Coordination of Benefits: Everything You Need to Know

COB, or coordination of benefits, occurs when an individual is in possession of more than one insurance policy and it comes to processing a claim. 4 min read updated on February 01, 2023

Also referred to as COB, coordination of benefits occurs when an individual is in possession of more than one insurance policy and when it comes to processing a claim, the policies are assessed to determine which will be assigned with the primary responsibility for covering the predominant share of the claim costs.The process also involves assessing the extent that other policies held will contribute toward the claim. This article will provide you with everything that you need to know about coordination of benefits.

What Is Coordination of Benefits?

The primary intentions of coordination of benefits are to make sure that individuals who receive coverage from two or more plans will receive their complete benefit entitlement and to prevent benefits from being duplicated when an individual has more than one policy in place. This process covers insurance pertaining to several sectors including health insurance, car insurance, retirement benefits, workers compensation, and others.

The order in which the insurance policies are coordinated is dictated by insurance law and cannot be decided by a company or an individual. This process takes place only when multiple insurance plans are involved. If only one plan is held, then all responsibility is put onto the sole plan.

Predominantly, coordination of benefits happens when an individual has two plans in place (primary and secondary), but it may also include a tertiary plan in some circumstances. The primary insurance plan is given the responsibility of being the first payer, the secondary plan is the second payer, and so on depending on how many plans the individual holds.

Why Is COB Important?

There are numerous reasons why COB is an important process. These are summarized below:

  • A lack of coordination between the plans a person holds can result in the claim not being paid until the COB has been confirmed, thus potentially causing financial difficulties.
  • Either the individual or the insurance provider could be subjected to expenses that they did not need to pay if the insurance plans are not coordinated correctly.

Order of Benefit Determination

The primary plan is always considered as the predominant provider of benefits, and it must provide these as though the claim holder does not have a second or third policy in place. The COB provisions that are specified in the insurance policy outline which plan is the primary plan. Once identified, the primary plan's benefits are applied to the claim first.

It is important to note that the primary plan is always considered as the first payer, regardless of the specifics written in its clauses. This means that any plan that does not include the COB provisional clause may not incorporate the benefits offered by a claimant's other plan into their considerations when assessing what benefits are due.

Any unpaid balance owed to the patient is typically paid by the claimant's second plan, within the limits of its responsibility. This secondary insurance plan can take the benefits of the patient's other plans into consideration only when it has been confirmed as being the secondary — not primary — plan.

The payments that are delivered to the patient by their combined insurance plans do not exceed 100 percent of the charges for necessary covered services. The benefits are usually coordinated between all of the plans held by the patient.

If a family is making a claim, each individual and their COB will be assessed separately, as there is a possibility that the order of plans and benefits may differ between each member.

There may be some differences to the "order of benefit determination" as laid out here if the claimant's policy is held with Medicare, but otherwise, these rules should be followed as a standard process.

Understanding Various COB Rules

Common COB circumstances and how the COB rules are then applied are outlined below.

  • Plan Type Rule If the individual has both a commercial insurance plan and Medicaid, then the commercial plan will always be considered as the primary policy, and Medicaid is secondary.
  • Subscriber or Dependent Rule If a patient subscribes to two or more policies, where one policy is as a subscriber, and another is as a dependent, then the policy under which they are classified as a subscriber is the primary policy, and that where they are a dependent will fall as the secondary policy.
  • Timeline Rule If the patient is the primary subscriber to two commercial plans, then the plan to which they have been subscribed the longest is considered as the primary plan, and the newer plan is the secondary.
  • Employer Coverage Rule If the individual has coverage both through their employer and as a dependent through another commercial plan, then the employer-operated plan will always be considered as the primary plan.
  • 1. The birthday rule of the parent (whoever's occurs earlier in the year) and,
  • 2. The length of policy rule of the policy holders (whichever commenced first).
  • Dependent Child (Parents Not Separated or Divorced) Rule If a child's parents are together, then determining the primary plan is done by using the birthday rule (i.e. whoever was born earlier is responsible).

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Benefits of Having 2 Health Insurance Plans

How Does Having More Than One Health Plan Work?

What Is Coordination of Benefits?

How having two health plans works.

  • Should You Keep Two Health Insurance Plans?

Understanding Coordination of Benefits System

Medicare combined with a group plan, reasonable and customary costs, you may still need to pay some costs, frequently asked questions (faqs).

The Balance / Bailey Mariner

Having access to two health plans can be good when making health care claims. Having two health plans can increase how much coverage you get. You can save money on your health care costs through what's known as the "coordination of benefits" provision. Here's what you need to know about using two health care plans and how it works.

Key Takeaways

  • Having access to two health plans can increase how much coverage and save money on your health care costs through the "coordination of benefits" provision.
  • When an insured person has two health plans, one is the main plan, and the other is the second plan.
  • In there's a claim, the primary health plan pays out first, while the second plan pays some or all of the costs the first plan didn't pay.
  • If you and your spouse or partner both have a health care plan at work, and your children are covered on both plans, the second plan can pay some of the costs the first plan didn't.

When a person is covered by two health plans , coordination of benefits is the process the insurance companies use to decide which plan will pay first and what the second plan will pay after the first plan has paid.

As an example, if your spouse or partner has a health care plan at work, and you have access to one through work as well, your children could have coverage through both plans. Once the main plan pays, rather than having to pay the rest, you could see the second plan paying some of what you would have had to pay if you didn't have it. You can use both plans to get the most out of your children's health care.

In some cases, one plan may provide better care in one area, like mental health coverage . The other plan may offer better coverage in some other area. You can get the best of two health plans when you combine care.

When an insured person has two health plans, one is the main plan, and the other is the second one. In the event of a claim, the primary health plan pays out first. The second one kicks in to pay some or all of the costs the first plan didn't pick up. Some of the health care costs to consider when deciding how to manage your health care plans are outlined below.

Your deductible is the amount you need to pay out of pocket each year before your insurance covers any of your medical costs, including appointments and prescriptions. For example, your insurance plan might have a $2,000 annual deductible, which means you need to cover the first $2,000 in costs each year before your insurance covers any expenses.

A copay —short for copayment—is an amount you pay at the time of each doctor’s appointment. Typically it's a small fee, such as $15 or $25 for your primary doctor. However, the copay might be higher for a specialist or other service.

Coinsurance

Coinsurance is a set percentage of the cost of service that you must share in paying. For example, your insurance provider might pay 80% of the cost of a service, while you'd be responsible for 20%. Coinsurance costs can be expensive if you or a family member need extensive care, such as a hospital stay or surgery.

Should You Keep Two Health Care Plans? 

If you have access to two health care plans, you could end up paying less money out of your own pocket for expenses the first plan doesn't cover. For example, if your first plan has a deductible or copay, the second plan may pay for that.

Does a person with two health care plans get double benefits? Not exactly. Having two health plans does help cover any health care costs better through the coordination of benefits provision.

If you are thinking you will save money on health insurance by only having one plan, think about how combining care works and what health care costs you have before signing a health insurance waiver and giving up a second plan. If your plan through your own job is free, and your partner can add you to their plan for a low cost, you should keep both plans.

Here's how a person may have two health care plans:

  • A child's parents each have access to a health plan at work. Children can be covered under both plans if the parents decide to include them.
  • Married couples or domestic partners who each have access to a health plan through their job may put each other on their plans.

The health plan coordination of benefits system is used to ensure both health plans pay their fair share. When both health plans combine coverage in the right way, you can avoid a duplication of benefits while still getting the health care to which you're entitled.

Health plans combine benefits by looking at which health plan is the patient's main plan and which one is the backup plan. There are guidelines set forth by the state and health plan providers that help the patient's health plans decide which health care plan is the main plan and which is the second plan.

If you have two health plans, you may be asked to declare which one you want to name as your main plan. Do your research to decide which plan will work better as your main plan.

Once you've named one plan as your first plan, that plan will pay what is required without looking at what the second plan covers. Once the main plan has paid the costs it has to pay, the second plan will be used.

Your second health plan, unlike your first plan, can look at what health care service was provided to you by the main plan. The health care costs that are still due will then be looked at for payment under the second health care plan.

If you’re 65 or older, have group health plan coverage based on your or your spouse's current employer, and it has 20 or more employees, the group plan will pay first. If they have less than 20 employees, Medicare will kick in first.

There are some rules that health plan providers follow that could cause a person covered by two plans to still have to pay for some health care costs . One such area is the "reasonable and customary" amount.

Most health plans will only cover costs that are reasonable and customary. In other words, the health plan provider will not pay for any services or supplies that are being billed at a cost that is more than what is the usual charge for the treatment in the area where the treatment takes place.

Once your main plan pays the reasonable and customary amount on a health care service, there may still be a balance due. This could happen if the health care provider was charging more than what the main plan felt was reasonable and customary.

The second plan does not have to pay the amount the first plan did not pay if the charge is deemed out of the normal limit. The insured person could still end up paying out-of-pocket. This could still happen even if there are two health plans.

What's more, neither health care plan will cover the cost of a service that is not covered under their health care plans. If both plans do not cover a certain test, for example, the second one doesn't have to pay after the first one denies the expense.

People with more than one health care plan should discuss with their health plan providers how combining plans will work with their plans. This way, they can see what health care coverage they can expect.

If you have two insurances, will you have a copay?

If you have two health insurance plans, the second may pick up any copayments or additional costs that were not covered by your primary insurance. Your copay may or may not be covered. So, be sure to check with each of your insurance plans.

Will I lose my Medicaid when I am eligible for Medicare?

No, Medicaid and Medicare work together well, and between the two, most of your costs should be completely covered. Some states even offer Medicaid-Medicare plans that offer more coverage options.

National Association of Insurance Commissioners. " Using Your Health Plan ," Page 17.

Nebraska.gov. " Title 210 - Nebraska Department of Insurance: Chapter 39 - Coordination of Benefits Regulation ," Pages 24-26.

Nebraska.gov. " Title 210 - Nebraska Department of Insurance: Chapter 39 - Coordination of Benefits Regulation ," Pages 14, 18.

Nebraska.gov. " Title 210 - Nebraska Department of Insurance: Chapter 39 - Coordination of Benefits Regulation ," Page 1.

Nebraska.gov. " Title 210 - Nebraska Department of Insurance: Chapter 39 - Coordination of Benefits Regulation ," Page 17.

Centers for Medicare & Medicaid Services. " Medicare & Other Health Benefits: Your Guide to Who Pays First ," Pages 6, 12-13.

New York State. " Usual and Customary or Reasonable Fees for Health Insurance Reimbursements ."

National Association of Insurance Commissioners. " Coordination of Benefits Model Regulation ," Pages 120–1-120–2.

Medicare. " Medicaid ."

What is Coordination of Benefits?

what is a coordination of benefits used for

Coordination of benefits (COB) refers to determining how multiple health insurance plans work together to cover a person’s medical expenses, ensuring that total payments do not exceed the actual cost of care.

Coordination of benefits must occur when a person holds multiple health insurance policies. If you have two plans, your insurers coordinate to determine which policy is the primary and which is the secondary. Coordination of benefits helps avoid duplicate expenses and keeps healthcare and prescription costs affordable for all policyholders .

Table of Contents

How common is double coverage.

Healthcare can be complex, and some people may need to enroll in multiple healthcare plans to cover all of their medical needs. It also may come as a matter of convince if both your and spouse have employer-provided care. 

Dual coverage through Medicare and a private or group insurer is especially common. More than half of  seniors age 65 or older  in the U.S. in 2021 held more than one health insurance policy, compared to only 6% of adults aged 19-64 that same year. 

Dual benefits are common among the following groups:

  • Working couples who each have employer-sponsored health insurance
  • People who are still working but are eligible for Medicare
  • Someone who holds private insurance and is eligible for Medicaid
  • A young adult who is on their parent’s insurance and an employer-provided plan

How Does the Coordination of Benefits Work?

COB applies to dual group coverage, Medicare and Medicaid , extended coverage such as COBRA , or dependent coverage when combined with another healthcare plan.

