There is a claim in your system right now with a date of service in late June, a commercial payer with a 180-day filing limit, and no accepted submission on file. It has about three weeks left. Nobody is looking at it because it is one line in an aging report of four thousand lines, and December is busy. On December 28 it becomes a write-off. Multiply that by the number of payers you bill and you have the reason we run a timely filing sweep every year between Thanksgiving and New Year.
The sweep is not the same as working the aging report. Aging sorts by how old the balance is. The sweep sorts by how many days are left before the claim can no longer be filed or appealed, which is a different list, and a shorter one. This year it also has an extra category, because the shutdown left most practices with the largest block of unpaid Medicare claims they have had in years, and CMS finally said on November 20 what to do with them.
Key takeaways
- Sort by days remaining to the filing or appeal deadline, not by balance or age. The two lists overlap less than people expect.
- Five reports feed the sweep: encounters without a claim, rejections never resubmitted, claims with no response, denials with an open appeal window, and secondary claims not filed.
- Shutdown-era Medicare telehealth claims are not at timely filing risk, but returned claims must be resubmitted and patients who paid out of pocket must be refunded, so they belong in the sweep.
- Write off what is truly dead with a reason code that names the process failure, so January's review can fix the cause instead of hiding it.
Know the limits before you pull anything
Filing limits vary by payer and by contract. The table shows what we most often see; your contracts govern.
| Payer type | Typical initial filing limit | Counted from | Typical appeal window |
|---|---|---|---|
| Medicare Part B | 12 months | Date of service | Redetermination: 120 days from the remittance date |
| Medicare Advantage | 90 days to 12 months, by contract | Date of service | 60 days from the denial is common |
| Medicaid fee-for-service | 90 days to 12 months, by state | Date of service | Varies by state |
| Commercial (contracted) | 90 to 180 days | Date of service | 60 to 180 days from the denial |
| Commercial (secondary) | Often 90 days | Primary payer's remittance date | Same as primary |
Build a small table in a spreadsheet with each payer you bill and its limit in days. You will use it to calculate the deadline for every claim in the sweep. If you do not know a payer's limit, the provider manual says, and if it does not, the contract does. Watch for two traps: some contracts count from the date of service for the initial claim but from the remittance date for corrected claims, and some Medicaid managed care plans have shorter limits than the state's fee-for-service program.
The five reports, in order
- Encounters without a claim. Signed encounters with billable services and no claim on file, any date of service in 2025. These are the visits that never became claims. Each one needs a claim this week, oldest first. For a 90-day commercial payer, anything before late September is already gone; know that before you spend time on it.
- Clearinghouse rejections never resubmitted. Every rejection in 2025 without a later accepted submission for the same encounter. Rejections are invisible to the payer, so the filing clock never stopped. Fix and resubmit, oldest first.
- Claims with no response. Submitted, accepted by the clearinghouse, no 277 claim status and no 835 remittance after 30 days. Some of these were never received by the payer. Call, get a reference number, and if the payer has no record, resubmit with proof of the original timely submission.
- Denials with an open appeal window. Every denial in the last 180 days where the appeal window has not closed and no appeal is on file. Sort by dollar value and by days remaining. A $1,400 procedure denial with 12 days left on the appeal window goes to the top.
- Secondary claims not filed. Primary paid, patient has a secondary, no secondary claim on file. The clock on these runs from the primary remittance, and 90 days passes quickly.
The 2025 wrinkle: shutdown-era Medicare claims
This year the sweep has an extra category. Medicare telehealth claims with dates of service from October 1 to November 12 were held at the MACs during the shutdown, and on November 6 CMS had the MACs return a subset of telehealth claims submitted on or before November 10 with CARC 16 and RARC M77. The funding law signed on November 12 made them payable again, retroactively, through January 30, 2026. On November 20, CMS posted its processing update: practitioners may resubmit the returned claims and submit any telehealth claims they held back; the earlier instruction to append the GY modifier is rescinded; the MACs will perform mass adjustments on paid claims that are inconsistent with the restored law, including physician fee schedule claims paid without the 1.0 work GPCI floor; and practitioners should identify beneficiaries who were charged for telehealth services that are now payable, bill Medicare instead, and refund any overpayment.
