductible was met in March will owe the full allowed amount for the same visit in January. The Part B deductible resets for traditional Medicare patients as well, and for 2024 it is $240, up from $226, per the CMS announcement in October. Every year, this produces a wave of patient statements in February and March, and a wave of calls from patients who feel they were not warned.

The fix is a conversation at scheduling and check-in, supported by a real estimate. Verify eligibility for January appointments in the last week of December, read the deductible remaining on the 271 response, and tell the patient before the visit: "Your plan's deductible resets on January 1, and this visit will likely apply to it. Based on your plan, we estimate your responsibility at about $185. Would you like to pay today or set up a plan?" Scripts help. So does a card-on-file policy explained in advance. Practices that collect at the time of service in January have a very different first quarter from practices that mail statements in March.

Two things the estimate has to get right. The allowed amount, not the charge, is what applies to the deductible, so the estimate needs the payer's fee schedule loaded. And the 271 response shows the deductible remaining as of the inquiry date; a patient seen by another provider on January 3 may have less remaining by the time of your January 9 visit. Say "about" and mean it.

4. Re-verify Medicaid patients

States have been redetermining Medicaid eligibility since April, after the pandemic-era continuous coverage requirement ended. KFF's unwinding tracker now counts more than 12 million people disenrolled nationally, and in the states reporting the reason, roughly seven in ten were terminated for procedural reasons (paperwork not returned, mail not received) rather than because they were found ineligible. Many of those people are still eligible and can be reinstated; many do not know they have lost coverage until they arrive at a practice.

For a practice, that means the Medicaid eligibility you verified in the spring is unreliable. Run eligibility on every Medicaid and Medicaid managed care patient scheduled in January. For anyone who shows terminated, have the front desk ready with two things: the state's reinstatement or reapplication contact, and the practice's policy on seeing patients whose coverage has lapsed. Procedural terminations can often be reversed with retroactive coverage in some states, which means a claim held rather than written off may still be paid. Talk to your state Medicaid agency or managed care plan about the retroactive rules that apply.

Pediatric practices should pay particular attention. Children make up a large share of the disenrolled, and many remain eligible for Medicaid or CHIP even where a parent does not. A child whose coverage shows terminated in January is very often a child whose family did not receive or return a renewal packet.

5. The IDR portal is open again

For practices with out-of-network emergency or facility-based claims under the No Surprises Act, the federal independent dispute resolution portal reopened to all dispute types on December 15, 2023, after being partially closed since August following a court decision. Parties whose deadline to initiate a dispute fell between August 3 and December 15 have until January 16, 2024, to initiate. The Departments have also finalized a new administrative fee of $115 per party per dispute, which applies to disputes initiated on or after January 22, 2024. If your practice has out-of-network disputes on hold from the closure, the January 16 date is the one to calendar.

6. Fee schedules and code tables for January 1

The CY 2024 Physician Fee Schedule takes effect January 1 with a conversion factor of $32.74. The CPT 2024 changes take effect the same day. Confirm with your practice management vendor that both updates are scheduled, load the Medicare-linked fee schedules, add G2211 and any new codes your practice uses with January 1 start dates, and end-date deleted codes as of December 31 rather than removing them.

G2211 needs one more step before January: a claim edit that flags it when the same claim carries an E/M with modifier 25, because that combination is not payable under the final rule, and a one-line answer for the front desk when a Medicare patient asks what the new code on their statement is.

The December calendar

WhenTask
By December 21Timely filing and appeal deadline sweep complete; all submittable claims sent
December 26 to 29Eligibility sweep for January 2 to 12 appointments, including all Medicaid patients; deductible estimates prepared; fee schedule and code table loads confirmed
December 29Bank to payments reconciliation for the year; unapplied balances cleared
January 2 to 5Post the ERA backlog; ask for the card at every visit; watch first-pass rejections for new-code and new-plan problems
January 16IDR initiation deadline for disputes delayed by the portal closure

Questions we hear

Can we bill the patient for a claim we missed the filing limit on?

Generally no. Most payer contracts prohibit billing the patient for charges denied due to the provider's failure to file timely. Check your contract, and treat the write-off as a process lesson rather than a collection opportunity.

Should we hold January claims until the payer loads the new fee schedule?

No. Submit on time. If a payer pays January claims at 2023 rates or rejects a new code, that is a reprocessing request, not a reason to delay submission and risk filing limits. Track the variance and request reprocessing in a batch.

Who should run this checklist?

The billing lead, with the practice administrator reviewing the timely filing results and the front desk owning the eligibility and deductible pieces. If your billing is with Revelrex, the sweep and the January preparation are part of the service, and the timely filing report appears in your December package.

What to do this week

  1. Run the unaccepted claims report for all 2023 dates of service and the unworked denials report, and mark each item with its filing or appeal deadline.
  2. Submit or correct everything within 30 days of a limit by December 21, and give every item already past its limit a documented decision.
  3. Schedule the batch eligibility run for January 2 to 12 appointments for the week of December 26, with Medicaid patients flagged for a second look.
  4. Load the 2024 Part B deductible of $240 and the January deductible script into the front desk's estimate routine.
  5. Confirm the fee schedule and CPT 2024 load dates with your vendor, add G2211 with the modifier 25 edit, and calendar January 16 if you have IDR disputes on hold.