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Back  RFI # 172: 837 - Multiple Primary Payers

Formal vs. Informal Help Informal Formal

Submitter

Carol Lewis

Description

We have reviewed the 837P Implementation Guide and need further assistance. Our interpretation of the 2000B and 2320 loops is that only one primary payer may be submitted; either in the 2000B or 2320 loop. We reviewed sections 1.3.1, 1.4.2 and the text associated with each loop. In addition, we reviewed the business scenarios and although the examples contain one primary; it does not specifically indicate that multiple primary payers could not be submitted.

Please provide your opinion. Does HIPAA allow multiple primary payers?

2000B SBR01 = P; 2320 SBR01 = P
2000B SBR01 = P; 1st 2320 SBR01 = S, 2nd 2320 SBR01 = P
2000B SBR01 = S; 1st and 2nd 2320 SBR01 = P

Response

This issue is addressed in multiple locations of guide 004010X098. Section 1.4.2.1, figures 1 and 2, and section 1.4.2.1.1 all identify the flow of formation for the 837 claims in a coordination of benefits environment. Within those flows, the presence of multiple primary payers would be illogical. As such, multiple primary payers within a single claim in an 837 is not consistant with the guide. This response does not address HIPAA policy issue questions, which should be directed to askhipaa@cms.hhs.gov.

Recommendation

Submission 1/6/2005
Status Date 1/24/2005
Status F - Final
Primary References
Document 004010X098A1
Section1.4.2
Page17
Set ID837P
Table2
Loop2000B
Segment Position005
Segment IDSBR
Element Position01
Industry NamePayer Responsibility Sequence Number Cod
Code ValueP
Secondary References
RFI ID 138
Document 004010X098A1
Section1.4.2
Page17
Set ID837P
Table2
Loop2320B
Segment Position290
Segment IDSBR
Element Position01
Industry NamePayer Responsibility Sequence Number Cod
Code ValueP