US · guidance
CMS Pub. 100-04, ch. 28, § 70.6.3
Coordination of Benefits Agreement (COBA) Eligibility File Claims Recovery
Process
(Rev. 10638; Issued: 03-09-21; Effective: 04-05-21; Implementation: 04-05-21)
Effective January 2, 2007, when the CMS or the BCRC determines that 1) certain members on a COBA
production trading partner’s eligibility file were not properly loaded to the Common Working File (CWF)
Beneficiary Other Insurance (BOI) auxiliary file (see §70.6 of this chapter for more details regarding this
file) or 2) a COBA production trading partner’s claims selections, as conveyed via the COBA Insurance File
(COIF), were not properly loaded to the CWF, the CMS shall send the A/B MAC crossover contact(s) and
associated Virtual Data Center (VDC) a ‘COBAProcess’ e-mail communication. When the CMS sends a
“COBAProcess” e-mail communication to an A/B MAC to initiate a COBA eligibility file claims recovery
process, the A/ B MAC shall acknowledge receipt of the communication via return e-mail within 1 business
day. The CMS will then contact the A/B MAC’s crossover staff and associated VDC either via phone or e-mail to discuss the specific Common Working File (CWF) date span (i.e., process date) or claim date of
service parameters, or both, for the claims recovery process. Additionally, CMS will specify which specific
MAC(s), by state, will be involved in the COBA claims recovery activity. (NOTE: DME MACs and their
shared system may be required to implement the COBA eligibility file claims recovery process as part of a
future instruction.)
Following the telephone discussion between the CMS and the A/B MAC crossover staff, the COBA
eligibility file recovery process will further unfold as detailed below.
1. Receipt and Processing of the BCRC COBA Eligibility File and Searching Claims History for the
Needed Claims
Until April 5, 2021, as part of an active COBA claims recovery, the two VDCs that support the A/B MACs
shall complete an Electronic Transmittal Form (See Attachment A at the conclusion of this section) on behalf
of their associated MACs that are participating in a COBA claims recovery process. (Note: The COBA E01
eligibility file contains specifications on the COBA trading partner and the individuals whose claims need to
be recovered.)
Effective April 5, 2021, the VDCs shall be prepared to accept the following modified dataset names for the
COBA E01 Eligibility File as received from the CMS BDC:
Perspecta VDC Part A Recovery E01 Eligibility File: ASH0.FISP.HBADR.GHI.FSSFCOBE(+1)
Perspecta VDC Part B Recovery E01 Eligibility File: B999.MCSP.HBXDR.AR99RCVR(+1)
Companion Data Services (CDS) VDC Part A Recovery E01 Eligibility File:
ASP2.FISP.NDM.FSSFCOBE(+1)
CDS VDC Part B Recovery E01 Eligibility File: B999.MCSP.HBXDR.AR99RCVR(+1)
Through the COBA claims recovery process, the COB&R system supporting the BCRC sends the appropriate
VDC a copy of the trading partner’s COBA eligibility file(s), which will be prepared in accordance with the
CMS proprietary format. (Note: The COB&R system supporting the BCRC will transmit the COBA
eligibility file to the VDC through its existing Connect: Direct connection.) The VDC then notifies the
affected A/B MAC(s) that the COBA recovery eligibility file is available so that the A/B MAC(s) may
initiate a claims recovery.
Effective April 1, 2019, the shared systems supporting the A/B MACs shall accept either a Health Insurance
Claim Number (HICN) or Medicare Beneficiary Identifier (MBI), as reported via the COBA E01 eligibility
file, in the field defined as “Beneficiary Medicare ID” (file displacement 64—75).
The A/B MAC shall initiate recovery of the processed claims by systematically going against its online
claims history that meet the beneficiaries’ eligibility dates, as provided on the BCRC eligibility file(s), and
that fall within the specified CWF date span (i.e., process date) or date of service parameters, or both, that
CMS has provided to the A/B MAC.
In performing the COBA claims recovery, MACs shall not attempt to recover claims that were previously
transmitted to the BCRC. "Previously transmitted claims" may be identified by the claims' crossover
location status or the presence of the COBA ID being used for the recovery process along with a "P"
(production) indicator in association with the processed claims.