The coordination of benefits still largely follows the guidelines set by the National Association of Insurance Commissioners (NAIC) in 1971 including identifying a primary and secondary plan and using the “ birthday rule ” to cover dependents with double coverage. The birthday rule is for dependents who have coverage from both parents: the parent with the earlier birthday is the primary coverage, and the other parent is the secondary. 

Eligibility

You will experience coordination of benefits if you hold two different insurance plans. Eligibility for COB requires you to keep up on premiums for both plans. Additionally, you must adhere to each policy’s individual deductible , copay , and coinsurance terms. Always confirm your eligibility for each of the respective plans with an insurance agent. 

How Is the Primary Payer Determined?

what is a coordination of benefits used for

The process of coordination of benefits follows certain universal guidelines to determine a primary and secondary plan. 

For example, Medicare typically acts as the primary payer if combined with another type of insurance, and the birthday rule applies to two employer-funded plans. Your healthcare provider can bill your secondary plan to pay the remainder of medical costs only after the primary plan pays its share. 

The rules on which insurer becomes the primary payer vary by situation, so it’s good practice to carefully review your policy terms and seek help if you need clarification. Understanding your coordination of benefits will ensure your healthcare costs are covered.

When Is the Coordination of Benefits Necessary?

The following are among the most common scenarios requiring coordination of benefits:

  • You have employer-sponsored health insurance and are also covered by your spouse’s employer-sponsored plan
  • You have health insurance through a private insurer and are also covered by your spouse’s group health insurance plan
  • You and your spouse’s plans both cover your dependent child or children
  • You receive Medicare and are also insured through your current employer   

Each scenario will have different ways of establishing the primary and secondary plans. It often looks like the examples below. 

The Methods of COB

A COB “method” is used to determine how your primary and secondary plans will share the costs of your medical coverage.

Full Method

Under the full method, the primary payer covers the claim as if you have no other insurance and applies the costs toward your deductible. After the primary payer has paid its part, the secondary payer determines its share of other out-of-pocket expenses, such as copays or coinsurance. Together, the two plans pay most or all of what your medical care costs. 

Non Duplication Method

The non duplication method requires the secondary payer to review claims paid by the primary payer. If the amount paid by the primary payer is equal to or more than the amount owed by the secondary payer, the secondary plan does not pay. However, the secondary plan will pay for applicable costs that the primary payer did not cover. 

Traditional

The traditional method of COB combines the coverage of multiple insurance policies to cover 100% of expenses. This process may require your insurers to work together to decide which will cover certain benefits on a case-by-case basis while still relying on select guidelines like the birthday rule. 

The Rules Around the Coordination of Benefits

what is a coordination of benefits used for

Several ground rules exist to help govern coordination of benefits, explained below. If neither plan includes coordination of benefit rules, the plan providing coverage for a longer period pays first.  

  • Employer-sponsored plans : Generally, your employer is the primary payer of your healthcare expenses, and your spouse’s plan is secondary if you both are enrolled in an employer health plan. 
  • Medicare and Medicaid : Medicare acts as the primary payer if the other insurer is a business employing less than 100 people but is the secondary payer to the insurer of a large company. Medicaid typically only pays after the other insurer covers most of the costs.
  • Private health insurance plan and Veterans Administration (VA) benefits : The VA charges health insurance providers for care and services instead of offering traditional health insurance coverage and does not offer secondary benefits. Your private health insurance would be the sole primary payer in this case.
  • Workers’ compensation : If you receive both worker’s comp and traditional health insurance coverage, worker’s comp benefits always pay first, followed by your health insurance plan.
  • Military coverage (TRICARE):  You may only have TRICARE coverage and no other health insurance benefits if you are on active duty; however, TRICARE is considered secondary to all other health plans, except Medicaid, for non-active-duty military service members. 

Determining Out-of-Pocket Costs

Insurers must determine how out-of-pocket costs are paid through COB. This process depends on whether your plans use the full COB method or the non duplication COB method. One of your insurers may cover out-of-pocket costs such as copays or coinsurance that remain after paying for services rendered.

Out-of-pocket costs include copays, or a set fee for doctor visits or prescriptions. Your secondary plan may pay copay costs after your primary plan applies its payment toward the deductible. Coordination of benefits must also be applied to other out-of-pocket expenses such as coinsurance or out-of-network providers, facilities, or prescription drugs.   

what is a coordination of benefits used for

COB In Action

Your insurers must coordinate benefits if you have multiple health insurance plans. Common scenarios requiring COB include spouses with respective employer-sponsored plans, Medicare beneficiaries still working and receiving group healthcare benefits, and adults up to age 26 who buy their own coverage but also remain on their parent’s plan.

Insurers use various methods and rules to determine the primary and secondary plans. You should review your policies and speak with an expert to ensure you understand your coordination of benefits. 

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Coordination of Benefits and Recovery Overview

Guidance for Coordination of Benefits (COB) process that allows for plans that provide health and/or prescription coverage for a person with Medicare to determine their respective payment responsibilities.

Issued by: Centers for Medicare & Medicaid Services (CMS)

Issue Date: June 30, 2020

Coordination of benefits (COB) allows plans that provide health and/or prescription coverage for a person with Medicare to determine their respective payment responsibilities (i.e., determine which insurance plan has the primary payment responsibility and the extent to which the other plans will contribute when an individual is covered by more than one plan).  

The COB Process:

  • Ensures claims are paid correctly by identifying the health benefits available to a Medicare beneficiary, coordinating the payment process, and ensuring that the primary payer, whether Medicare or other insurance, pays first.
  • Shares Medicare eligibility data with other payers and transmits Medicare-paid claims to supplemental insurers for secondary payment. Note: An agreement must be in place between the Benefits Coordination & Recovery Center (BCRC) and private insurance companies for the BCRC to automatically cross over claims. In the absence of an agreement, the person with Medicare is required to coordinate secondary or supplemental payment of benefits with any other insurers he or she may have in addition to Medicare.
  • Ensures that the amount paid by plans in dual coverage situations does not exceed 100% of the total claim, to avoid duplicate payments.
  • Accommodates all of the coordination needs of the Part D benefit. The COB process provides the True Out of Pocket (TrOOP) Facilitation Contractor and Part D Plans with the secondary, non-Medicare prescription drug coverage that it must have to facilitate payer determinations and the accurate calculation of the TrOOP expenses of beneficiaries; and allowing employers to easily participate in the Retire Drug Subsidy (RDS) program. Please click the Coordinating Prescription Drug Benefits link for additional information.

COB Data Sources

COB relies on many databases maintained by multiple stakeholders including federal and state programs, plans that offer health insurance and/or prescription coverage, pharmacy networks, and a variety of assistance programs available for special situations or conditions. Some of the methods used to obtain COB information are listed below:

Voluntary Data Sharing Agreements (VDSAs) - CMS has entered into VDSAs with numerous large employers. These agreements allow employers and CMS to send and receive group health plan enrollment information electronically. Where discrepancies occur in the VDSAs, employers can provide enrollment/disenrollment documentation. The VDSA data exchange process has been revised to include Part D information, enabling VDSA partners to submit records with prescription drug coverage be it primary or secondary to Part D. Employers with VDSAs can use the VDSA to submit their retiree prescription drug coverage population which supports the CMS mission of a single point of contact for entities coordinating with Medicare. Please click the Voluntary Data Sharing Agreements link for additional information.

COB Agreement (COBA) Program - CMS consolidates the Medicare paid claim crossover process through the COBA program. The COBA program established a national standard contract between the BCRC and other health insurance organizations for transmitting enrollee eligibility data and Medicare paid claims data. This means that Medigap plans, Part D plans, employer supplemental plans, self-insured plans, the Department of Defense, title XIX state Medicaid agencies, and others rely on a national repository of information with unique identifiers to receive Medicare paid claims data for the purpose of calculating their secondary payment. The COBA data exchange processes have been revised to include prescription drug coverage.

Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA) – This law added mandatory reporting requirements for Group Health Plan (GHP) arrangements and for liability insurance, including self-insurance, no-fault insurance, and workers' compensation. Insurers are legally required to provide information.

Other Data Exchanges - CMS has developed data exchanges for entities that have not coordinated benefits with Medicare before, including Pharmaceutical Benefit Managers (PBMs), State Pharmaceutical Assistance Programs (SPAPs), and other prescription drug payers. CMS has worked with these new partners to educate them about coordination needs, to inform CMS about how the prescription drug benefit world works today, and to develop data exchanges that allow all parties to efficiently serve our mutual customer, the beneficiary.

COB Entities

Benefits Coordination & Recovery Center (BCRC) - The BCRC consolidates the activities that support the collection, management, and reporting of other insurance coverage for beneficiaries. The BCRC takes actions to identify the health benefits available to a beneficiary and coordinates the payment process to prevent mistaken payment of Medicare benefits. The BCRC does not process claims, nor does it handle any GHP related mistaken payment recoveries or claims specific inquiries. The Medicare Administrative Contractors (MACs), Intermediaries and Carriers are responsible for processing claims submitted for primary or secondary payment.

The BCRC is responsible for the following activities:

  • Initiating an investigation when it learns that a person has other insurance. The investigation determines whether Medicare or the other insurance has primary responsibility for meeting the beneficiary's health care costs.
  • Collecting information on Employer Group Health Plans and non-group health plans (liability insurance (including self-insurance), no-fault insurance and workers’ compensation), and updating this information on Medicare databases every time a change is made to insurance coverage. Information comes from these sources:  beneficiary, doctor/provider of service, employer, GHP, liability, no-fault and workers’ compensation entity, and attorney.
  • Establishing MSP occurrence records on CWF to keep Medicare from paying when another party should pay first. The CWF is a single data source for fiscal intermediaries and carriers to verify beneficiary eligibility and conduct prepayment review and approval of claims from a national perspective. It is the only place in the fee for service claims processing system where full individual beneficiary information is housed.
  • Transmitting other health insurance data to the Medicare Beneficiary Database (MBD) for the proper coordination of Rx benefits.
  • Recovery of Non-Group Health Plan (NGHP) related mistaken payments where the beneficiary must repay Medicare. Please see the Non-Group Health Plan Recovery page for additional information.

Once the BCRC has completed its initial MSP development activities, it will notify the Commercial Repayment Center (CRC) regarding GHP MSP occurrences and NGHP MSP occurrences where a liability insurer (including a self-insured entity), no-fault insurer or workers’ compensation entity is the identified debtor. The BCRC will maintain responsibility for NGHP MSP occurrences where Medicare is seeking reimbursement from the beneficiary.   

When to contact the BCRC:

  • To report employment changes, or any other insurance coverage information.
  • To report a liability, auto/no-fault, or workers’ compensation case.
  • To ask a general MSP question.
  • To ask a question regarding the MSP letters and questionnaires (i.e. Secondary Claim Development (SCD) questionnaire.) For more information, click the Reporting Other Health Insurance link.

Please see the Contacts page for the BCRC’s telephone numbers and mailing address information.

Commercial Repayment Center (CRC) – The CRC is responsible for all the functions and workloads related to GHP MSP recovery with the exception of provider, physician, or other supplier recovery. The CRC is responsible for identifying and recovering Medicare mistaken payments where a GHP has primary payment responsibility. Some of these responsibilities include: issuing a Primary Payment Notice (PPN) to verify MSP information, issuing recovery demand letters when mistaken primary payments are identified, receiving payments, resolving outstanding debts, and referring delinquent debt to the Department of Treasury for further collection actions, including the Treasury Offset Program, as appropriate. Please see the Group Health Plan Recovery page for additional information.

The CRC will also perform NGHP recovery where a liability insurer (including a self-insured entity), no-fault insurer or workers’ compensation entity is the identified debtor. Please see the Non-Group Health Plan Recovery page for additional information.

Medicare Administrative Contractors (MACs) – A/B MACs and Durable Medical Equipment Medicare Administrative Contractors (DME MACs) are responsible for processing Medicare Fee-For-Service claims submitted for primary or secondary payment. These entities help ensure that claims are paid correctly when Medicare is the secondary payer. They use information on the claim form, electronic or hardcopy, and in the CMS data systems to avoid making primary payments in error. Where CMS systems indicate that other insurance is primary to Medicare, Medicare will not pay the claim as a primary payer and will deny the claim and advise the provider of service to bill the proper party.

