Medicaid Claim Submission Deadlines in 2025: MCO and State Rules with Compliance Tips
Blog Outline
- Introduction — Why Medicaid Timely Filing Limit Matters
- CMS Framework for Medicaid Timely Filing (42 CFR § 447.45)
- Medicaid Claim Submission Deadlines by State (2025 Update)
- Medicaid Managed Care (MCO) Filing Limits (2025)
- Exceptions to Medicaid Timely Filing (2025 Update)
- How Medicaid Filing Limit Works
- Common Medicaid Denial Codes for Late Filing (2025)
- Key Takeaways
- Frequently Asked Questions (FAQ)
Introduction — Why Medicaid Timely Filing Limit Matters
Timely filing limit is often overlooked in Medicaid billing. Each state Medicaid program sets a specific deadline for providers to submit their claims after the date of service (DOS). When providers miss that claim filing window, the claim is automatically denied, often without appeal rights.
Medicaid claim filing limit deadlines vary by state, and even by plan type within the same State. For example, Texas allows just 95 days, while Florida and Washington permit 12 months. Managed Care Organizations (MCOs), which process the majority of Medicaid claims, often impose shorter filing limits, sometimes as little as 90 days.
For providers serving Medicaid patients across multiple states or managed care plans, this creates a serious compliance challenge. Missing even one filing window can result in permanent revenue loss, CO 29 denials, or plan-specific rejection codes that cannot be reopened.
Read our detailed post on CO 29 and N39011 denial codes.
CMS Framework for Medicaid Timely Filing (42 CFR § 447.45)
While every state controls its own Medicaid program, the claim filing process operates under federal oversight. The Centers for Medicare & Medicaid Services (CMS) sets the baseline rule for all states in Title 42 of the Code of Federal Regulations, Section 447.45(d).
Federal Requirement (42 CFR § 447.45(d)(1)):
“The Medicaid agency must require providers to submit all claims no later than 12 months from the date of service.”
In simple terms, this rule means:
- States cannot allow more than 12 months from the date of service for original claim submission.
- However, they may impose shorter limits — and many do (for example, 90 or 180 days).
- Each Medicaid agency must publish its filing rules in its state provider manual or MCO contract.
How the Federal Rule Works in Practice
- Date of Service (DOS): This anchors the timely filing window. For inpatient or institutional claims, the discharge date (“through” date) applies.
- Proof of Receipt: Timeliness depends on when the state or MCO receives the claim, not the postmark date.
- Exceptions: CMS allows limited flexibility — for example, retroactive eligibility or system errors — but these must be defined in each state’s approved plan
Medicaid Claim Submission Deadlines by State (2025 Update)
Every state Medicaid agency sets its own timely filing limit. If a claim is received even one day past the deadline, it is considered untimely and will be denied unless a documented exception applies. Below is a summary table (2025 updated) showing current filing deadlines and resubmission periods based on the most recent Medicaid provider manuals and MCO bulletins.
⚠️ Note: Always confirm with your state’s official Medicaid provider manual or MCO contract, as deadlines can vary between fee-for-service (FFS) and managed care plans.
2025 Medicaid Claim Filing Deadlines by State
| State | Filing Deadline | Resubmission / Adjustment Window | Notes (2025) |
|---|---|---|---|
| Alabama | 12 months from DOS | 6 months post-denial | Exceptions for retroactive eligibility. |
| Alaska | 12 months | 180 days after denial | Extensions possible for retroactive coverage. |
| Arizona (AHCCCS) | 6 months (180 days) | 12 months for AHCCCS retro cases | Applies to both physical & behavioral health. |
| California (Medi-Cal) | 6 months (180 days) | 60 days for corrected claims | Must submit via DHCS or clearinghouse. |
| Florida | 12 months | 6 months for adjustments | Managed care plans may have shorter limits. |
| Georgia | 6 months | 12 months for retroactive cases | Updated policy effective July 2024. |
| Illinois | 180 days | 180 days after denial | Provider must show proof of initial submission. |
| Indiana | 12 months | 90 days after denial | Applies to both FFS and managed care. |
| Iowa | 12 months | 6 months correction period | Extensions possible for retroactive coverage. |
| Kentucky | 12 months | 120 days resubmission | Managed care may differ. |
| Louisiana | 12 months | 24 months for retroactive eligibility | State offers exception form for review. |
| Maryland | 12 months | 6 months correction | Applies to FFS; MCOs 90–180 days. |
| Michigan | 12 months | 120 days | Electronic and paper deadlines same. |
| Mississippi | 180 days | 6 months resubmission | Proof of denial required for resubmission. |
| New York (eMedNY) | 90 days | 60 days resubmission | Strictest timeline in U.S.; requires documentation for exceptions. |
| North Carolina | 12 months | 180 days correction | Updated to match NCTracks portal policy. |
| Ohio | 12 months | 180 days resubmission | Applies to both FFS and MyCare plans. |
| Oklahoma | 12 months | 6 months resubmission | Managed plans: 90–120 days. |
| Pennsylvania | 180 days | 60 days correction | Applies to both DHS and MCOs. |
| Tennessee | 12 months | 6 months | BlueCare and Amerigroup follow 120-day rules. |
| Texas (TMHP) | 95 days | 120 days for MCO claims | Strict receipt-based deadline. |
| Virginia | 12 months | 6 months | Retroactive eligibility exceptions only. |
| Washington | 12 months | 24 months for retroactive cases | Disaster extensions apply automatically. |
| Wisconsin | 365 days | 180 days | Managed care deadlines vary by plan. |
- 6-month states: California, Georgia, Arizona — shorter timelines mean stricter compliance needs.
