If a provider is not enrolled with Medicare, they generally **cannot** bill Medicaid/PASSE for therapy services provided to Medicare-eligible clients. Medicaid is required to be the payer of last resort — it cannot be billed when the client has Medicare and the provider is not enrolled with Medicare to bill primary.

Options for providers not enrolled with Medicare:
– Refer Medicare-eligible clients for therapy to a provider that is enrolled with Medicare.
– Pursue Medicare enrollment — the process through Palmetto GBA (the Arkansas Medicare Administrative Contractor) takes several months but is essential for ADDT programs serving adults who may have Medicare.
– Some providers have separate therapy entities (or contracted therapy groups) that are Medicare-enrolled to handle this billing.

This is a compliance-critical area — billing Medicaid for therapy on a Medicare-eligible client without billing Medicare first can constitute a Medicaid billing violation.