Susan,
There are two models of COB.
One of these, which I will call Model A, does not
require use of a separate COB standard. The X12 837 (claim) transaction
allows a provider to report an earlier payer's reimbursement when billing the
next payer. That is the Provider-to-Payer-A-to-Provider-to-Payer-B model.
Model B, or Provider-to-Payer-A-to-Payer-B
COB, is what the COB provisions of the TCS regulations address. Here,
again, the X12 837 is used, but now Payer A reports how it paid directly to
Payer B, instead of forcing the provider to do so. This is usually
done when two payers share a substantial volume of multi-payer claims, such
as between a Medicare Payer and a Medicare Supplemental Plan, or between
Medicare and Medicaid, or either of those and a local BC/BS Plan.
If a provider is using Model A COB, their COB
transaction coveredness is essentially a subset of their claims transaction
coveredness. If they do any claims electronically, whether with single or
multiple payers, they are covered.
Under Model B, only the Health Plan's coveredness
is an issue. Whether two health plans conduct COB at all is a business
decision. If they do so, and also choose to do it electronically, they
must use the 837. But that is their choice, and doesn't affect the
coveredness of the providers that submitted the associated claims to Payer
A.
Are their any other thoughts on this out
there?
- Zon Owen -
(808)597-8493
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