HHS is committed to making its websites and documents accessible to the widest possible audience, including individuals with disabilities. We are in the process of retroactively making some documents accessible. If you need assistance accessing an accessible version of this document, please reach out to the [email protected] .

DISCLAIMER: The contents of this database lack the force and effect of law, except as authorized by law (including Medicare Advantage Rate Announcements and Advance Notices) or as specifically incorporated into a contract. The Department may not cite, use, or rely on any guidance that is not posted on the guidance repository, except to establish historical facts.

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What is coordination of benefits (COB)?

Providers are exceptional at providing care. If there is one area that they find challenging, it is medical billing. With so many regulations and codes, a myriad of jargon and rules could confuse anyone. Coordination of Benefits (COB) is another terminology used in healthcare. In this article, we will walk you through the meaning of coordination of benefits and the process and rules involved.  

What is Coordination of Benefits?  

Coordination of Benefits (COB) is a process to streamline medical billing services . It helps avoid duplication of coverage and overpayment. Some patients may have more than one source of health insurance coverage. Coordination of benefits (COB) helps healthcare insurance providers determine their payment responsibilities or the percentage a plan contributes to the range if there is more than one payment plan. Simply put, coordination of benefits helps payers determine which health insurance plans are primary and which are secondary. Naturally, the primary health insurance plan pays first. If there are any additional expenses that need to be covered, then the secondary health insurance plan provides extra coverage. In this case, there is still some coverage left after using the secondary and primary healthcare plans; the patient pays out of pocket for those expenses. The term “covered services” refers to the medical treatment, supplies, labor, or medications that insurers offer as part of the benefits of their plans.  

Why is Coordination of Benefits Important?  

Coordination of Benefits (COB) is necessary when an individual is signed up on two plans. Some common examples for requesting coordination of benefits are:   

  • When an individual is under 26 and under their parent’s plan and covered by their employer’s policy.    
  • When a person has a marketplace plan as well as an additional plan.   
  • When more than one guardian or parent covers a child.   
  • When an individual is covered under their spouse’s plan as well as their employer’s policy.   
  • When an individual has Medicare or Medicaid and is covered by a commercial insurance plan.    

Care coordination  helps ensure that the medical billing process is easier for patients. When a patient requests coordination of benefits, the primary insurance provider will take care of the treatment expenses first. As stated before, if there are any other expenses, they will be taken care of by the secondary provider. This ensures that there is no way to receive double benefits from more than one insurance company. It helps reduce the cost of insurance premiums and avoid any situation where the patient has to pay out of pocket due to a lack of coordination between payers. Using coordination of benefits also allows providers to determine which policy should be billed, primary or secondary.    

Coordination of Benefits Rules  

The rules for Coordination of Benefits (COB) vary depends on the place you live, the state you are listed in and most importantly, the type and size of your insurance plans. Some employers may have their own rules set. However, there are some rules that are common:  

  • If a patient has more than one health insurance provider, CMS only pays the remaining payable amount. Depending on the situation. Medicare can even be a primary or secondary payer. If the other provider is a small business, it can be the primary provider too.  
  • When it comes to the case of spouses, spouses can have separate insurance plans as well. In such a situation, your employer’s insurance policy would become the primary plan and your spouse payer will be secondary.  
  • Veterans Administration (VA) is not considered a health insurance plan by CMS. They submit claims for supplies, prescriptions, services, and treatment to public or commercial health insurance companies. If you have VA plan, you must rely on your spouse’s medical insurance plan as your plan.  
  • If an employee is covered by an employer, then their compensation package becomes primary and any other payer, whether Medicare or any other insurance company, becomes secondary.  
  • Military coverage is a secondary healthcare plan. It is the primary payer for the Tricare Supplement, certain federal government programs, and state crime compensation programs. If a member of the military is injured, military coverage is the only alternative available to them.  

Conclusion  

In the intricate world of outsource medical billing , coordination of benefits stands as a crucial process for ensuring fair and efficient payment processes. IT contributes to a more streamlined and cost-effective healthcare system. Coordination of benefits is a part of a complicated medical billing process. CareCloud provides efficient medical billing services that helps providers navigate through the medical billing landscape and maximize reimbursements.

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Coordination of Benefits

Tips for reducing payment delays and improving accounts receivable.

One of the major reasons for delays in claims processing is the need for information to support coordination of benefits. Coordination of benefits (COB) applies to a person who is covered by more than one health plan. The COB provision and regulations require that all health plans and other payers (e.g., Medicaid and Medicare) coordinate benefits to eliminate duplication of payment and assist patients to receive the maximum benefit to which they are entitled. By adhering to the COB provisions, the health plans and other payers can determine which plan will pay for a claim first.

The health plan or payer obligated to pay a claim first is called the "primary" payer and the other plan or payer is termed "secondary." Together, the primary and secondary payers coordinate payments for services up to 100% of the covered charges at a rate consistent with the benefits. When information about all potential sources of coverage is not available to plans and payers, claims will generally be "pended" and remain unpaid until complete COB information is on file.

Top reasons for COB-related delays in payment include: (1) incomplete or inaccurate COB information on file with the plan or payer, and (2) failure to attach the Explanation of Benefits (EOB) from the primary payer when billing the secondary payer. In addition, one of the leading reasons for claim denials is failure to submit complete and clean claims. The following tips are designed to assist physicians/providers and their billing staff to reduce payment delays attributed to COB-related problems:

1. Ask All Patients About Secondary Insurance Coverage

Have an office procedure to collect and/or confirm primary and secondary insurance information at each visit. Ask patients to provide the following information about their spouse and/or dependents: social security number; birth date; group/policy number for other medical coverage (if applicable); and Medicare or Medicaid ID card (if applicable). Collect this information at the time the appointment is booked to allow time for your staff to confirm eligibility prior to the visit.

2. Know What Plans and Payers Need to Pay Claims

Although each plan and payer may have slightly different requirements, there are some requirements that are nearly universal. For example, nearly all plans require a copy of the EOB from the primary payer prior to paying a claim as the secondary payer. Most plans and payers publish their requirements and the information should be available in physician/provider manuals, online and by contacting physician/provider representatives.

3. Determine Primary and Secondary Payers

It is important for physicians/providers to determine primary and secondary payers so that claims can be sent to the primary payer first. Some plans will be able to tell physicians/providers whether they are primary or secondary at the time the physician/provider contacts the plan to verify eligibility. Typically, the following rules are used by plans and payers to determine the primary and secondary payer:

  • The payer covering the patient as a subscriber will be the primary payer.
  • If the patient is a dependent child, the payer whose subscriber has the earlier birthday in the calendar year will be the primary payer. This is known as the Birthday Rule.

4. Attach EOB from Primary Payer When Submitting Claim to Secondary

Secondary payers must have a copy of the Explanation of Benefits (EOB) provided by the primary payer to process and pay a claim. Make attaching an EOB to claims filed with secondary payers a part of your routine office procedure.

A special consideration for Medicare claims

Many health plans receive Medicare claims automatically when they are the secondary payer. In this case, the Explanation of Medicare Benefits (EOMB) will indicate that the claim has been automatically crossed over for secondary consideration. Physicians/Providers should look for this indication on their EOMBs and should not submit a paper claim to the secondary payer. A paper claim submitted in this circumstance would be coded as a duplicate and rejected by the secondary payer.

A committee representing health plans and health care physicians/providers prepared this document. Organizations that participated in the development of this document include American Academy of Family Physicians, American College of Obstetricians and Gynecologists, American Academy of Dermatology Association, Bethesda Healthcare System, Piedmont Hospital, Group Health Incorporated, and Health Alliance Plan. America's Health Insurance Plans and the Healthcare Financial Management Association convened the committee.

The recommendations in this publication do not indicate an exclusive course of treatment or serve as a standard of medical care. Variations, taking into account individual circumstances, may be appropriate. This content is for informational purposes only. It is not intended to constitute financial or legal advice. A financial advisor or attorney should be consulted if financial or legal advice is desired.

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IntelyCare for Healthcare Facilities > Resources > Compliance and CMS Ratings > What Is Coordination of Benefits? Explanation and FAQ

What Is Coordination of Benefits? Explanation and FAQ

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Healthcare facilities sometimes provide care for patients that are on multiple insurance plans. In these instances, it’s important to figure out which entity is paying for what costs in order to avoid any hiccups in billing. This process as a whole is formally known as coordination of benefits . So, you may be wondering, What is coordination of benefits and who’s responsible for it?

In this FAQ, we explain everything you need to know. By understanding what this process entails, you can stay on the forefront of keeping your staff well-informed .

Coordination of Benefits: Definition

Individuals in the U.S. are allowed to be covered by more than one health insurance plan at a time, typically among spouses. To determine how coverage is split for these patients, insurers follow the coordination of benefits (or COB) process, which broadly refers to how these insurers decide who pays for a patient’s care first.

What Is Coordination of Benefits Like in Practice?

The exact process of coordinating benefits can vary depending on the types of insurance an individual has. At baseline, insurance providers work together to establish who the primary and secondary payer for a patient is.

  • The primary payer is the first to pay for any of the patient’s covered services, according to the benefits outlined in their plan.
  • The secondary payer is the next to pay for any remaining costs, according to what they should cover in their plan.

After a primary and secondary payer are established, insurance providers will usually specify these rules in their coverage plans. This helps healthcare staff understand how to start the billing process and gives patients more transparency on what costs will be shared.

Coordination of Benefits Example

To understand how benefit coordination applies in practice, we can look at a simplified example:

  • A patient has a medical bill totalling $100.
  • A claim is first submitted to the primary payer/insurer, who is responsible for $80, based on their coverage plan.
  • Afterwards, a claim is submitted to the secondary payer/insurer, who calculates how much of the remaining $20 they should cover, based on their plan details.
  • The patient then pays for any remaining, out-of-pocket expenses.

What Is Coordination of Benefits’ Importance?

Coordination of benefits in medical billing can help streamline the process of submitting claims. Lack of coordination can lead to confusion for insurers, facilities, and patients since there’s no clear system dictating how costs are split. Establishing a primary and secondary payer ensures that:

  • The total coverage between plans does not exceed the total cost of care.
  • Covered medical services are not paid for twice by different insurers.
  • Errors are avoided throughout the administrative billing process.
  • The patient does not overpay due to miscalculated out of pocket costs.
  • One insurer is not bearing significantly more costs than another.

What Are the Rules Around Coordinating Benefits?

There are various scenarios in which a patient may have more than one insurance plan. In some cases, legal rules can automatically apply to determine the primary payer. Common coordination of benefits rules include:

  • Private and public plans — Some people have both private and public (government-sponsored) health plans. In these instances, the private plan will generally pay first.
  • Dependent children — Children can sometimes be covered by insurance plans provided by both of their parents’ employers. The parent with the earlier birthday will have their plan pay first.
  • Employer-sponsored health plans — Some individuals may purchase a commercial plan on top of a plan provided by their employer. The employer-sponsored plan will generally be the primary payer.
  • Dual coverage with spouses — Individuals can sometimes elect to be covered by both their own employer’s plan and their spouse’s employer plan. In this case, a person’s own employer plan would be the primary payer while their spouse’s plan would be secondary.
  • Medicare and Medicaid — Some individuals over the age of 65 may have both Medicare and Medicaid. For these individuals, Medicare will serve as the primary payer.
  • Consolidated Omnibus Budget Reconciliation Act (COBRA) — Individuals may have COBRA coverage from a previous employer as well as a current employer-subsidized health plan. The most current employer-health plan will serve as the primary payer.

Who Is Responsible for Coordinating Benefits?

Insurance companies are primarily responsible for coordinating their benefits, and certain aspects of this process are regulated by federal and state laws. The National Association of Insurance Commissioners (NAIC) and The Centers for Medicare and Medicaid Services (CMS) provide guidelines that insurance companies should follow.

It’s also important for healthcare facilities to stay aware of policies surrounding this process. Not only does this allow for stronger oversight of the administrative billing process, but this also enables proper education for staff and patients who are working with multiple insurers.