- 12-month states: Florida, Michigan, Washington, Louisiana — more provider flexibility.
- Shortest window: New York (90 days).
- Strictest enforcement: Texas (95-day cutoff) and New York (90-day MCO enforcement).
- Longest exceptions: Washington and Louisiana allow up to 24 months for retroactive cases.
Medicaid Managed Care (MCO) Filing Limits (2025)
Managed Care Organizations (MCOs) administer Medicaid benefits in many states and typically enforce their own claim filing deadlines separate from the state fee-for-service (FFS) program. Because most Medicaid members are covered by MCO plans, understanding MCO deadlines is critical to avoid denials.
MCO filing Limits
These are representative examples to illustrate the range of MCO practices in 2025. Always check the plan’s current provider manual or portal.
- 90 days — some Medicaid MCOs (especially for behavioral health or specialized networks) require submission within 90 calendar days of service.
- 120 days — many regional plans (Aetna Better Health, Cigna/multiple local plans) use 120 days as a standard filing window.
- 180 days — several large MCOs (some Centene affiliates, Molina in certain states) allow up to 180 days for clean claim submission.
- Plan-specific exceptions — credentialing delays, retroactive eligibility, or system outages sometimes permit limited extensions but require formal documentation.
How MCO rules differ from State FFS Rules (Practical Examples)
- State FFS = 12 months, MCO = 120 days: If your state allows 12 months but the member is in an MCO with a 120-day rule, you must file within 120 days for that claim.
- State FFS = 6 months, MCO = 180 days: If the MCO affords a longer window than FFS, the plan contract governs claims sent to that MCO.
- Corrections: Several MCOs treat resubmissions and corrected claims as new claims (they require resubmission within the original window), while others provide an explicit correction window (e.g., 60 days).
Practical workflow to handle MCO filing limits (step-by-step)
1. Map payer IDs to filing windows.
Maintain a single reference table in your RCM system that lists each MCO payer ID + exact filing window (days from DOS) and where to find the provider manual.
2. Set plan-level aging alerts.
Configure alerts at 60%, 80%, and 95% of the plan’s filing window (for a 120-day window: alerts at ~72, 96, and 114 days).
3. Treat MCOs as separate “payers” in workflows.
Apply MCO-specific batching rules so submissions for a plan go out before its EDI cutoff.
4. Monitor plan portals daily for bulletins.
Many MCOs post temporary filing extensions, outage notices, or new provider guides on their portals.
5. Document exceptions promptly.
When you request an exception (e.g., retroactive eligibility), upload or save the MCO confirmation to the claim file for audit trails.
6. Automate RTP handling per MCO rules.
If an MCO returns a claim as unprocessable, route it into a priority queue and rework within the plan’s filing window.
7. Reconcile ERA/835s with MCO rules.
When a denial posts, map denial codes back to the MCO rule (some MCOs use proprietary denial codes to indicate late filing).
When you open an MCO provider manual, scan for:
- Section titled “Timely Filing,” “Submission Deadlines,” or “Claim Filing Requirements.”
- Exact wording: e.g., “Claims must be submitted within 120 calendar days from the Date of Service (DOS). Claims received after this period will be denied.”
- Separate subsections for clean claims, corrected claims, and paper claim receipt vs. EDI timestamps.
- Instructions for appeal/reconsideration and whether late-filed claim reconsideration is allowed.
Example: How different MCOs commonly phrase filing limits
- Wellcare (example): “Providers must submit clean claims within 180 calendar days from the date of service or discharge.”
- UnitedHealthcare Community Plan (example): “Timely filing is defined in the provider contract; typical limits are 90–180 days depending on state and contract.”
- Molina (example): “Claims must be filed no later than 120 days from the date of service for all lines of business unless otherwise stated.”
