CO-190: Payment Included in SNF Qualified Stay Allowance

What Does CO-190 Mean?

CO-190 is the standard pairing and means the service is bundled into the SNF's per diem rate under the provider's contract. The provider cannot bill the patient separately for this service — it is a contractual write-off. However, the provider should coordinate with the SNF to obtain payment from the facility if the SNF is responsible for arranging and paying for the service from their bundled rate.

CARC 190 appears on your remittance when the payer determines that the billed service is part of the Skilled Nursing Facility's consolidated billing package and cannot be reimbursed separately. Under Medicare's SNF Prospective Payment System (PPS), the SNF receives a bundled per diem rate that covers virtually all services the patient receives during a qualified stay — including therapy, medications, lab tests, and supplies.

This denial most commonly hits outside providers who furnish services to SNF patients without realizing that the service is included in the SNF's payment. For example, a lab company that draws and processes bloodwork for an SNF patient, or a therapy provider who renders services at the facility, may bill the payer directly only to discover that the service was already covered under the SNF's rate. The SNF is responsible for paying these providers from its per diem payment.

There are important exceptions. Certain services are excluded from SNF consolidated billing and can be billed separately — including physician professional services, certain dialysis services, specific ambulance transports, and some high-cost imaging. The SNF consolidated billing exclusion list maintained by CMS specifies exactly which services can be separately billed. If your service is on the exclusion list, the denial may be in error and you can resubmit with the appropriate modifiers and documentation.

Common Causes

How to Resolve

Determine if the service is included in the SNF consolidated billing bundle or qualifies for separate billing under the CMS exclusion list, then either write off the claim or resubmit with correct coding.

1. Check the exclusion list Determine whether the service falls on the CMS SNF consolidated billing exclusion list. If it does, the service can be billed separately with the correct coding and modifiers.
2. Resubmit or bill the SNF If excludable, correct the coding and resubmit to the payer. If bundled, bill the SNF directly for the service, as the facility received the per diem payment that covers it.
3. Establish SNF billing agreements If you regularly provide services to SNF patients, establish formal billing agreements with the SNF that clarify which services you bill to the payer and which you bill to the facility.

Common RARC Pairings

The RARC code tells you exactly what triggered the CO-190:

How to Prevent CO-190

• Check the patient's SNF stay status before rendering services to determine if consolidated billing applies
• Maintain current knowledge of the CMS SNF consolidated billing exclusion list and update billing procedures when changes are published
• Implement billing system edits that flag services commonly bundled under SNF consolidated billing
• Establish clear billing agreements with SNFs for services rendered to their patients
• Train billing staff on SNF consolidated billing rules and the distinction between excludable and non-excludable services

General Prevention

• Train billing staff on Medicare SNF consolidated billing rules and which services are included in the SNF per diem rate versus those that can be billed separately
• Implement billing system edits that flag services typically bundled under SNF consolidated billing to prevent separate billing errors
• Verify the patient's SNF stay status and dates before submitting claims for services rendered during the stay period
• Maintain current knowledge of the SNF consolidated billing exclusion list and update billing procedures when CMS makes changes
• Coordinate billing between the SNF and outside providers to ensure services are billed correctly and not duplicated

Also Filed As

The same CARC 190 may appear with different Group Codes:

Related Denial Codes