Keep Up With the Latest Policies Impacting Your Facility

Now that you know the fundamentals to answering the question, “What is coordination of benefits?” you may be wondering what other policies can affect your patients and staff. Sign up to receive all of our latest healthcare news and insights today.

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What Is Coordination of Benefits?

Coordination of Benefits is a complex concept that requires an in-depth understanding of insurance. This article provides an all-encompassing guide to the topic, covering everything from an introduction of what coordination of benefits is and how it works, to the various types of coordination that exist, to the impact of coordination on medical coverage and insurance claims.

We’ll cover frequently asked questions regarding Coordination of Benefits, such as who is liable for payment, where you can find more information or resources, and what the risks are of applying coordination to your claim, as well as deeper discussions of newer concepts like multi-state plan coordination and disability benefits coordination.

This article will explain the Coordination of Benefits, arming you with the knowledge required to maximize your health plan’s benefits.

____________________________

Key Takeaways

  • Coordination of Benefits (COB) is a process that determines the payment order between multiple health insurance plans to avoid overcharging or duplicate payments.
  • COB covers various services, including medical care, equipment, services, and prescription drugs, ensuring combined insurance plans do not exceed 100% of necessary covered medical expenses.
  • The order of benefit determination is a framework used to decide which health insurance plan pays first; the primary insurance plan pays first, followed by the secondary insurance plan if needed.
  • Medicare Crossovers and COBA help ensure payments are made correctly between Medicare and other health insurance providers in cases where a person has both Medicare and private health insurance.
  • Subrogation is a process where the primary insurer seeks reimbursement from the other health insurance provider for any services they’ve paid for, ensuring no one receives duplicate payments.
  • Failure to complete the COB process can result in the patient being responsible for all claims, making it crucial to work with both insurers to ensure proper coordination of benefits.

Coordination of benefits – what is it? It’s a process used to determine which health insurance company pays first and which one pays second, like two boxers in the ring. The National Association of Insurance Commissioners is the referee that makes sure no double payments or reimbursements for more than necessary are made.

What services does this cover? Medical care, equipment, services, and prescription drugs – all of these fall under covered services. For example, Medicare Part A covers hospital visits while Part B oversees physician office visits. Payments from combined insurance plans should not exceed 100% of charges for necessary covered medical expenses and services.

In conclusion, coordination of benefits helps ensure you don’t get overcharged by your insurance companies and that everything runs smoothly when dealing with multiple policies. The NAIC Model Coordination of Benefits Guidelines provides a necessary framework to ensure this happens appropriately every time!

Why Is COB Important?

Having two health plans can be like having a safety net when you need healthcare. Coordination of benefits (COB) is the process that helps make sure you don’t have to pay more than necessary for health care. But what exactly is COB, and how does it work?

Coordination of benefits ensures insurance companies pay their fair share when both plans cover the same person. It looks at factors such as type of health plan, age, the order in which the plans were obtained, or the amount of coverage to decide which plan pays first and how much each will contribute. For instance, if a family has two health plans – one from an employer group health plans and another from the government – then typically, the employer’s plan will take precedence.

The rules used to determine who pays first are specific to each insurance company. They also consider things like type of service or drug, deductibles/coinsurance, whether either plan covers it, etc.

This process may seem complicated, but its purpose is simple. To give patients maximum benefit from their health insurance plans while keeping costs down for everyone involved. In other words, coordination of benefits helps ensure that people get quality coverage for their medical needs without breaking the bank!

Order of Benefit Determination

The order of benefit determination is a complex system that can be hard to wrap your head around. But understanding it is essential if you want to make sure you’re not overpaying for health care.

So, what exactly is the order of benefit determination? It’s a framework used to decide which health insurance plan pays first when multiple plans are in place. Usually, the primary insurance plan pays first, followed by the secondary insurance plan if necessary. The amount each insurer pays depends on state law, plan size, and type – all subject to state legislation.

For example, many states have laws that dictate an employee’s plan should pay first before their spouse or parent’s. In addition, a smaller plan may pay first if it offers more coverage than the larger one.

When it comes to who gets paid back what portion of healthcare costs, typically, the primary payer will be either an employer filing a claim or Medicare, while the secondary payor could be another person filing a claim with private insurance or an employer of their spouse/parent (with exceptions). If there’s still money left unpaid after both insurers have done their part, then up steps the secondary payor, who’ll cover up to 100% of any remaining balance due on bills!

But don’t worry too much about getting confused by the coordination of benefits rules – remember why they exist: so you don’t end up paying out-of-pocket for services unnecessarily!

Medicare Crossovers

The Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA) Section 111 requires Group Health Plans (GHPs), liability insurance, such as self-insurance, no-fault insurance, and workers’ compensation to report. Blue Cross is responsible for notifying Medicare about its members who have elected Original Medicare as their primary plan and verifying the memberships of those individuals.

Coordination of Benefits Agreement (COBA) is a national program that facilitates the transmission of enrollee eligibility data and Medicare-paid claims data between BCRC and other health insurance organizations. COBA was established to coordinate benefits between Medicare and other health insurance involved – what does it do? It helps ensure that payments are made correctly!

As an example of a coordination of benefits situation involving Medicare, consider a scenario in which an individual has both Medicare and a private health insurance plan. In this case, the primary payer would be the private health insurance plan and the secondary payer would be Medicare. The insurance companies would coordinate benefits to determine which plan pays first and how much each plan pays for health care costs.

The plan with the most comprehensive coverage will pay first, and the other plan will pay any remaining costs not covered by the primary plan. For example, if the covered services provided by the primary plan cost $1,000 and the plan only covers 80% of those costs, then the secondary plan would cover the remaining 20%, or $200.

In this situation, the primary payer would be responsible for paying the first $800, and the secondary payer would be accountable for the last $200.

Subrogation

Subrogation is getting another insurance company to pay for care that the primary health insurer already covers. In coordination of benefits, it’s a process where the primary insurer seeks reimbursement from the other health insurance provider for any services they’ve paid for. This is done so that no one gets double payment for the same service.

The primary insurer must submit all claims to the other health insurance company and if approved, will receive some of this reimbursement back – this is subrogation in action! Large employers often use voluntary data sharing agreements (VDSAs) to send their retiree prescription drug coverage population details to the other health insurance provider. This allows them to get reimbursed for any care they have already provided and receive a portion when the second insurer accepts their claim.

Subrogation plays an important role in coordinating benefits as it ensures no one receives duplicate payments – plus VDSAs help large employers maximize their reimbursements from secondary insurers, which helps reduce the overall cost of care for those insured!

When One Person Has Two Health Insurance Plans

Having two health insurance plans is becoming more and more common. Dual-income households, working Medicare beneficiaries, and extended dependent coverage for children up to age 26 contributed to this. As a result, it has had an impact.

While having two health plans may provide more coverage and better access to healthcare services, there are potential downsides, such as paying double premiums and dealing with deductibles for both plans.

Two health insurance plans are most common when both spouses have employer-sponsored health plans. In these scenarios, it’s important to determine which of the two plans will be the primary payor and which will be the secondary. The primary plan pays benefits first, and any remaining balance is paid by the secondary plan.

It’s also important to remember that each family member’s order of plans and benefits may differ. For example, if a couple has two plans and one partner is the policyholder for both, their partner’s insurance plan may be the primary payor for their child(ren)’s claims.

In divorce cases, the custodial parent’s health plan is usually the primary payor. The birthday rule applies if a child is covered under both parents’ plans. The parent whose birthday falls earlier in the calendar year is the primary payor.

When submitting a claim to the partner’s insurance plan, the amount of coverage offered will determine the reimbursement. Your partner can file a claim for the remaining balance to your insurance plan if their plan does not cover it. This way, they would be able to get the necessary medical assistance. However, they will not be reimbursed for the remaining balance as this depends on the coverage offered by the insurance plan.

Overall, coordination of benefits is a necessary process to understand when a person has two health insurance plans. Insurance companies coordinate benefits based on the benefits rules outlined in the contracts of the two insurance plans.

When both plans pay, the primary payor pays first, and the secondary payor pays the remaining balance. It is important to understand how insurance plans work and to consult the benefits statement from each insurance plan to ensure that all claims are submitted correctly.

What Happens If the Coordination of Benefits is Not Completed?

When it comes to the coordination of benefits process, it’s like a puzzle – if you don’t complete it, there can be serious consequences. If the COB isn’t finished, insurance companies won’t coordinate benefits and the patient is left holding the bag for all claims – no matter how many plans they have.

To figure out what amount is owed on a medical or prescription drug claim, take a look at the second payer’s explanation of benefits. This will show you things like how much needs to be paid, what was already paid by the primary payor and any amounts that were disallowed due to being previously covered.

If this issue isn’t resolved quickly, then it’ll be up to the patient to foot the bill for everything. Insurance companies won’t even consider paying until coordination of benefits has been completed properly – so that means shelling out cash from your own pocket!

It pays (literally!) to understand why completing this process correctly is so important: insurance companies coordinate benefits in order to make sure each plan covers its fair share without going over budget. So work with both insurers and get those pieces into place!

Frequently Asked Questions

What is the difference between cob vs eob in healthcare.

As a medical billing professional, it is important to understand the distinction between COB and EOB in healthcare. Coordination of Benefits (COB) relates to insurance benefits assigned to individuals, dependents or children covered by both multiple policies.

Explanation of Benefits (EOB) outlines the details of those benefits. Understanding these terms can help to ensure accurate billing procedures.

In conclusion, Coordination of Benefits (COB) is a process used by insurance companies to determine the primary and secondary payor for a medical claim when two or more health plans are involved. It ensures that all parties involved in providing and paying for healthcare services have accurate and consistent information, helping individuals secure the best possible coverage.

Understanding coordination of benefits is important when managing multiple plans and can help prevent out-of-pocket costs. Providing complete information to each health plan is key in determining the order of benefit determination, with the primary insurer paying first followed by the secondary insurer paying the remaining costs not covered by the first plan.

Knowledge of the coordination of benefits rules, including the birthday rule, can help ensure individuals get the most out of their insurance coverage.

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what is a coordination of benefits used for

What does "Coordination of Benefits" Mean Anyway?

A mental health provider looking up "Coordination of Benefits" on a computer

Main Points

Coordination of benefits (COB) allows an insurance plan to know where they fall in the reimbursement chain

A miscommunication in coordination of benefits can inhibit insurance companies from paying on claims

The way an insurance company knows the coordination of benefits can vary, and the patient is ultimately responsible for knowing their benefits

One of the most misunderstood denial reasons that providers receive is called "coordination of benefits". What does that mean? What am I supposed to do about that? If I told my patient, what would they do with that information?

The disorienting nature of this denial reason lends itself to delaying payment as long as possible from the insurance company. The problem is that the term "coordination of benefits" doesn't communicate what the patient should do, what the provider should do, or what the biller should do to resolve the issue.

In this blog we are going to flesh out the term "coordination of benefits" and what you should do if you receive a denial with this designation. It will be important that you communicate clearly to your patient that way they know exactly what they need to do and who they need to communicate with.

First, let's define the term "coordination of benefits". Coordination of benefits is the process that allows a plan to determine their respective payment responsibilities . Basically, if a patient has multiple insurance plans that are active, which one is responsible for covering the patient first, second, and third.

There can be quite a bit of confusion around which insurance company pays first.

The COB process is beneficial for several reasons:

Ensures claims are paid correctly by identifying the health benefits available to a Medicare beneficiary, coordinating the payment process, and ensuring that the primary payer, whether Medicare or other insurance, pays first.

Shares Medicare eligibility data with other payers and transmits Medicare-paid claims to supplemental insurers for secondary payment. Note: An agreement must be in place between the Benefits Coordination & Recovery Center (BCRC) and private insurance companies for the BCRC to automatically cross over claims. In the absence of an agreement, the person with Medicare is required to coordinate secondary or supplemental payment of benefits with any other insurers he or she may have in addition to Medicare.

Ensures that the amount paid by plans in dual coverage situations does not exceed 100% of the total claim, to avoid duplicate payments.