Medicare's twelve-month limit means none of these are at risk of timely filing. They belong in the sweep anyway, for three reasons: they are the largest block of unpaid 2025 claims most practices have, the returned ones will never pay unless someone resubmits them, and the refunds are owed as soon as the claims adjudicate. Add a sixth line to the report list: Medicare telehealth claims with October and November dates of service and no payment on file, split into held, returned and never submitted.
Calculating days remaining
For each line in the five reports, the deadline is the date of service (or the primary remittance date for secondaries, or the denial date for appeals) plus the payer's limit in days. Subtract today. Sort ascending. Everything with fewer than 30 days remaining is worked this week. Everything with 30 to 60 days is next week. Everything else waits until January, when the aging report will find it in the normal course.
A worked example: a practice pulls 212 lines across the five reports. Forty-one have already passed their limit and are written off with a reason code that says "timely filing, process failure" rather than a generic adjustment, so the number shows up in the January review. Fifty-eight have fewer than 30 days remaining and total $31,400 in charges. The billing lead assigns them across two staff, oldest first, with a rule that every line gets a submission or a call by Friday. The other 113 are calendared.
| Line from the sweep | Payer and limit | Clock starts | Deadline | Days left on November 21 | Action |
|---|---|---|---|---|---|
| Encounter without a claim, 99214 | Commercial, 180 days | June 2 date of service | November 29 | 8 | Claim out today |
| Rejected claim, invalid subscriber ID | Medicaid MCO, 120 days | August 20 date of service | December 18 | 27 | Fix and resubmit this week |
| Denied colonoscopy, CO-197 | Commercial, 90-day appeal | September 15 denial | December 14 | 23 | Appeal with authorization proof |
| Secondary not filed | Commercial secondary, 90 days | October 3 primary remittance | January 1 | 41 | Next week |
| Held Medicare telehealth, 99213 | Medicare, 12 months | October 14 date of service | October 14, 2026 | 327 | Watch for release; no action |
Mistakes that waste the sweep
Sorting by balance instead of by deadline. The biggest balance is often a Medicare claim with ten months of runway. The smallest is often a commercial claim with nine days.
Working the aging report and calling it the sweep. The aging report does not know that a claim was rejected at the clearinghouse. Only the rejection report does.
Resubmitting instead of appealing. A denied claim resubmitted as new is often denied again as a duplicate, and the appeal window keeps running while you wait. Read the denial first.
Ignoring proof of timely filing. Clearinghouse acceptance reports and payer acknowledgement dates are the evidence for a timely filing appeal. Keep them, and know where they are before the payer asks.
Writing off without a reason. A generic adjustment code hides the problem. A code that says timely filing, and a note that says which report should have caught it, turns the write-off into a fix.
Questions we hear
Can we appeal a timely filing denial?
Yes, if you can show the claim was originally submitted within the limit. A clearinghouse acceptance report with the date, or a payer acknowledgement, usually works. If the claim was never submitted in time, there is no appeal; there is a process fix.
What makes year end different from any other month?
Because payers change plan years, patients change plans, and the practice's own attention moves to January. A claim that misses its window in December is rarely revisited. And because the finance team wants a clean picture of 2025 receivables, which it cannot have while recoverable claims sit next to unrecoverable ones.
How long does the sweep take?
Pulling and sorting the five reports is a day for one person. Working the under-30-days list depends on its size. Most practices we work with finish the urgent list in a week and the rest by the third week of December. Practices on our denial management service get the appeal-window report weekly, and the RCM audit starts with the first two reports on this list.
What to do this week
- Build the payer limit table from your contracts and provider manuals.
- Pull the five reports plus the shutdown-era Medicare telehealth list, and calculate days remaining for every line.
- Assign everything under 30 days to named staff with a Friday deadline; calendar the 30-to-60-day lines for next week.
- Resubmit the Medicare telehealth claims returned with CARC 16 and M77, without the GY modifier, and submit any you held back.
- Write off the expired lines with a timely filing reason code and a note naming the report that should have caught them.