Additionally, the MAC shall not apply the COBA trading partner's selection criteria, as found on the Health
Insurance Master Record (HIMR) COBS, when recovering claims.
2. Time Frames for Recovery
The A/B MAC shall complete its claims recovery process, culminating with transmission of the recovered
claims to the COB&R system supporting the BCRC, within eight (8) work days following the date that it
receives the BCRC COBA eligibility file or as soon as possible thereafter as CMS directs.
3. Using Data Elements from the COBA Eligibility File For the Claims Recovery Process and
Copying Elements from That File to the Recovered Claims Flat File
A/ B MACs shall perform the following activities related to the COBA eligibility file:
a) Utilize each beneficiary’s coverage dates from the COBA eligibility files (file
displacement 121—128 for beneficiary supplemental eligibility-from date and file
displacement 129—136 for beneficiary supplemental-to date); and successive eligibility-from and eligibility-to dates if provided);
b) Apply the specified CWF date span; or
c) Apply the date of service parameters; or
d) Both items b and c above.
Once the A/B MAC, working with the VDC as necessary, has recovered the specified claims, it shall copy
the COBA ID from the BCRC COBA eligibility file and place it within the NM109 segment of the 1000B
loop of the flat file containing the recovered Part A and B claims.
4. Using Data Elements from the COBA Eligibility File For the Claims Recovery Process and
Copying Elements from That File to the Recovered Claims Flat File
A/ B MACs shall perform the following activities related to the COBA eligibility file:
e) Utilize each beneficiary’s coverage dates from the COBA eligibility files (file
displacement 121—128 for beneficiary supplemental eligibility-from date and file
displacement 129—136 for beneficiary supplemental-to date); and successive eligibility-from and eligibility-to dates if provided);
f) Apply the specified CWF date span; or
g) Apply the date of service parameters; or
h) Both items b and c above.
Once the A/B MAC, working with the VDC as necessary, has recovered the specified claims, it shall copy
the COBA ID from the BCRC COBA eligibility file and place it within the NM109 segment of the 1000B
loop of the flat file containing the recovered Part A and B claims.
4. Scope of the Claims Recovery Effort
Neither the A/B MAC nor its VDC shall be required to search archived claims history while fulfilling the
COBA eligibility file claims recovery process.
The A/ B MAC and its VDC shall not be required to apply the COBA production trading partner’s selection
criteria before transmitting the recovered claims to the BCRC.
The A/B MAC or its VDC shall not transmit claims that had previously been sent to the BCRC as part of the
COBA eligibility file claims recovery process, as demonstrated by the claims’ crossover location status or
the presence of a COBA identification (ID) number accompanied by a ‘P’ (production) indicator in relation
to the processed claims.
5. Populating a Unique BHT-03 Identifier to Designate Recovered Claims
The A/ B MAC shared systems shall be required to populate an ‘R’ indicator in the 22nd position of the
Beginning of the Hierarchical Transaction (BHT)-03 segment of the ASC X12 837 flat file when
transmitting recovered claims for COBA production trading partners to the BCRC. (NOTE: The CMS
would only consider invoking the COBA eligibility file recovery process for trading partners that are in
production mode. Therefore, this practice does not conflict with previous guidance issued by the CMS,
which may be referenced in §70.6.1 of this chapter.)
6. Preparation and Transmission Requirements
The recovered claim files shall be prepared in the same ASC X12 837 flat file format used for normal, daily
transmissions to the COB&R system in support of BCRC, as discussed in §70.6 of this chapter.
Effective April 5, 2021, in transmitting the recovered claims to the CMS BDC (which, in turn, transmits the
files to the COB&R system in support of the BCRC), the VDCs shall transmit the claims via a separate ASC
X12 837 flat file transmission using the modified EFT dataset names shown below.
• P/T#EFT.ON.COBA.PA.Cxxxxx.RCV.Dyymmdd.Thhmmsst [For 837 Institutional Claims]
• P/T#EFT.ON.COBA.PB.Cxxxxx.RCV.Dyymmdd.Thhmmsst [For 837 non-DMEPOS Professional
Claims]
Note the following definitions apply to the dataset names above:
• P/T – “P” = Production; “T”=Test
• Cxxxxx = C + the 5-digit MAC ID; e.g, C12302
• Dyymmdd.Thhmmsst = Current date and Time concatenated to literals D and T.