Accommodates all of the coordination needs of the Part D benefit. The COB process provides the True Out of Pocket (TrOOP) Facilitation Contractor and Part D Plans with the secondary, non-Medicare prescription drug coverage that it must have to facilitate payer determinations and the accurate calculation of the TrOOP expenses of beneficiaries; and allowing employers to easily participate in the Retire Drug Subsidy (RDS) program.

However, this process can be a bit confusing and complicated to navigate.

The way an insurance company knows the coordination of benefits can vary, and the patient is ultimately responsible for knowing their benefits . Here is a breakdown of where COB data can come from or get communicated:

COB Data Sources:

COB relies on many databases maintained by multiple stakeholders including federal and state programs, plans that offer health insurance and/or prescription coverage, pharmacy networks, and a variety of assistance programs available for special situations or conditions. Some of the methods used to obtain COB information are listed below:

IRS/SSA/CMS Claims Data Match - The law requires the Internal Revenue Service (IRS), the Social Security Administration (SSA), and CMS to share information about beneficiaries and their spouses. By law, employers are required to complete a questionnaire, the IRS/SSA/CMS Data Match, on the group health plan that Medicare-eligible workers and their spouses choose. The Data Match identifies situations where another payer is primary to Medicare. In addition, CMS has entered into Voluntary Data Sharing Agreements with numerous employers. These agreements allow employers and CMS to send and receive group health plan enrollment information electronically.

Voluntary Data Sharing Agreements (VDSAs) - CMS has entered into VDSAs with numerous large employers. These agreements allow employers and CMS to send and receive group health plan enrollment information electronically. Where discrepancies occur in the VDSAs, employers can provide enrollment/disenrollment documentation. The VDSA data exchange process has been revised to include Part D information, enabling VDSA partners to submit records with prescription drug coverage be it primary or secondary to Part D. Employers with VDSAs can use the VDSA to submit their retiree prescription drug coverage population which supports the CMS mission of a single point of contact for entities coordinating with Medicare.

COB Agreement (COBA) Program - CMS consolidates the Medicare paid claim crossover process through the COBA program. The COBA program established a national standard contract between the BCRC and other health insurance organizations for transmitting enrollee eligibility data and Medicare paid claims data. This means that Medigap plans, Part D plans, employer supplemental plans, self-insured plans, the Department of Defense, title XIX state Medicaid agencies, and others rely on a national repository of information with unique identifiers to receive Medicare paid claims data for the purpose of calculating their secondary payment. The COBA data exchange processes have been revised to include prescription drug coverage.

Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA) – This law added mandatory reporting requirements for Group Health Plan (GHP) arrangements and for liability insurance, including self-insurance, no-fault insurance, and workers' compensation. Insurers are legally required to provide information.

Other Data Exchanges - CMS has developed data exchanges for entities that have not coordinated benefits with Medicare before, including Pharmaceutical Benefit Managers (PBMs), State Pharmaceutical Assistance Programs (SPAPs), and other prescription drug payers. CMS has worked with these new partners to educate them about coordination needs, to inform CMS about how the prescription drug benefit world works today, and to develop data exchanges that allow all parties to efficiently serve our mutual customer, the beneficiary.

A miscommunication in coordination of benefits can inhibit insurance companies from paying on claims . Obviously, there are several ways in which insurance companies can know how a patient is covered, which means there are several points where error can creep in and muddle the process.

Therefore, there are several rules of thumb when it comes to determining which insurance company pays first and which insurance company pays second.

The first rule of thumb is called the birthday rule. This is a default principle that the insurance companies use to determine when a dependent is covered by two parents. Basically, whichever parent's birthday falls earlier in the year, that is the primary insurance. For example, if a child's dad's birthday is February 1st and the mom's is March 1st, the dad's insurance is primary and the mom's is secondary, even if the mom is older.

The second rule of thumb comes down to whether the patient has a commercial payer or a government payer. If the patient has a commercial payer, that payer is first. Then the government payer is last. This is not always true, but it is true in most cases. If the patient has two government payers then Medicaid is ALWAYS the payer of last resort.

COB issues can be pervasive and can cause payment delays, but asking your patients and knowing where COB information comes from can lead to clear and evident reimbursement. You will want to be very clear with the patient when it comes to COB issues and denials and tell them to follow up with their insurance if you believe there is a problem.

If you find that you are still confused by COB issues or laws concerning COB, please reach out to us and we would be happy to clear up any confusion that you may have.

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Coordination of Benefits & Third Party Liability

Related resources.

  • Claims Under the Camp Lejeune Justice Act (CLJA)
  • Medicaid Medical Support Requirements and Implementation Strategies Slide Deck
  • Summary of Federal Statutory Requirements
  • Summary of Federal Regulatory Requirements
  • CFR Subpart D, Third Party Liability  
  • Guide to Effective State Agency Practices 2014
  • Guide to Effective State Agency Practices 2015
  • Frequently Asked Questions
  • 2020 COB/TPL Handbook

It is possible for Medicaid beneficiaries to have one or more additional sources of coverage for health care services. Third Party Liability (TPL) refers to the legal obligation of third parties (for example, certain individuals, entities, insurers, or programs) to pay part or all of the expenditures for medical assistance furnished under a Medicaid state plan. By law, all other available third party resources must meet their legal obligation to pay claims before the Medicaid program pays for the care of an individual eligible for Medicaid. States are required to take all reasonable measures to ascertain the legal liability of third parties to pay for care and services that are available under the Medicaid state plan. The Deficit Reduction Act of 2005 included several additional provisions related to TPL and coordination of benefits for Medicaid beneficiaries. For more information on Medicaid TPL and COB, see our  Frequently Asked Questions . For detailed information about COB/TPL policies, see our  2020 COB/TPL Handbook .

Coordination of Benefits

Coordination of Benefits (COB) refers to the activities involved in determining Medicaid benefits when an enrollee has coverage through an individual, entity, insurance, or program that is liable to pay for health care services. Individuals eligible for Medicaid assign their rights to third party payments to the State Medicaid Agency.

Examples of third parties which may be liable to pay for services:

  • Group health plans
  • Self-insured plans
  • Managed care organizations
  • Pharmacy benefit managers
  • Court-ordered health coverage
  • Settlements from a liability insurer
  • Workers' compensation
  • Long-term care insurance
  • Other state or Federal coverage programs (unless specifically excluded by law)

Identification of Third Parties

States gather information regarding potentially liable third parties, including information about other sources of health coverage, when individuals apply for medical assistance. This information is periodically updated whenever a Medicaid enrollee's eligibility is renewed.    

Data Matching

States conduct data matches to identify third party resources. States must have laws in place that require health insurers to provide their plan eligibility and coverage information to Medicaid programs. For example, states conduct data matches with public entities, such as the Department of Defense, to identify Medicaid enrollees and/or their dependents that have coverage through the Military Health Services system and the TRICARE program. States also match with workers' compensation and state motor vehicle accident files. These matches can identify Medicaid enrollees that have sustained injuries which may be covered through workers' compensation or through an automobile insurance policy. State child support agencies are required to notify the Medicaid agency whenever a parent has acquired health coverage for child as a result of a court order.  

State Medicaid Programs and Use of Contractors for Data Matching

State Medicaid programs may enter into data matching agreements directly with third parties or may obtain the services of a contractor to complete the required matches. When the state Medicaid program chooses to use a contractor to complete data matches, the program delegates its authority to obtain information from third parties to the contractor.

Third parties should treat a request from the contractor as a request from the state Medicaid agency. Third parties may request verification from the State Medicaid agency that the contractor is working on behalf of the agency and the scope of the delegated work.

COB/TPL Guidance

  • Guidance to State Medicaid Agencies on Dually Eligible Beneficiaries Receiving Medicare Part B Marriage and Family Therapist Services, Mental Health Counselor Services, and Intensive Outpatient Services Effective January 1, 2024 December 2023
  • Third-Party Liability in Medicaid: State Compliance with Changes Required in Law and Court Ruling s April 2023
  • Third Party Liability in Medicaid: State Compliance with Changes Required in Bipartisan Budget Act of 2018 and Medicaid Services Investment and Accountability Act of 2019 August 2021
  • Notice of Proposed Rulemaking: Value-based Purchasing (VBP) and Drug Utilization Review (DUR) Proposed Regulation CMS-2482-P  June 2020
  • CIB: Guidance for State Medicaid Agencies on Dually Eligible Beneficiaries Receiving Medicare Opioid Treatment Services December 2019
  • Guidance to Medicaid Bipartisan Budget Act (BBA) of 2018 and changes to Medicaid Provisions Passed in April 2019 – Third Party Liability in Medicaid and CHIP  November 2019

Managed Care and Third Party Liability

The contract language between the State Medicaid agency and the Managed Care Organization (MCO) dictates the terms and conditions under which the MCO assumes TPL responsibility. Generally, TPL administration and performance activities that are the responsibility of the MCO will be set by the state and should be accompanied by state oversight.

There are four basic approaches to carrying out TPL functions in a managed care environment.  

  • Enrollees with any other insurance coverage are excluded from enrollment in managed care
  • Enrollees with other insurance coverage are enrolled in managed care and the state retains TPL responsibilities
  • Enrollees with other insurance coverage are enrolled in managed care and TPL responsibilities are delegated to the MCO with an appropriate adjustment of the MCO capitation payments
  • Enrollees and/or their dependents with commercial managed care coverage are excluded from enrollment in Medicaid MCOs, while TPL for other enrollees with private health insurance or Medicare coverage is delegated to the MCO with the state retaining responsibility only for tort and estate recoveries

MCOs and Data Matching

State Medicaid programs may contract with MCOs to provide health care to Medicaid beneficiaries, and may delegate responsibility and authority to the MCOs to perform third party discovery and recovery activities. The Medicaid program may authorize the MCO to use a contractor to complete these activities.

When TPL responsibilities are delegated to an MCO, third parties are required to treat the MCO as if it were the State Medicaid agency, including:

  • Providing access to third party eligibility and claims data to identify individuals with third party coverage
  • Adhering to the assignment of rights from the state to the MCO of a Medicaid beneficiary’s right to payment by such insurers for health care items or services
  • Refraining from denying payment of claims submitted by the MCO for procedural reasons

Third parties may request verification from the state Medicaid agency that the MCO or its contractor is working on behalf of the agency and the scope of the delegated work.

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ADA Guidance on Coordination of Benefits

Coordination of Benefits takes place when a patient is entitled to benefits from more than one dental plan. Plans will coordinate the benefits to eliminate over-insurance or duplication of benefits.

General Coordination of Benefits Rules

It is important to note that only group (employer) plans are required to coordinate. So if one of the policies covering your patient is an individual policy, then it does not coordinate.

Employee/Main Policyholder - When both plans have COB provisions, the plan in which the patient is enrolled as an employee or as the main policyholder is primary. The plan in which the patient is enrolled as a dependent would be secondary.

Current Employment – When an employed patient has coverage through an employer that plan is primary over a COBRA or a retiree plan.

More than One Employer Plan – When a patient has plans provided by more than one employer, the plan that has covered the patient the longest is primary. A change in the dental plan carrier does not change the length of coverage time for the patient.

Dependent Children - The typical rules for dependents of parents with overlapping coverage rely on the birthday rule, that is, the parent with the earliest birthday in a calendar year is primary. In the case of divorced/ separated parents, the court's decree would take precedence.

Medical/Dental Plan – When a patient has coverage under both a medical and dental plan, the medical plan is primary.

Additional information regarding coordination of benefits that may be helpful follows.

Types of Coordination of Benefits

Many factors determine how COB is handled including state laws, processing policies of the carriers involved, contract laws, fully insured versus self-funded plans and types of COB utilized. There are several different types of COB that plans may use. A brief description of some of the more common methods follows.

Traditional - Traditional coordination of benefits allows the beneficiary to receive up to 100 percent of expenses from a combination of the primary and secondary plans.

Maintenance of Benefits - Maintenance of benefits (MOB) reduces covered charges by the amount the primary plan has paid, and then applies the plan deductible and co-insurance criteria. Consequently, the plan pays less than it would under a traditional COB arrangement, and the beneficiary is typically left with some cost sharing.

Carve out - Carve out is a coordination method which first calculates the normal plan benefits that would be paid, then reduces this amount by the amount paid by the primary plan.

