The SMRC Is Reviewing Claims You Billed in March

If you billed J3300 between January and March, the review is already open.

Noridian posted project 01-176 on September 29, six months after the quarter closed. The window under review runs January 1 through March 31, 2026.

Eighty-nine days.

That is the Supplemental Medical Review Contractor working on claims plenty of practices have not finished reconciling.

What the SMRC Actually Has Open

Fifteen projects, and the oldest date of service any of them touches is January 1, 2023 (chart below).

The right edge is the part worth staring at. Three of the fifteen reach into claims Medicare paid you this year:

01-173, long-term care hospitals in the Northeast, takes dates of service through June 30, 2026, and its page says CMS directed Noridian to start on July 20, 2026. Twenty days after the window closed.
01-169, the second pass at chronic venous insufficiency, runs through June 17, 2026.
01-176, the Triesence coding project, is the Q1 window above, scoped as outreach and education rather than post-payment review.

Three of the fifteen also carry OIG in the project title, which is the SMRC saying out loud where the topic came from.

The Windows Doubled

Pull the date-of-service window off all fifteen open pages and the median is 730 days. Eight of them run two years or longer, and five are exactly 730.

Now pull the same number off the 93 completed projects that publish one. The median there is 364 days, a single calendar year, and 64 of the 93 are 366 days or shorter.

Only 11 reach two years.

So the open book's median window is exactly twice the completed record's. Two things follow for anyone who gets the letter:

One additional documentation request now reaches across two fiscal years of the same code family, which means two coding-guidance regimes and, often, two different sets of people who prepared the documentation.
A denial pattern that used to surface against one year of volume gets extrapolated against two.

Why Nothing Starts Before October 2022

Look at the accent line on the chart. Not one span crosses it.

"Within 4 years from the date of the initial determination or redetermination for good cause."

That sentence is 42 CFR 405.980(b)(2), the outer limit on a contractor reopening a paid claim on its own motion. Inside one year it can reopen for any reason.

Past four, it needs reliable evidence that the determination was procured by fraud or similar fault.

01-176's own references section cites §405.980 and Chapter 34, §10.6 of the Claims Processing Manual, "Timeframes to Reopen Claim Determinations." The contractor names the clock it is running against before it asks for a single record.

Here is the catch, and it is in the same regulation. 405.980(a)(2) says that when a contractor denies a claim because it never received the documentation it asked for, and you then request a redetermination, the contractor processes that request as a reopening. The lead denial reason across the completed SMRC record, repeated verbatim page after page, is no response to the documentation request inside the 45 calendar days chapter 3 of the Program Integrity Manual allows.

Miss the ADR deadline and your first appeal spends itself buying back a reopening you already had.

Final Thoughts

The outcomes on the finished work are the reason any of this is worth an afternoon.

Across the 96 completed projects carrying a published error rate, the median is 53.5%. Fifty-three of them land at or above 50 percent, 25 at or above 75, and three sit at 100%.

The old defense against a post-payment review was arithmetic. By the time a demand letter arrived, the claim was usually old enough that somebody's clock had run out first, and the fight was about timeliness instead of documentation.

Nothing on this list offers that. Every open window sits inside the four-year line, and one of them closed in June.

Which leaves the unglamorous version: read the fifteen titles, find the two or three that match your mix, and confirm the records for 2024 and 2025 can come out of the system in under 45 days. The SMRC publishes the list on purpose, and it notes that at CMS discretion not every project appears there at all.

Thanks for reading.