Exceptions to Medicaid Timely Filing (2025 Update)
While Medicaid programs enforce strict claim submission deadlines, nearly every state allows limited exceptions when circumstances beyond the provider’s control prevent timely filing. These exceptions mirror the flexibility permitted by CMS regulation 42 CFR § 447.45(d)(4), which directs state Medicaid agencies to accept claims filed later than their standard window only under defined, documented conditions.
1. Retroactive Beneficiary Eligibility
When it applies
A patient’s Medicaid eligibility was approved after the date of service (e.g., retroactive coverage, newborn enrollment, SSI/Disability determination).
Example
A newborn is added to Medicaid 60 days after birth. The provider’s delivery claim, though filed after 60 days, qualifies for an exception because coverage was retroactive.
Documentation required
- Copy of Medicaid eligibility notice showing retroactive coverage period
- State eligibility system printout or EHR verification screenshot
- Claim resubmission within the state’s post-eligibility window (commonly 6–12 months)
2. State or System Administrative Error
When it applies
A Medicaid agency, fiscal intermediary, or contracted MCO caused a delay in processing, enrollment, or system acceptance.
Example
- System outage prevented EDI submission
- State portal rejected clean claims in error
- Provider ID activation delay after credentialing approval
Documentation required
- State-issued bulletin, error letter, or system ticket reference
- Proof of timely initial submission attempt (277CA acknowledgment or clearinghouse log)
3. Retroactive Provider Enrollment or Revalidation
When it applies
A provider was approved or revalidated retroactively and could not bill until enrollment was finalized.
Example
- A clinic applied for Medicaid enrollment in April 2024 but approval took effect in October 2024 retroactive to April. Claims for April–September qualify for exception filing once active.
Documentation required
- Provider enrollment approval letter with effective date
- Correspondence showing retroactive effective period
4. Natural Disaster or Declared Public Emergency
When it applies
Federal or state authorities declare a natural disaster (hurricane, wildfire, flood, etc.) that disrupts operations or EDI transmission.
Example
During a declared disaster period, Florida AHCA and Louisiana Medicaid automatically extend timely filing deadlines for affected counties.
Documentation required
- FEMA or state emergency declaration reference
- MAC or state Medicaid bulletin citing extended deadlines
- Claim submitted within the extended timeframe
5. State-Defined “Good Cause” or “Administrative Delay” Waivers
Some states (e.g., Louisiana, Ohio, Virginia) permit discretionary review of late claims under a “good cause” or “administrative delay” category. These are not federally mandated but are built into state policy.
Example
- Provider attempted submission within deadline but received repeated “invalid member ID” rejections due to state data mismatch.
- Upon proof of continuous eligibility, claim is reopened under good-cause review.
Documentation required
- Proof of timely submission attempt
- Explanation letter citing specific rule or code section
- Supporting screenshots or correspondence
6. Crossover Claim Exceptions (Medicare → Medicaid)
For dual-eligible patients, Medicaid acts as secondary payer. Many states allow crossover claims submitted by Medicare contractors to bypass normal Medicaid filing limits — provided the claim was filed to Medicare on time.
Example
Medicare claim submitted within 12 months → crossover to Medicaid received automatically, even if past the state’s standard window.
Documentation required
- Medicare RA (Remittance Advice) showing initial submission and payment date
- Cross-over EDI acknowledgment (835 or 999)
Key Points About Exceptions in Medicaid Claim Filing Limits
| Rule | Applies To | Proof Needed |
|---|---|---|
| Retroactive eligibility | Patient enrollment delay | Medicaid eligibility notice |
| State/system error | System outage or EDI issue | Ticket or bulletin |
| Provider enrollment delay | Late approval or revalidation | Enrollment letter |
| Natural disaster | Declared emergency | FEMA/state notice |
| Good-cause waiver | Case-by-case | Written justification |
| Medicare crossover | Dual-eligible claims | Medicare RA / crossover record |
How to Request an Exception in Claim Filing to Medicaid
Each state has its own procedure — typically through a Late Claim Override or Timely Filing Exception Form.
Examples
- Florida: AHCA Form 2040 – Timely Filing Certification Statement
- Louisiana: Form 146 – Late Claim Certification
- Texas (TMHP): Form CMS-1500 + documentation under TMHP Appeals
Best practice
Submit exceptions within 6 months of discovery, attach proof, and keep copies of all correspondence. Always include the claim control number (TCN) and original submission date in your exception request.
How Medicaid Filing Limit Works
Late submission is one of the most common and costly Medicaid denial reasons. When a claim is received after the filing deadline, the system automatically returns a denial with a Claim Adjustment Reason Code (CARC) or Remittance Remark Code (RARC) explaining that the time limit has expired.