Nonduplication COB - In the case of nonduplication COB, if the primary carrier paid the same or more than what the secondary carrier would have paid if it had been primary, then the secondary carrier is not responsible for any payment at all. Nonduplication is typically used in self-funded dental plans. A self-funded dental plan is a plan in which the plan sponsor bears the entire risk of utilization.

Self-funded plans are exempt from state insurance statutes and are generally governed by federal legislation known as the Employee Retirement Income Security Act (ERISA). In 2012, 49% of people with a dental benefit had a self-funded plan. 1 It is important that dental offices understand that not all patients will have a dental plan that is subject to your state’s COB laws. ADA policy opposes nonduplication provisions and at least one state, California, has enacted legislation prohibiting such provisions.

Network Plan Write-Offs

The difference between the dentist’s full fee and the sum of all dental benefit plan payments and patient payments is the amount of the write-off. Write-offs should not be posted until all plans have paid accordingly. If a write-off is posted after the primary pays and then posted again based on the secondary payment, it is possible the dental office may incorrectly apply a credit to the patients’ balance. Remember to always submit your full fee on the dental claim form.

Medicaid, Medicare and Coordination of Benefits

By law, all other available third party resources must meet their legal obligation to pay claims before the Medicaid program pays for the care of an individual eligible for Medicaid. 2 Thus, Medicaid is typically secondary to any other benefit plan.

In cases that involve a patient presenting with a retiree plan, Medicare and the patient has coverage on a spouse’s plan, generally any dependent coverage pays first, Medicare pays second and any non-21 dependent coverage (e.g. retiree coverage) pays third. 3

National Association of Insurance Commissioners (NAIC)

The NAIC has drafted model regulation on coordination of benefits and recommends that states pass similar legislation so that benefits can be coordinated uniformly across states. The ADA supports this also and recommends that state dental association’s attempt to pass similar legislation.

Affordable Care Act and its Impact on COB

Contrary to many myths, the Affordable Care Act did little to address claims submission and coordination of benefits (COB) arising from dental benefits embedded in medical plans and sold through the Federal and State Marketplaces. Thus, coordination of benefits and claims submission is handled the same as it was prior to the implementation of the Affordable Care Act.

The following information should help dental offices navigating the COB maze in the context of the ACA.

Billing to Medical Plans

Dentists will continue to submit the dental claim form along with Current Dental Terminology (CDT) codes to these plans. Even though the covered benefits are not necessarily the same as regular dental plans, the claims process remains the same.

Coordination of Benefits

For routine dental billing to two medical plans with embedded dental benefits, billing will be no different than it is now and any coordination should be attempted in the usual way (a determination of who the

1 NADP Purchaser Behavior Survey, September 2011 2 Accessed from: http://www.medicaid.gov/Medicaid-CHIP-Program-Information/By-Topics/Eligibility/TPL-COB-Page.html 3 Model Regulation Service - October 2013, Coordination of Benefits Model Regulation, National Association of Insurance Commissioners, pg. 8.

primary payer is and then a copy of the explanation of benefits (EOB) statement submitted with the claim 1 to the secondary payer).

How is the primary coverage determined between a medical plan and a stand-alone dental plan? The usual primary coverage determination rules would apply. In California, Exchange contracts call for the embedded dental plan to always be primary and the standalone plan to pay secondary – this may vary by state. Keep in mind that some embedded plans may utilize a closed panel network meaning that benefits will only be paid if services are provided by a network provider. In this case and if the closed panel plan was primary, the secondary would basically provide coverage as though it were primary.

As in the past, it is strongly recommended that the dental office (assuming the office files claims on behalf of the patient) verify primary/secondary coverage by calling the customer service number on the patient’s identification card. If a dental office cannot determine which plan is primary, a call to the state insurance commissioner’s office could be made to determine primary versus secondary.

Contracting with Medical Plans

Medical plans with embedded dental benefits have indicated that they will not require dentists to be credentialed under the medical plan(s). Fees are determined by the dental plan and if a dentist is under contract with the plan, then contracted dental fees apply. If the dental office has questions regarding participating provider status, it is recommended that the office call the plan’s professional services department to obtain that information. Contact information for these departments can be found on the patient’s identification card.

Current ADA Policy on Coordination of Benefits

Guidelines on Coordination of Benefits for Group Dental Plans (Trans.1996:685; 2009:423)

When a patient has coverage under two or more group dental plans the following rules should apply: a. The coverage from those plans should be coordinated so that the patient receives the maximum allowable benefit from each plan. b. The aggregate benefit should be more than that offered by any of the plans individually, allowing duplication of benefits up to the full fee for the dental services received.

Navigating the path of coordination of benefits can be a frustrating and time consuming endeavor for dental offices trying to settle accounts for patients with more than one dental benefits plan. In addition, state laws and regulations often mandate coordination of benefits. If after the claim payment has been made and it appears to have been incorrectly adjudicated it is recommended that the claim determination be appealed and if necessary the state insurance commissioner’s office be contacted for assistance. This information along with state specific information on coordination of benefits, can be found by visiting the member’s only resource, Center for Professional Success website (success.ada.org) or you may call ADA staff at 800-621-8099 for further assistance.

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Coordination of Benefits vs. Explanation of Benefits

Simply Benefits Marketing

By Simply Benefits Marketing

January 4, 2022

If you’re enrolled in a group benefits plan, you've likely come across the terms Coordination of Benefits (COB) and Explanation of Benefits (EOB) . Each of these terms has to do with submitting claims and receiving reimbursement, so it’s important you know and understand what they mean!

In this blog, we’ll outline the details of COBs and EOBs and describe the connection between them, so you’ll be able to submit claims easier and without confusion. 

What is a Coordination of Benefits?

An Employee Benefits plan is centered around receiving health services, as well as paying and adjudicating claims. When you use a service that is part of your health plan (massage, chiropractic, etc.), you’ll need to submit a claim to be reimbursed for the amount that you are covered for. Once submitted, your insurance company is responsible for paying your claim and providing you with a record of that payment.

Spouse Coverage

In some cases, if your spouse is also part of an employer-sponsored group benefits plan, you may be eligible for additional coverage under their plan as well. This comes in handy if your benefits plan only covers a percentage of a service (ex. If only 80% of your massage therapy is covered under your health plan, you may be able to submit the remaining 20% under your spouse’s plan). Figuring out how to coordinate between both plans is where Coordination of Benefits comes in.

Coordination of Benefits (COB) describes the claims process for an employee with a spouse/dependent who also has group coverage elsewhere.

A dependent is a person (e.g. spouse, child) who relies on you financially that you add to your group benefits plan so they have benefits, or you are included in theirs. The rules of COBs outline which plan pays first and how benefits are calculated when claims are made to more than one group plan. This is common especially among families with two working adults that each have group benefits that are using their insurance for their child dependents. 

Which Plan Do I Submit My Claim To?

The company that provides your insurance will likely take care of the nitty-gritty details in terms of payment, but there are some things that you should know regarding common issues that happen with a COB.

Here are some general rules when it comes to COBs.

  • For example , if you have two part-time jobs with benefits, one that started in 2018 and one that started in 2019, you would submit your claim to the plan that was started in 2018 and it will also be the one that pays first.
  • For example , for two parents that have a child covered under both plans with birthdays on October 11 and September 21, the parent with the September birthday will pay the claim first. 

Of course, there are other cases such as for retired people or post-secondary students. For those cases, refer to your employee booklet or contact your plan administrator for more information, so you know how to submit your claims properly. 

What happens if I make a mistake?

Well, if you accidentally submit a claim to the wrong insurance provider, it will likely get denied. However, the easy fix to this is to just resubmit it to the right provider. 

It’s important to always keep your dependent information up to date, so when you submit claims, they are processed correctly and won’t get denied. Any time your dependent information is changed, including the birth of a child, or divorce, you should contact your plan administrator with the updates. 

What is an Explanation of Benefits?

An explanation of benefits (EOB) is a statement that includes details about a medical insurance claim that explains what portion was paid to the health provider and how much the employee is responsible to pay out-of-pocket. This is generated and sent once it has been fully adjudicated or processed.

  • EOBs are provided any time an employee makes a claim for an extended health care service. The key thing to keep in mind about EOBs is that they are not bills, they are only for your reference to how much you will owe. 
  • Since EOBs are more of a record of payment rather than a bill, you don’t have to do much with an EOB . You may receive an actual bill later if you owe money for your claim, but typically you can file away your EOB for reference.
  • EOBs help you understand the value that you get out of our insurance plan. Simply Benefits stores all of your previous EOBs on your employee profile so you can reference them whenever you need to. 

How are they Connected?

EOBs and COBs go hand in hand. The EOB that you receive after you submit a claim can and will be used to receive a COB from another insurance provider.

  • For example, With Simply Benefits, when you submit any kind of claim, you’ll receive an EOB. If your plan doesn’t cover the full amount, and you want your spouse's plan to cover the rest, you’ll send the EOB along with the original receipt to your spouse's health insurer. They’ll take care of the rest of the payment, and you may or may not receive another EOB from the other health insurer.

Final Thoughts

Hopefully, you now have a better understanding of how EOBs and COBs work, so the next time you submit a claim you'll know the process making it easier for you with faster reimbursement .  

If you’re a Simply Benefits plan member, talk to your plan administrator or contact our Support Team to find out details about your coordination of benefits and what to expect from an EOB. 

Reach out to Support

Watch how easy it is to submit a claim through Simply Benefits!

Other Helpful Employee Resources

  • Employee Health Benefits Coverage in 5 Minutes
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About Simply Benefits

Simply Benefits  is a Third Party Payor (TPP) that provides Employee Health Benefits 100% digitally through our Canadian Advisor partners. Our all-in-one digital solution provides three portals that enable   Benefits Advisors   to digitally manage all client plans online,   Employers   to efficiently administer employee coverage, and   Employees   to view, update and use their benefits 24/7 via desktop or smartphone app.

We help   ENGAGE   Employees Anytime, Anywhere,   SIMPLIFY   the Benefits Experience, and   EVOLVE   an Advisors’ Benefits Business.

Connect with us at   simplybenefits.ca   or on   LinkedIn ,   Twitter ,   Facebook ,   Instagram ,   and   YouTube .

Employee Benefits Made Simple. 

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Simply Benefits collects information needed to provide services and meet the regulatory requirements of our industry. When you open an account or sign up for services, we collect personal information which may include but is not limited to the following:

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The information we collect is used so we can communicate with you, provide benefits and insurance management services, improve our products and services, and meet our regulatory obligations.

We share only the information which is reasonably required in the normal course of business with third parties such as our custodians, securities regulators, auditors, legal counsel, or law enforcement agencies, to enable them to fulfill their obligations to Simply Benefits and our clients. We may also disclose your personal information to third-party service providers, affiliates and agents in order to assist us in providing the services you requested and to fulfil the purposes for which your personal information has been collected. Outside of this we shall not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.

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We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. In the event that we share your personal information with third-party service providers, affiliates and agents, these parties will be required to adhere to strict confidentiality obligations and practices.

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Simply Benefits Corp.

601-460 Doyle Ave,

[email protected]

If you believe that any information we have on file for you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

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Coordination of Benefits for MassHealth Providers

Coordination of benefits.

Coordination of Benefits (COB) refers to the activities involved in determining MassHealth benefits when a member has other health insurance including Medicare, Medicare Advantage, or commercial insurance in addition to MassHealth that is liable to pay for health care services.

Related Regulations

MassHealth regulations at 130 CMR 450.316 require providers to make diligent efforts to identify and obtain payment first from other resources including casualty payer payments to ensure that the MassHealth agency is always the payer of last resort.

Providers should refer to the following MassHealth/Third Party Liability (TPL) regulations and billing guides located in their provider manual when submitting COB claims to MassHealth:

  • MassHealth Administrative and Billing Regulations at 130 CMR 450.316 through 450.318 and
  • Subchapter 5: Administrative and Billing Instructions, Part 7. Other Insurance.

You can find links to these below in "Additional Resources."

Additional Resources

Job aids for cob claims submissions.

You can find j ob aids for COB claims submissions at the  Provider Online Service Center (POSC) . See "Additional Resources" below.

