What should I do if I receive two primary payments?

There are times when a provider will receive a primary payment from another insurance company after Medicare has paid as primary. When this happens, it is assumed that Medicare should be the secondary payer. If you receive two primary payments, you should refund Medicare’s payment in full. In order to refund the Medicare overpayment, the provider should adjust the claim to bill Medicare secondary.

  • Refund the Medicare payment to Palmetto GBA within 60 days of the date you receive the duplicate payment, even if Medicare’s records show that Medicare is primary
    • Adjust the claim to bill Medicare secondary
    • Use Condition Code D7 — Change to Make Medicare the secondary payer
    • Remarks should be entered on the claim explaining the payment from the primary and change to Medicare secondary

Note: Medicare will allow adjustment claims to process past the Medicare timely filing limits in order to pay back a Medicare overpayment. The provider should add remarks on the claim that state they are adjusting the claim and need timely filing extended in order to pay back a Medicare overpayment.

  • If Medicare records show that Medicare is primary for the patient, the provider will need to request that these records (Common Working File or CWF records) be updated to reflect that Medicare is secondary prior to submitting the claim. The Coordination of Benefits (COB) contractor will update the records.
    • Please note that updates to CWF records can take up to 100 days
    • If claim adjustments are sent before the records are updated, the adjustment claim will reject with reason code U6802, instructing the provider to contact COBC, now referred to as the Benefits Coordination & Recovery Contractor (BCRC), to set up the record
    • When the provider submits subsequent claims, the system will attempt to generate a record to CWF and post. If the record was not successful in posting, all subsequent claims will automatically reject until there is a valid record on CWF.
  • Providers are reminded that they are responsible for determining when Medicare is primary or secondary by way of completing the Medicare Secondary Payer Questionnaire (MSPQ). Another good resource for understanding when Medicare pays primary or secondary is the MSP Lookup Tool, which is available on Palmetto GBA's website.

Reference: CMS IOM Publication 100-05, Chapter 3, Section 10.4 (PDF, 234 KB)

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