The VDCs shall send no more than 100,000 recovered claims (which equates to 20 ST-SE envelopes per
A/B MAC with 5,000 claims per envelope) to the COB&R system supporting the BCRC per transmission.
7. Marking Claims History To Assist Customer Service Efforts
When the VDC transmits the recovered claims to the COB&R system supporting the BCRC, the A/B MAC
shall mark its claims history to indicate that each claim was recovered and transmitted to the BCRC to be
crossed over to the COBA trading partner.
A/B MACs shall notify their customer service representatives that they will be able to determine that
recovered claims were sent to the BCRC by referencing claims history.
8. BCRC Detailed Error Report Processes In Relation to the Claims Recovery Process
If A/B MACs receive BCRC Detailed Error Reports that contain a 22-byte BHT-03 identifier that ends with
an ‘R,’ they shall suppress generation of provider letters, regardless of the error source code indicated
(‘111,’ ‘222,’ or ‘333’).
When the A/B MAC, or its shared system, receives BCRC Detailed Error Reports for recovered BCRC
Detailed Error Reports for recovered claims that contain ‘111,’ ‘222,’ or ‘333’ errors, it shall mark its claims
history to indicate that the recovered claims will not be crossed over.
9. The Possibility of Repairing COBA Recovery Claims
A/B MACs, and their shared systems, shall assume that recovered claims for COBA production trading
partners that exceed established percentage parameters for ‘111,’ ‘222,’ and ‘333’ errors are potential
candidates for the COBA repair process, as provided in §70.6.2 of this chapter.
In accordance with the full claim file repair process discussed in 70.6.2 of this chapter, A/B MACs and their
shared systems shall populate an ‘18’ Beginning of the Hierarchical Transmission (BHT)-02 transaction set
purpose code at the ST-SE envelope level when transmitting the ‘repaired’ COBA recovery claims.
Unlike the process documented in §70.6.2 of this chapter, A/B MACs shall transmit ‘repaired’ COBA
recovery claims to the COB&R system supporting the BCRC via the separate ASC X12 837 flat file
transmission for recovery claims, as described within "Preparation and Transmission Requirements” above.
In addition, unlike the existing full claim file recovery process documented in §70.6. 2 of this chapter, A/B
MACs and their shared systems shall include an ‘R’ in the 22nd position of the BHT-03 identifier when
transmitting the ‘repaired’ COBA recovery claims to the COB&R system supporting the BCRC.
A/B MACs, or their shared systems, shall also not generate provider notification letters if they, in
conjunction with CMS, determine that the recovered claims that contained severe errors cannot be repaired.
10. COBA Claims Recovery Financial Management Processes
The CMS will reimburse the A/B MAC for individual claims accepted by the trading partner at the current
per claim rate.
The A/B MACs’ shared systems shall develop a separate report for their associated A/B MACs to enable
them to fulfill the foregoing requirements. The shared systems shall create reports that will provide MACs
with the count of recovered claims per cycle.
Attachments A and B Relating to the COBA Claims Recovery Process
Special note: With the modernization of the Electronic Files Transfer (EFT) process used for COBA, the
A/B MACs and their associated VDCs will no longer need to complete the Electronic Transmittal Form
(Attachment) A, as included below, prior to initiating a COBA claims recovery process effective April 5,
2021.
Attachment A
ELECTRONIC TRANSMITTAL FORM
Project: Coordination of Benefits Agreement (COBA)
Task: COBA Claims Recovery Process
Contact Information
Company Name: __________________________
Contact Name: ______________________________ Phone# ___________ ext. _
Contact Email Address: ______________________________________________
CMSNet Information
Account ID:___________________ Node ID: ________________
IP Address: ___________________ Port: ____________________
Production Requirements
Filename(s): _______________________________________________________
Special Instructions (e.g., file triggers):
Test Requirements
Filename(s):
Special Instructions (e.g., file triggers):
Attachment B
COBA Eligibility File
Table 1: COBA Eligibility E01 Record Layout Header – E00
Data Element Description Field
Length
MO Field
Location
HEADER RECORD
TYPE
Value -E00 3X O E00.001
HEADER COBA ID COBA ID assigned by the COBC
Field is 9 position, alphanumeric (no
special characters), left justified, last
four positions are spaces.