Because Medicaid programs operate under both federal and state authority, the exact denial code can differ between fee-for-service (FFS) and Managed Care Organizations (MCOs). However, the meaning is the same — the claim was received too late to be processed for payment.
- Each claim’s “receipt date” (not postmark) is compared against the state’s filing window.
- If the date exceeds the deadline and no exception flag is attached, the claim automatically denies.
- Denials are generally final, but some states allow reopenings if documentation proves a valid exception.
- Most denials appear with CARC 29 (Time limit for filing claim expired), though some states use their own proprietary denial codes or RARCs.
Common Medicaid Denial Codes for Late Filing (2025)
| Code | Code Type | Meaning | Used By / Applies To | Resolution / Next Steps |
|---|---|---|---|---|
| CO 29 | CARC (Claim Adjustment Reason Code) | Time limit for filing claim expired. | Universal — used by most state Medicaid and MCO systems. | Cannot be appealed unless a valid timely filing exception is documented; otherwise final denial. |
| CO 146 | CARC | Out of timely filing period or exceeded state’s submission limit. | Common in Georgia, Illinois, Pennsylvania, and several MCOs. | Review DOS and resubmission logs; submit Late Filing Exception Form if eligible. |
| N39011 | State-specific / Institutional Remark Code | Timely filing expired (institutional claims). | Used by some states (e.g., Florida, Washington, Louisiana) and Medicare crossovers. | Reopen only if proof of exception (retroactive eligibility, crossover, or system error). |
| MA39 / M290 | RARC (Remittance Advice Remark Code) | Missing or incomplete information caused claim to exceed timely filing. | Used in conjunction with CO 29 or CO 146. | Correct missing data and resubmit within window (if still open). |
| CO 252 | CARC | Claim was not received within plan filing deadline for MCO claims. | Common in UnitedHealthcare, Aetna, and Centene MCO systems. | Submit reconsideration request if documentation shows timely submission attempt (e.g., 277CA log). |
| CO 252 with N706 | Combo Code | Late filing + plan-level rule exceeded. | Appears in MCO ERA/835 files. | File appeal or reconsideration per MCO’s timely filing policy. |
| CO 128 | CARC | Claim/service was submitted too late. | Some MCOs and clearinghouses use interchangeably with CO 29. | Review plan manual for specific days limit; include EDI proof of submission if appealing. |
⚡ Key Denial Code Insights (2025)
- CO 29 remains the universal code for both Medicaid and Medicare late filings.
- CO 146 and CO 252 often appear in state-managed Medicaid systems or MCOs that use proprietary logic.
- N39011 is common on institutional (UB-04) claims that miss deadlines in crossover situations.
- Most MCOs treat these denials as final unless an approved exception is attached at resubmission.
How to Handle Medicaid Late Filing Denials
| Step | Action | Purpose |
|---|---|---|
| 1 | Identify denial code on ERA/835 or paper RA. | Confirms whether it’s a filing-limit denial. |
| 2 | Review the Date of Service (DOS) vs. claim receipt date. | Verifies if truly late or a system error. |
| 3 | Check for an exception trigger (retroactive eligibility, system issue). | Determines if reopening is possible. |
| 4 | If eligible, submit Late Claim Exception Form with supporting documents. | Requests review under 42 CFR §447.45(d)(4). |
| 5 | Keep proof (screen captures, 277CA, eligibility letter). | Required for audits and future appeal tracking. |
💡 Pro Tip
If your clearinghouse shows a claim was transmitted before the deadline but Medicaid denies it as “late,” attach your EDI transmission proof (277CA acknowledgment) to the Late Claim Exception form. Most states — including Texas (TMHP) and Ohio Medicaid — will honor this documentation if the state’s system date mismatch caused the denial
Key Takeaways
In 2025, Medicaid claim submission deadlines remain one of the most critical compliance factors in medical billing. While federal CMS regulation (42 CFR § 447.45) sets a maximum 12-month filing window, most states enforce shorter limits—often 90, 120, or 180 days—and Managed Care Organizations (MCOs) may shorten them even further. Missing these deadlines leads to denials such as CO 29, CO 146, or N39011, which are often final unless a valid exception applies. Limited exceptions exist for retroactive eligibility, system or administrative errors, provider enrollment delays, and disaster-related disruptions, but each requires clear documentation like eligibility letters or EDI proof. To stay compliant, providers must maintain submission logs, audit trails, and awareness of both state and MCO-specific timelines.
At MedStates, we help practices eliminate timely filing denials through proactive Medicaid billing management, automated claim tracking, and exception handling support.
👉 Contact MedStates today to verify your state’s Medicaid deadlines and keep your reimbursements fully protected in 2025.