Providers must submit all claims electronically unless they have been approved for an electronic claim submission waiver. 

Related Bulletins

You can find additional information in the following All-Provider Bulletins:

  • All Provider Bulletin 273: MassHealth Coordination of Benefits (COB) Billing Best Practices and New Claim Error Codes  
  • All Provider Bulletin 246: MassHealth Claims Involving Casualty Payer Payments  
  • All Provider Bulletin 217: Waiver Policy for Claim Submissions 

See "Additional Resources" below. 

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Supreme Court sides with Army veteran in overlapping GI Bill benefits case

An Army veteran sued the VA for Post-9/11 GI Bill benefits to earn a graduate degree and become an Army chaplain.

By Patty Nieberg | Published Apr 16, 2024 3:27 PM EDT

James Rudisill served three different hitches in the military, qualifying for both the Montgomery GI Bill and the post-9/11 version. He sued when the VA limited his use of them. The U.S. Supreme Court ruled Tuesday that veterans with overlapping military service periods can use the benefits they earned from two different GI bills. Photo: courtesy of James Rudisill.

The U.S. Supreme Court ruled Tuesday that veterans with overlapping military service periods can use the benefits they earned from two different GI bills. 

Lawyers representing the Army veteran who brought the case, James Rudisill, said the decision could impact as many as 1.7 million veterans and allow them to receive education benefits from the Department of Veterans Affairs under the Montgomery and Post-9/11 GI bills.

“Fundamentally, this ruling applies to veterans who served six years or more. A continuous six-year enlistment or six years and then four years or whatever the case may be – as long as it aggregates up to six years total,” said Tim McHugh, one of the lawyers representing Rudisill’s case. “As long as you didn’t get a dishonorable discharge or something like that, you should get both benefits.”

The court’s decision was 7-2 with two of the court’s more conservative judges disagreeing with the ruling.

In her ruling, Justice Ketanji Brown Jackson cited the so-called “pro-veteran canon,” a legal interpretation that instructs courts to favor the rights and benefits of veterans when interpreting ambiguity in federal law.

“The bottom line is this: Veterans who separately accrue benefits under both the Montgomery and Post-9/11 GI Bills are entitled to both benefits,” Justice Jackson wrote in the court’s final opinion for Rudisill. “If the statute were ambiguous, the pro-veteran canon would favor Rudisill, but the statute is clear, so we resolve this case based on statutory text alone.”

Rudisill enlisted in 2000 but bounced in and out of the military over the next decade. He served a total of eight years over three separate active duty hitches. He deployed to Iraq and Afghanistan, where he saw combat and suffered multiple injuries. Rudisill became a captain before he separated in 2011 and earned several medals and commendations, including a Bronze Star. His service earned him benefits from two GI bills: the Montgomery GI Bill which covers military service between 1985 and 2030 and the Post-9/11 Veterans Educational Assistance Act which covers service for those who joined after September 11, 2001. 

Rudisill used the Montogomery benefits to help pay for 25 months and 14 days of his undergraduate degree before rejoining the Army in 2007 for a third tour. He intended to use the Post-9/11 bill for his graduate degree and become a chaplain in the Army. 

Rudisill believed he was entitled to 36 months of Post-9/11 benefits based on his second and third periods of service, though he expected to use just 22 months of it due to the VA’s 48-month aggregate benefits cap. He soon found out that he was only eligible for 10 months and 16 days of Post-9/11 benefits — the length of his unused Montgomery benefits — due to a provision in the Post-9/11 Bill, referred to as Section 3322. Rudisill filed a notice of disagreement with the VA, which denied his claim.

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With the Supreme Court’s latest ruling, veterans will be able to use both bills for their education. Rudisill however, is now too old to reenlist but said in a statement that he is grateful to help future service members receive benefits they were “promised after their service to our country.”

Kate Kuzminski , director of the Center for a New American Security, a Washington D.C. think tank’s military program said the number of impacted veterans may be smaller than the 1.7 million figure, noting that the case was centered around a lost opportunity instead of veterans who were actually forced to use one GI bill benefits in lieu of another.

“I don’t know if there will be a push to kind of recoup the difference for people who were told that they had to continue on the Montgomery GI Bill before they could use their Post-911,” Kuzminski said. “Now that the law has changed, theoretically, [the VA] would have to take a look because they need to know how much they need to budget for if there is some sort of follow up for anyone who came after.”

Supreme Court sides with Army veteran in overlapping GI Bill benefits case

McHugh said that the firm has heard from hundreds of veterans who were forced to use post-9/11 GI bill benefits over Montgomery bill benefits, or vice versa, including several veterans that the firm now represents. He believes the number is growing and could be closer to two million veterans at this point.

“I think Congress should keep an eye on how the VA implements this,” McHugh added. “If there is any sort of lack of statutory authority for the VA to retroactively do right by these folks – who they never told were being denied benefits – then how would they know to challenge anything?”

The Montgomery bill, dating back to WWII, gives veterans who served two to three continuous years $36,000 for their studies, a “limited stipend” that “ordinarily does not pay the full costs of a veteran’s education,” according to the court’s opinion. The Post-9/11 bill, however, gives veterans who served three years “enhanced educational assistance benefits” which translates to the “actual net cost” of state tuition, and a stipend for extra costs like housing, books, and supplies.

The decision

A federal circuit court had previously decided that Rudisill had made an “election” for the 36-month limit. When the case made it to the Supreme Court, the dispute came down to the definition of “coordination” or election of veteran benefits.

The dissenting judges, Justices Clarence Thomas and Samuel Alito, argued that a veteran’s “coordination” of their benefits is required because they are limited in using the two GI bills concurrently.

When denying Rudisill’s benefits, the VA pointed to section 3322 which was enacted by Congress and “provides that a servicemember meeting the criteria for both GI bills can elect to swap Montgomery benefits for the more generous Post-9/11 benefits, up to a total of 36 months of benefits,” according to the Supreme Court. 

“If you served during the Gulf War, do four years then earn the Montgomery GI Bill, and then get out and you’re out from ‘95 to 2001 but then 9/11 happens and you reenlist – I think it makes perfect sense that those are very different periods, different wars, different everything,” McHugh said. “Of course, Congress would want you to get two benefits. But under the VA’s view, you would have to give that up.”

However, the court’s majority argued that the provision addressing veterans with more than one entitlement “does not require, or even mention, coordination” but rather “coordination of entitlement.” 

“Rudisill has no need to coordinate any entitlement: He is already entitled to two separate benefits,” the court said. The justices also said that the provision in question aims to prevent double dipping which Rudisill is not doing by using his GI bill benefits separately.

Kuzminski said the dissenting opinion by two of the court’s more conservative justices wasn’t surprising when it comes to balancing veteran’s issues with costs like the value of military service and providing service members with different social safety nets. While new for the Supreme Court, those philosophical questions have played out in law and policy, she said.

“There’s been a gradual shift over time in the perception of what types of health care benefits are provided to service members. Back towards the origins of the VA, it was very much clear service-connected, you were an amputee from an injury you sustained in war,” she said. “As we evolved over time and particularly post-Gulf war, it was at times difficult to separate what is service-connected from what is not.”

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Patty Nieberg

Patty is a senior staff writer for Task & Purpose. She has covered the military and national defense for five years, including embedding with the National Guard during Hurricane Florence and covering legal proceedings for a former al Qaeda commander at Guantanamo Bay. Her previous bylines can be found at the Associated Press , Bloomberg Government , Washington Post , The New York Times , and ABC . Contact the author here.

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CDER Center for Clinical Trial Innovation (C3TI)

Streamlined Trials Embedded in clinical Practice (STEP) Demonstration Project

C3TI aims to promote the adoption of pragmatic design elements to integrate randomized trials into clinical practice and improve coordination and collaboration between CDER and sponsors to effectively support these innovative trials. To this point, CDER will partner with sponsors on trials that include limited procedures outside of routine clinical care, decentralization of procedures that can be done outside of designated research sites, the use of real-world data to obtain outcomes, and, where appropriate, the integration into point-of-care practice. These types of trials are advantageous as they can be more resource-efficient, able to better attract broader study populations, can be completed more rapidly, and yet still robustly assess study objectives.

With the Streamlined Trials Embedded in clinical Practice (STEP) demonstration project, C3TI looks to partner with sponsors planning pragmatic/point-of-care trials to provide an opportunity to address and resolve issues (e.g., statistical analyses, incorporation of real-world data and evidence, trial endpoint selection, inspectional approaches) around trial design and conduct, the lessons learned from which will be made available broadly and used to inform updates to relevant CDER guidance.

Benefits of participating

By participating, sponsor(s) would receive additional CDER engagement support for trial design and implementation aspects, which includes leaders across several CDER offices (e.g., Office of Medical Policy, Office of New Drugs, Office of Translational Sciences). Engagement may include access to additional coordination support with CDER subject matter experts and an inspection process that is fit-for-purpose for the innovative design (i.e., focused on a quality by design approach).

Eligibility Criteria for STEP Demonstration Project Proposals

  • The sponsor has an active pre-Investigational New Drug (IND) or IND for the product(s) included in the proposal.
  • The trial incorporates pragmatic design elements that are reflective of routine clinical practice to improve trial efficiency and enhance patient centricity while maintaining patient safety and data integrity. Examples of pragmatic design elements include (but are not limited to) broad eligibility criteria, limited visits and procedures outside of what might occur in routine care, including incorporation of decentralized procedures, and limited safety data collection consistent with ICH E19.
  • Trial later in pre-market development, when the safety profile is reasonably well-defined.
  • Post-approval trial (either that the sponsor initiated or in response to a post-marketing requirement), wherein the population, trial procedures, and endpoints can all be appropriately incorporated into a large simple trial. 

Of note, trials with narrow entry criteria, complex procedures, complex drug administration, or challenging endpoint collection will likely NOT be appropriate.

  • Sponsors participating in demonstration projects will be expected to share select details of their clinical trials and the implementation of clinical trial innovations as they progress, starting as early as the finalization of study design. This sharing may include updates, lessons learned, and relevant insights gathered during the trial. It is understood that these shared details will reflect general principles and innovative aspects, while maintaining the necessary confidentiality of proprietary or sensitive information.

Instructions on how to submit a proposal can be found on the C3TI Demonstration Program Proposal Submission webpage.

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Education & Transition

Supreme court rules in favor of veteran who sued over gi bill limits.

what is a coordination of benefits used for

The Supreme Court on Tuesday ruled in favor of a veteran who unsuccessfully tried to use both his Post-9/11 GI Bill and Montgomery GI Bill benefits , saying that Veterans Affairs officials erred in limiting his education support.

The 7-2 decision could have far-reaching impact on student veterans who use up their VA benefits but still wish to continue degree programs. Lawyers for the plaintiff have estimated as many as 1.7 million veterans nationwide could benefit from the ruling, but federal officials have estimated the number to be less than 30,000 individuals.

The case has been closely watched by veterans advocates for nearly nine years because of its potential ramifications. VA pays out more than $8 billion in education payments annually, and the Supreme Court ruling could boost that figure even higher.

The legal fight centered on Jim Rudisill, a 43-year-old Army veteran who was wounded in a roadside bomb attack in Iraq in 2005. Rudisill used all of his Post-9/11 GI Bill benefits shortly thereafter, but later wanted to tap into his unused Montgomery GI Bill benefits to attend Yale Divinity School as part of the process to become an Army chaplain.

what is a coordination of benefits used for

One vet’s GI Bill fight could win benefits for millions of other students

The case could give an extra year of benefits for veterans who have used up their post-9/11 gi bill but still have some eligibility left under the montgomery gi bill program..

When VA officials denied that move, Rudisill sued, claiming they were unfairly limiting his options. Writing for the majority, Justice Ketanji Brown Jackson called the government’s denial “nonsensical” and reversed lower court rulings supporting VA’s position.

Most veterans attending college today with federal financial support use the Post-9/11 GI Bill program, a generous benefit passed in 2008 that awards eligible veterans 36 months of tuition payouts, housing stipends and other financial assistance.

The Montgomery GI Bill program was the predecessor to that benefit, and is being phased out by the department. It offers far less money, but still can provide several thousands of dollars annually to veterans for tuition costs if they paid into the program at the start of their military service.

