Anticipated Extension of Use of Delay Reason Code 15

August 29, 2024

The day after the CHANGE Healthcare attack was reported in the media, the NYS Council went to work to ensure providers are paid for services rendered before, during and after the cyber event.  Several months ago we worked with our colleagues at CHCANYS to compel the state to issue a Delay Reason Code 15 option for coders to use to indicate a Medicaid Fee for Service claim had been caught up in the CHANGE Healthcare attack, the claim was late for this reason and the payer should pay the claim.  But use of the DRC 15 was set to expire tomorrow (August 30). We know you are struggling to obtain the information you need to file mental health and/or substance use disorder service claims timely, or to re-submit claims.  So earlier this week the NYS Council went to OMH and requested an extension for use of the DRC 15 for Medicaid FFS claims. DoH agrees and the state is extending use of DRC 15 for “another 30 days at least.”   I’m going to assume this includes OASAS since the option to use this DRC was/is for both OASAS and OMH providers. We will push for a more robust extension of the deadline but we first needed something quick.  Something in writing is coming on this ‘shortly’.  Stand by.

Thanks are due to the folks in both state agencies for hearing our concerns and responding quickly and (as always) to our Billing Geeks for elevating the problem in the nick of time!

I pasted the eMedNY Advisory from June 2024 re: use of DRC 15 (below).  The first Memo re: use of DRC 15 went out from OMH on May 20, and the OMH update was issued on June 7, fyi.

Change Healthcare/Optum Cybersecurity Incident, Delay Reason Code 15 (Natural Disaster) Guidance
Due to the cybersecurity incident that occurred with Change Healthcare/Optum on February 21, 2024, claims that exceed the timely filing limits may be submitted electronically using Delay Reason 15 (Natural Disaster). There is no additional documentation required to use Delay Reason 15; however, where particular claims require documentation, such as invoices for pricing, the claim and all necessary documentation should be submitted as a paper claim along with the delay reason form indicating delay reason 15. Providers should also maintain documentation that supports being affected by this incident.

Claims must be submitted by August 30, 2024, to be considered for payment. Claims that are payable using Delay Reason 15 are all claims that couldn’t be submitted timely due to the Change Healthcare/Optum cybersecurity incident only. Submitting claims that do not meet this purpose with Delay Reason 15 is not permitted and may be considered Medicaid fraud subject to review by the Office of the Medicaid Inspector General.

Claims for this incident submitted after August 30, 2024, with delay reason 15 will be denied.

General questions for claims submission should be directed to the eMedNY Call Center at 1-800-343-9000. Questions on specific claims that are pended for review should be directed to the Bureau of Medical Review, Pended Claims Unit at 1-800-342-3005 (option 3).