Can a Physician Bill Medicare Claims on Paper?

February 18, 2013

The Administrative Simplification Compliance Act (ASCA) requires that all initial claims for reimbursement under Medicare be submitted electronically as of October 16, 2003, with limited exceptions. Medicare will not cover claims submitted on paper that do not meet the limited exception criteria. Medicare contractors are required to monitor and enforce the ASCA regulations. The contractors conduct a quarterly analysis of paper claim receipts.

Following the analysis, a letter is mailed to the providers who submitted a high volume of paper claims the previous quarter. This letter requests a response and explains the possible exceptions and what accompanying documentation is needed to support these exceptions. If a response to the letter is not received with acceptable evidence to substantiate eligibility to submit paper claims, all paper claims will begin to reject the 91st day after the date of the letter. This decision cannot be appealed.

Exceptions to the electronic claim submission requirement include:

  • A small provider – a facility (Medicare Part A) that has fewer than 25 Full-Time Equivalent employees (FTEs), or a physician, practitioner, or supplier (Medicare Part B) with fewer than 10FTEs;
  • A dentist;
  • A participant in a Medicare demonstration project in which paper claim filing is required;
  • A provider that conducts mass immunizations, such as flu injections, and may be permitted to submit paper roster bills;
  • A provider that submits claims when more than one other payer is responsible for payment prior to Medicare payment;
  • A provider that only furnishes services outside of the United States;
  • A provider experiencing a disruption in electricity and communication connections that are beyond their control;
  • A provider that can establish an “unusual circumstance” exists that precludes submission of claims electronically.

The inability to submit claims electronically to Medicare when Medicare is the Secondary payer is not a qualifying reason for a waiver. Software is available to submit Medicare Secondary Payer (MSP) claims electronically. This exception applies only when there is more than one payer primary to Medicare.


A condensed version of the ASCA is available in Medicare Learning Network (MLN) Matters articles at:

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