Mandatory.
9X O E00.002
HEADER CREATION
DATE
Date the record was created; format:
(CCYYMMDD), with no special
characters
8X O E00.003
HEADER BENEFICIARY
STATE CODE
Beneficiary State of residence
NOTE: This field will not be
used by the COBA Process.
2X O E00.004
FILLER Blank Field. Value is spaces. 178X O E00.005
Table 2: COBA Eligibility E01 Record Layout
File attributes:
Format: Fixed block
Length: 200 bytes
Data Field Length Type Displacement Description
Record type 3 Alpha-Numeric 1–3 Type of Record Set to ‘E01’.
Mandatory
COBA ID 9 Alpha-Numeric 4-12 Coordination of Benefits
Agreement Identification
Number Field is 9 position,
alphanumeric (no special
characters), left justified, last
four positions are spaces.
Mandatory
File Effective Date 8 Alpha-Numeric 13-20 Effective date of file in
CCYYMMDD format with no
special characters.
Mandatory
Data Field Length Type Displacement Description
File Update Indicator 1 Alpha-Numeric 21 Type of update values:
‘A’ = Add
‘C’ = Change/Update
‘D’ = Delete
Required as of March
1, 2007
*Beneficiary Surname 20 Alpha-Numeric 22-41 Beneficiary last name
Mandatory
Uppercase characters only
*Beneficiary First 12 Alpha-Numeric 42-53 Beneficiary first name.
Mandatory
Uppercase characters only
Beneficiary Middle
Initial
1 Alpha-Numeric 54 Beneficiary middle initial.
Optional
Uppercase characters only
*Beneficiary Birth Date 8 Alpha-Numeric 55-62 Beneficiary date of birth in
CCYYMMDD format with no
special characters.
Mandatory
*Beneficiary Sex Code 1 Alpha-Numeric 63 Beneficiary sex code values
are: ‘M’ = Male ‘F’ = Female
NOTE: If unknown, default to
‘M’
Mandatory
Uppercase characters only
Beneficiary Medicare
ID
12 Alpha-Numeric 64-75 Beneficiary Medicare ID
(Medicare Health Insurance
Claim Number [HICN] or
Medicare Beneficiary
Identifier [MBI]).
Mandatory
Beneficiary
Supplemental ID
Number
25 Alpha-Numeric 76-100 Supplemental ID on file with
sender. Should be the same
as what is submitted on the
claim.
Optional
Beneficiary Group
Policy Number
20 Alpha-Numeric 101-120 Supplemental policy number
on file. Should be the same as
what is submitted on the claim.
Optional
Beneficiary
Supplemental Eligibility
From Date-1
8 Alpha-Numeric 121-128 Medicare supplemental
“from” date in CCYYMMDD
format with no special
characters.
Mandatory
Data Field Length Type Displacement Description
Beneficiary
Supplemental
Eligibility To Date-1
8 Alpha-Numeric 129-136 Medicare supplemental “to”
date in CCYYMMDD
format with no special
characters NOTE: This is
the coverage through
date. Indicate zeros for
open-ended dates.
Mandatory
Filler 64 Alpha- Numeric 137-200 Unused Field – Populate
with spaces
Table 3: COBA Eligibility E01 Record Layout Trailer Record – E99
Data Element Description Field
Length
MO Field
Location
Record Type Value is 'E99'. 3X M E99.001
E01 Record Count Total number of E01 records in this file. 7N M E99.002
Filler Blank Field – Value is spaces 190X M E99.003
History
(Rev. 10638; Issued: 03-09-21; Effective: 04-05-21; Implementation: 04-05-21)
Provenance
- Source
- cms.gov
- Retrieved
- 2026-08-25
- Edition
- iom-2026-08-25
- Content hash
5e03c45c105fc5167b7369661e2035a295a02f127180bf573b40efb4b672a2ff
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