Section title: Requests for Interpretation
Forward Balance Best Practice or Mandate (835)

Is the 005010X221A1 Balance Forward Process (FB) considered to be a federal mandate or a best practice? We have a vendor that considers the Balance Forward Processing a best practice. They state the FB is not a mandate as the guide does not say 'Must use' or 'Required'. Therefore, the vendor does not use the Forward Balance (FB) to move a negative balance out of the 835. We consider the X12 5010 guide to be a mandated at a federal level, as CMS has approved and adopted it.


Our Health Plan uses option 1, immediate overpayment recovery based on our provider contracts agreements.

Section Claim Overpayment Recovery has a note that states, "If any of the above processes result in an 835 with a negative balance (BPR02), the balance forwarding process identified in Section - Balance Forward Processing is used to eliminate the negative value in BRP02. They state that since the guide does not say MUST, that the FB is considered a best practice and not mandated and not required to follow. They use WO Overpayment recovery instead.

RFI Response

The HIPAA legislation mandated 005010X221A1 TR3 in its entirety which includes section 1 front matter in addition to the sections that include syntax.

Refer to Section 1.10.2 Data used by business Use. “This section and all subsections identify the business structure of the 835 and specific solutions or usage that relate to health care claim payment and remittance business issues. These solutions may not be the only possible solutions within an ASC X12 835 transaction. They are, however, the only solutions for the business situations identified that are compliant with this implementation guide. Creation of 835 transactions that are not consistent with the information here is prohibited under this implementation.

Section Balance forward processing states, “The adjustment reason used in PLB03-1 will be FB, "Forwarding Balance".”   The authors intention of “will be” is that FB is the required code to use.


Related RFIs:  2179, 2050, 1756, 1114