Please Reference 2189 response. Although it is appropriate to include other subscriber information on a primary claim. In this situation we are "Payer of last resort". The provider submitted the claim to another Medicaid agency, received a denial/reject for the member not having coverage under that health plan, and sent the claims to us (who actually covers the member), showing us as Primary and the other health plan(s) as Secondary and/or Tertiary. We feel this is reporting of incorrect data (even though it is syntactically sound) since the other health plans do not actually cover the member and were billed incorrectly before us. Would the other health plans truly be considered "potential payers" even though they were just billed incorrectly?
This response expands on RFI 2189. As indicated in section 1.4.1.1 of the guide the insurance companies on a claim are listed in order of claim submission. It is not desirable for a provider to submit a claim to incorrect payer or in an incorrect order. If that does occur the order of the payers on the claim still are to reflect the order in which data moved from payer to payer. If a claim is submitted to an incorrect insurance payer then the 2320 loop of the claim would reflect that the payer had adjudicated and denied the claim. The denial information would be reported using either the 2320C CAS segment or the 2420 CAS segment. The next payer to receive the claim data would be shown as secondary or tertiary as appropriate.