Currently, VA officials make students give up eligibility for the Montgomery GI Bill program when they register to begin using the Post-9/11 GI Bill. That means that once their education benefits from that program are exhausted, they cannot receive more tuition support from the other program.

But Rudisill’s attorneys argued that the limit is unfair and unfounded in federal law. Jackson agreed with that stance in her opinion.

“If service members serve for long enough, they may be entitled to both [education benefits],” Jackson wrote. “But such service members cannot receive disbursements from both entitlement programs at the same time, nor may they receive any combination of benefits for longer than 48 months.”

That’s because separate federal rules cap any government higher education payouts at 48 months, and prohibit using such benefits concurrently. Therefore, even if veterans qualify for both programs, they can only use them both in very limited circumstances.

But in Rudisill’s case, a majority of justices said that he should have been able to access about 10 months of Montgomery GI Bill benefits to attend Yale.

In his dissent, Justice Clarence Thomas said Rudisill clearly forfeited his remaining Montgomery GI Bill support when he opted for the more generous Post-9/11 GI Bill benefits, making his case moot.

The full decision is available on the Supreme Court’s website .

Leo covers Congress, Veterans Affairs and the White House for Military Times. He has covered Washington, D.C. since 2004, focusing on military personnel and veterans policies. His work has earned numerous honors, including a 2009 Polk award, a 2010 National Headliner Award, the IAVA Leadership in Journalism award and the VFW News Media award.

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Coordination of Benefits & Recovery Overview

what is a coordination of benefits used for

Additional Web pages available under the Coordination of Benefits & Recovery section of CMS.gov can be found in the Related Links section below.

The Medicare Secondary Payer (MSP) program is in place to ensure that Medicare is aware of situations where it should not be the primary, or first, payer of claims. If a beneficiary has Medicare and other health insurance, Coordination of Benefits (COB) rules decide which entity pays first. There are a variety of methods and programs used to identify situations in which Medicare beneficiaries have other insurance that is primary to Medicare. Activities related to the collection, management, and reporting of other insurance coverage for beneficiaries is performed by the Benefits Coordination & Recovery Center (BCRC).

In certain situations, after a Medicare claim is paid, CMS receives new information indicating Medicare has made a primary payment by mistake. Based on this new information, CMS takes action to recover the mistaken Medicare payment. The BCRC is responsible for the recovery of mistaken liability, no-fault, and workers’ compensation (collectively referred to as Non-Group Health Plan or NGHP) claims where the beneficiary must repay Medicare. If it has been determined that a Group Health Plan (GHP) is the proper primary payer, the Commercial Repayment Center (CRC) will seek recovery from the Employer and GHP. The CRC is also responsible for recovery of mistaken NGHP claims where a liability insurer (including a self-insured entity), no-fault insurer or workers’ compensation entity is the identified debtor. Together, the BCRC and CRC comprise all Coordination of Benefits & Recovery (COB&R) activities. The most current contact information can be found on the Contacts page. Additional information regarding the MSP program as well as COB and recovery activities can be found in the menu to the left. 

CMS has made available computer-based training courses (CBTs), flowcharts, presentations and other informational material to assist you in understanding COB&R. It is recommended you always scroll to the bottom of each Web page to see if additional information and resources are available for access or download.

How to sign-up for Coordination of Benefits & Recovery Overview Web page updates

CMS provides the ability for you to be notified when announcements or new information is posted on the Coordination of Benefits & Recovery web pages. If you have not already signed up for these notifications, please enter your e-mail address in the “Receive E-Mail Updates” box at the bottom of any CMS.gov web page and select which pages you would like to receive notifications on. When notifications and new information, regarding Coordination of Benefits & Recovery are available, you will be notified at the provided e-mail address.

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The 8 Most Impressive Health Benefits of Turmeric

Run, don’t walk, to stock up on turmeric.

The Nutritional Profile of Turmeric

The top 8 health benefits of turmeric, how much turmeric should you have everyday, ways to use turmeric at home, the bottom line.

Kolesnikovserg/Getty Image

In recent years, turmeric’s popularity has skyrocketed, thanks to its touted health benefits. “Turmeric is a vibrant yellow spice native to India and Southeast Asia that has been used for thousands of years for its medicinal properties,” says Amy Davis, RD, LDN Registered Dietitian at FRESH Communications. This beautiful root from the Curcuma longa plant can be enjoyed ground, juiced, or in its natural root form in both sweet and savory dishes. But what does current-day research tell us about the health benefits of turmeric? And what are the best ways to use it at home? We’ve got you covered with the answers to these questions and more in this turmeric tell-all.

“Historically, turmeric has been used in traditional Indian medical systems, as a common spice , and as a food coloring,” explains Davis. But when it comes to health benefits, you won’t find significant amounts of macronutrients like carbohydrates, protein , or fat in this spice. Rather, turmeric is an excellent source of micronutrients like vitamins, minerals, and plant compounds, and this is where most of its health benefits spawn from. In terms of vitamins and minerals, turmeric contains impressive amounts of manganese , iron, potassium , and vitamin C . “But turmeric also contains compounds called curcuminoids – with curcumin being the most prominent and well-researched,” says Davis. “These compounds belong to a class of polyphenols and have been shown to have antioxidant and anti-inflammatory effects.” In fact, curcumin is largely to thank for many of the benefits turmeric boasts. Its antioxidant properties positively affect nearly every body system.

So, what are those benefits? “Ancient Chinese medicine typically used turmeric for skin , joint , and digestive treatments,” Davis adds. Let’s see how these claims stack up to the latest research, with the top eight evidence-based benefits of turmeric:

Turmeric Boosts Immune Health

As a rich source of vitamin C and plant compounds (also known as polyphenols) like curcumin, turmeric’s antioxidant and anti-inflammatory effects boost overall immune health . This is partly because antioxidants search out and eradicate free radical molecules that are at the root of many chronic and acute illnesses. In fact, a 2019 Nutrients article even found curcumin to be effective against cancer.

Turmeric Champions Heart Health

Another chronic illness that free radicals contribute to is heart disease, making turmeric a powerful preventative measure. Research has found the curcumin in turmeric to be protective against both atherosclerosis—plaque build-up on the arteries and veins that can lead to the development of heart disease—and overall heart disease risk . This spice may also help to manage high cholesterol levels in the blood, which can further contribute to atherosclerosis. The magnesium, potassium, and iron found in turmeric also supports healthy heart rhythms and blood health.

Turmeric Aids Metabolic Health

For those with metabolic disorders like type 2 diabetes (or those looking to prevent them), turmeric is also a great addition. This is thanks to the fact that the spice has been found to aid in the regulation of blood sugars and the inflammatory response, helping to treat or prevent these conditions.

Turmeric Helps to Improve Mental Health

Interestingly, turmeric is often turned to for mental health aid – and we have the evidence to support this practice. This benefit is due, in part, to curcumin’s ability to increase brain-derived neurotrophic factor (BDNF) levels. BDNF plays an important role in behavior, learning, cognition, and memory, which bodes well for mood disorders like anxiety and depression . In fact, several studies have found this bioactive compound in turmeric to be effective in treating both conditions.

Turmeric Encourages Overall Brain Health

Speaking of brain health , turmeric may also help to ward off neurodegenerative disorders, like Alzheimer’s disease and dementia. Curcumin’s ability to increase BDNF levels certainly has a hand in this benefit, but there’s also plenty of research to back these claims. One 2018 study found daily curcumin administration to be linked to improved memory, attention, and mood in older adults, thanks to decreases in amyloid and tau accumulation in the brain. Amyloid and tau are proteins that can build up in the brain and disrupt communication between brain cells, potentially leading to neurodegenerative conditions. Further research has also found a positive correlation between curcumin and Alzheimer’s disease prevention.

Turmeric Promotes Joint Health

The anti-inflammatory nature of turmeric benefits joint health, too – especially for those dealing with concerns like arthritis. One 2021 study found turmeric supplementation to be nearly as effective as nonsteroidal anti-inflammatory drugs (NSAIDs) for individuals with osteoarthritis in the knees. Additionally, a 2022 paper found curcumin to be effective in treating osteoarthritis pain across the body.

Turmeric Supports Gentle Aging

Curcumin’s (and thus turmeric’s) antioxidant properties are also effective against signs of aging , such as fine lines, wrinkles , and dark spots . This has been shown in several studies, including this 2021 review of the evidence available at the time of publishing.

Turmeric Improves Gut Health

And finally, turmeric may also support a healthy gut . This is thanks to its positive influence on the gut microbiome , helping to regulate and support this important system. The gut microbiome is a colony of trillions of microorganisms found largely in the colon that supports immune, brain, and digestive health (among many other impressive benefits).

So, with all these exciting health perks of turmeric, you may be jumping at the chance to start including more of this spice in your meals and snacks. But how much should you be aiming for on a daily basis?

From what we know so far, you’ll reap the most benefits by consuming no more than 12 grams of turmeric per day—equivalent to about 2.5 teaspoons. “Overdoing it with turmeric may cause diarrhea, constipation, or vomiting, and excessive turmeric supplementation may interfere with certain medications,” says Davis. Considering this, it’s important to consult with your healthcare provider before significantly increasing your turmeric intake if you have any pre-existing conditions.

There are so many delicious dishes that can help you add more turmeric into your routine. Its sweet, peppery flavor and brilliant yellow-orange color pairs perfectly in curries, stir fries, casseroles, soups , stews, pastas, lattes, smoothies , homemade health shots, and even spiced baked goods! Some delicious and healthy prepared foods highlight this ingredient as well. “Though, it’s important to note that turmeric is fat-soluble and poorly absorbed alone. Therefore, it should be consumed with a source of fat and piperine (an active component of black pepper) to enhance absorption,” Davis notes. These prerequisites are pretty easy to achieve in all of the dishes we’ve mentioned here.

When it comes down to it, there’s no denying that turmeric is a bonafide superfood . This is thanks to the plethora of micronutrients found in this spice, especially the bioactive compound curcumin. The antioxidant and anti-inflammatory nature of these nutrients support so many angles of health, from metabolism and heart health, to immunity and brain function. It’s just an added bonus that this popular spice brings a beautiful color and flavor to any dish it’s added to.

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  25. What Is Coordination of Benefits?

    Note: If you have Medicare and another plan, coordination of benefits is always used. Medicare may be either primary or secondary based on the Medicare coordination of benefits. Letting your insurer know you have Medicare up front will save you and your doctor time when it comes to filing claims.

  26. Supreme Court rules in favor of veteran who sued over GI Bill limits

    The Supreme Court on Tuesday ruled in favor of a veteran who unsuccessfully tried to use both his Post-9/11 GI Bill and Montgomery GI Bill benefits, saying that Veterans Affairs officials erred in ...

  27. Coordination of Benefits & Recovery Overview

    The Medicare Secondary Payer (MSP) program is in place to ensure that Medicare is aware of situations where it should not be the primary, or first, payer of claims. If a beneficiary has Medicare and other health insurance, Coordination of Benefits (COB) rules decide which entity pays first. There are a variety of methods and programs used to ...

  28. KEH's 'Better Than New' Campaign Highlights Environmental Benefits of

    Used marketplaces help make photography more accessible and reduce the barrier to entry. The more options photographers have, and the more accessible photography is, the better. Environmental Benefits

  29. The 8 Most Impressive Health Benefits of Turmeric

    The Nutritional Profile of Turmeric "Historically, turmeric has been used in traditional Indian medical systems, as a common spice, and as a food coloring," explains Davis.But when it comes to health benefits, you won't find significant amounts of macronutrients like carbohydrates, protein, or fat in this spice.Rather, turmeric is an excellent source of micronutrients like vitamins ...

  30. ECA Notices

    APPLICATION NOTICE. As required by the Water Projects Environmental Coordination Act, K.S.A. 82a 325-327. For Technical Questions Contact: Krista Sylvester. Notice No.: 2024132. Date of Notice: 4/16/2024. WS No.: LBT-0118. Expiration Date: 5/16/2024. Project No.: 204 Coolidge St. This notice of application is provided so that interested persons ...