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Back  RFI # 930: COBRA Continuation Coverage

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Marcia Henderson


How should information be returned in the 271 response to meet IRS regulations Sec. 54.4980B-6 and 54.4980B-8 regarding COBRA Continuation Coverage? In Questions 3 of 54.4980B-6, plans must disclose specific information to a provider when they contact a health plan to confirm coverage.

Submitter Assigned Keywords

COBRA Continuation Coverage


The 005010X279 TR3 has a number of segments, data elements and code values relating to COBRA. The 2100C/D DTP01 Date/Time Period Qualifier and 2110C/D EB04 Insurance Type Code are elements that can identify COBRA coverage details. Additionally, all 271 responses must comply with the HIPAA requirements outlined in section


While 005010X279 does not explicitly address IRS requirements regarding COBRA Continuation Coverage within X12N 270/271 Health Care transactions, the following may be used to address the questions asked above:

2110C/D EB01 values 1-8 (more specifically, 5 Active - Pending Investigation 8 Inactive - Pending Investigation) as appropriate to identify conditional active or inactive coverage.

Contact information for the plan can be included in the corresponding 2120 loop.

The 2110C/D MSG segment can be used to identify any text needed to satisfy IRS requirements that cannot be codified elsewhere in the transaction (see Section 1.4.12 for requirements on the proper use of MSG segments). The use of the MSG segment is a temporary solution. Please work with WG1 to address this need in a codified solution for future version of the 270/271.

If the response above does not give you details to your question, please approach WG1 with details or change requests.
Submission 12/23/2009
Status Date 11/5/2010
Status F - Final
Primary References
Document 005010X279
Set ID271