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Denial code · group CO

CO-22: Another plan appears to be primary; the payer wants that plan's payment before it pays

Short answer

CO-22 means the payer's records show another plan should pay first, so it will not adjudicate until it sees that plan's payment or a corrected coordination of benefits record. If the other coverage is real, bill it and then send this payer a secondary claim with the primary's adjudication. If it is old or wrong, the member has to update the record with the plan before you resubmit.

Look up other codes in the denial code library.

Last reviewed by the Remitwright billing team. Editorial policy

  • Group CO · Contractual obligation

Group CO means contractual obligation: the balance is written off, not billed to the patient. The number is the reason; the two-letter group says who carries the balance.

Remark codes that usually come with CO-22

MA04
The secondary needs to know who the primary was and what it paid, and the claim did not show it
N4
The prior insurer's explanation of benefits is missing or incomplete
MA92
The claim leaves out the details of the member's other coverage

Common causes

The payer's file shows other coverage

An employer group plan, an auto or liability carrier, or a workers' compensation claim is recorded as primary for this member. Medicare runs a Medicare Secondary Payer program so that it does not pay first when a group health plan, workers' compensation, liability or no-fault insurer should. Commercial plans and Medicaid run similar checks.

Coverage that ended but was never closed

The member left a job or dropped a spouse's plan, nobody told the payer, and the payer's record still shows that plan as primary. Every claim denies CO-22 until the member updates the record.

Dependent children with two parents' plans

Both parents carry family coverage and the claim goes to the plan the family named at check-in. The plan applies its dependent coordination rule and decides the other parent's plan pays first.

A secondary claim without the primary's adjudication

The claim was meant for the secondary but went out without the primary's paid amount, adjustment codes and remittance date in the claim data, or without the EOB attached where the payer requires paper. MA04 or N4 names the gap.

An accident or injury diagnosis

A diagnosis that suggests an injury makes the payer ask whether auto, liability or workers' compensation coverage applies. Until the member or the office answers, the claim sits in CO-22.

How to fix it and resubmit

  1. 1

    Read the eligibility response, not just the denial

    Run a fresh 270/271 for the date of service and read the other-payer segments. The payer will often name the plan it believes is primary. Compare that to what the patient told you at intake.

  2. 2

    Bill the real primary first

    If the other coverage exists, send an original claim to that plan. When its 835 arrives, build the secondary claim with the primary's paid amount, adjustment codes and dates in the claim data, or the EOB attached for payers that want paper, and resubmit to the payer that denied CO-22.

  3. 3

    Get the member to correct the record

    When the other coverage is gone, the payer usually accepts a coordination of benefits update only from the member. Give the patient the payer's phone number and the exact information to update, then confirm with the payer before you resubmit. A termination letter from the old plan speeds this up.

  4. 4

    Answer the accident question

    For injury diagnoses, confirm with the patient whether a third party is involved and report it to the payer through its accident or subrogation questionnaire. If none is involved, the payer clears the hold and reprocesses; if one is, bill that carrier.

  5. 5

    Protect the filing window

    Document every call and the date the member updated coordination of benefits. If the resubmission arrives after the filing limit, that record supports a timely filing appeal.

How to prevent it

  • Eligibility checks that read the other-payer segments of the 271 at every visit, not just active or inactive status
  • A coordination of benefits question at check-in once a year and after any change of job, marriage or dependent status, recorded in the practice management system
  • Secondary claims held until the primary 835 posts, then built from the primary's adjudication automatically
  • Medicare patients asked the secondary payer questions at intake so group health, liability and workers' compensation coverage is found before the claim goes out
Worked example · hypothetical

A CO-22 on a working Medicare beneficiary

An internal medicine practice bills Medicare for an office visit for a 67-year-old patient who is still working. Medicare denies CO-22 with MA04 because its records show the employer's group health plan as primary. At intake the patient had only shown his Medicare card. The biller confirms the employer plan on the 271, bills it as primary, waits for its 835, and then sends Medicare a secondary claim with the group plan's paid amount and adjustments. Medicare pays its secondary share. The practice adds the secondary payer questions to its intake for every Medicare patient. This is a hypothetical example.

Official text: the X12 claim adjustment reason code list. The meaning above is our paraphrase for billers; the list is the authority.

Next step

The fix for CO-22 sits with eligibility verification.

See eligibility verification

FAQ

Questions about CO-22

Is CO-22 a denial I can appeal?

Rarely. The payer is not disputing the service; it is saying another plan pays first. The fix is to bill the right plan or to have the member correct the coordination of benefits record. An appeal letter without one of those does not move the claim.

The patient says there is no other insurance. What now?

The payer's record still shows one, and the payer will usually only change it on the member's word. Have the patient call the payer, note the date and the reference number, then confirm the record is clear before you resubmit.

What does Medicare mean by secondary payer?

Medicare runs a Medicare Secondary Payer program so that it does not pay first in situations where a group health plan, workers' compensation, liability or no-fault insurance should pay. When Medicare's records show one of those, the claim comes back CO-22 until the primary payer's payment is reported.

Can I bill the patient while CO-22 is unresolved?

No. CO means contractual, and the payer has not adjudicated the claim. Billing the patient for a claim that is waiting on coordination of benefits creates a complaint and still does not get the claim paid.

How long do I have to resubmit after a CO-22?

The payer's filing limit still applies, counted the way the payer counts it. Some payers allow extra time for secondary claims measured from the primary's remittance date; others do not. Document the coordination of benefits work so you can appeal a timely filing denial if the resubmission runs late.

Next step

Seeing a lot of CO-22?

Tell us the payer and the volume. Three quick questions, no patient data, a written answer from a biller who works that queue.

  • Three questions, about two minutes
  • No patient data, no software to buy
  • A written reply from a biller, not a sales deck

What happens next

  1. You answer three questions

  2. A billing specialist reads them

  3. A written reply by email

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Seeing a lot of CO-22?

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Step 1 of 3

What do you bill for?

A little about your volume
How many providers? (Medical practice)

Trips per month? (NEMT)

Active clients? (Home care / home health)

Orders per month? (DME)

How many clinicians? (Behavioral health / therapy)

Claims per month, roughly? (Something else)

What's the biggest problem right now?

Where should we send the review?

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See where claims are getting stuck. No patient data needed.

Step 1 of 3

What do you bill for?

A little about your volume
How many providers? (Medical practice)

Trips per month? (NEMT)

Active clients? (Home care / home health)

Orders per month? (DME)

How many clinicians? (Behavioral health / therapy)

Claims per month, roughly? (Something else)

What's the biggest problem right now?

Where should we send the review?

Add details (optional)

We work inside your system; this tells us which login to ask for.

Please don't include patient information in this form.

  • No patient data requested
  • No obligation
  • Reply in writing

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