CO-198: Precertification/Authorization Limits Exceeded
You delivered more services than were authorized and did not get an extension. Request retro authorization or appeal with medical necessity documentation. You cannot bill the patient for the denied amount.
What Does CO-198 Mean?
CO-198 means the provider exceeded the authorized limit and the financial responsibility falls on the practice. The provider's contract required obtaining additional authorization before delivering services beyond the approved scope, and that step was not completed. The provider cannot bill the patient for the denied amount — it is a contractual write-off unless successfully appealed.
CARC 198 signals that the precertification, authorization, notification, or pre-treatment requirements were exceeded — not missing, but surpassed. An authorization was in place, but the services delivered went beyond its scope. This could mean more visits than approved, more units than authorized, treatment dates outside the authorization window, or medication quantities above the pre-approved amount.
This denial is particularly common in therapy practices (physical therapy, occupational therapy, speech therapy) where initial authorizations cover a limited number of sessions and the patient's condition requires additional treatment. It also appears in behavioral health settings with session caps, DME orders that exceed quantity limits, and surgical cases where intraoperative findings require additional procedures beyond the original authorization scope.
The group code determines who absorbs the financial impact. Under CO, the provider is responsible because the contract required the provider to obtain additional authorization before exceeding the limit. Under PR, the patient is responsible when they have exhausted their plan's benefit limit for that service type (e.g., 20 PT visits per year). The distinction matters because CO means you cannot bill the patient, while PR means you should bill the patient directly.
Common Causes
| Cause | Frequency |
|---|---|
| Authorized visit or unit count exceeded The provider delivered more visits, sessions, or units than the payer authorized, and the excess services are denied under the contractual obligation | Most Common |
| Authorization expired before service was rendered The authorization had a validity period that expired before all services were completed, and the provider continued treatment without obtaining a new or extended authorization | Most Common |
| Treatment duration exceeded approved scope The treatment plan extended beyond the approved duration (e.g., physical therapy sessions continued past the authorized treatment window) without obtaining reauthorization | Common |
| Medication quantity exceeded authorized amount The prescribed medication quantity or dosage exceeds what was pre-approved by the payer | Common |
| Failure to request authorization extension The provider did not submit a request for extended or additional authorization before the current authorization limit was reached | Common |
| Services billed beyond what variance allows In workers' compensation cases, the treatment provided is not consistent with the approved variance or treatment plan | Occasional |
How to Resolve
Verify which services exceeded the authorization, request a retroactive extension, and appeal if the extension is denied.
- Review the authorization scope Pull the original authorization and identify the specific limit that was exceeded — number of visits, units, date range, or procedure scope.
- Request retroactive extension Submit a retro authorization request with clinical documentation showing the patient's progress, current functional status, and why additional services were medically necessary.
- Appeal if retro extension is denied File a formal appeal with a letter of medical necessity, progress notes from each excess visit, objective outcome measures, and the original treatment plan showing the evolving clinical picture.
- Write off if all appeals fail If all appeal levels are exhausted, post the excess amount as a contractual write-off and document the outcome for future reference.
Common RARC Pairings
The RARC code tells you exactly what triggered the CO-198:
| RARC | Description |
|---|---|
| N386 | This decision was based on a National Coverage Determination (NCD) or Local Coverage Determination (LCD). |
| N130 | Consult plan benefit documents/guidelines for coverage of this service. |
| N362 | The number of Days or Units of Service Exceeds our acceptable maximum. |
How to Prevent CO-198
- Implement automated authorization tracking that alerts clinical and billing staff when the patient is approaching the authorized visit or unit limit
- Submit reauthorization requests at least 3-5 visits before the current authorization expires to ensure continuity of coverage
- Review the authorization details (dates, units, CPT codes) at every patient visit to confirm the service is still within the approved scope
- Maintain a centralized authorization log accessible to scheduling, clinical, and billing teams that shows remaining visits and expiration dates
- Train clinicians to document ongoing medical necessity at every visit, which provides the evidence needed for reauthorization requests
General Prevention
- Track authorization utilization actively and set alerts when approaching the authorized visit or unit limit
- Submit reauthorization requests well before the current authorization expires or is exhausted
- Implement automated authorization tracking in your practice management system that flags claims approaching authorization limits
- Review the authorization details (dates, units, CPT codes) before each service delivery to ensure the visit is still within scope
- Maintain a centralized authorization log accessible to scheduling, clinical, and billing staff
- Train clinical staff to document ongoing medical necessity at each visit to support future reauthorization requests
Also Filed As
The same CARC 198 may appear with different Group Codes:
Related Denial Codes
Sources
- https://www.mdclarity.com/denial-code/198
- https://x12.org/codes/claim-adjustment-reason-codes
- https://www.wcb.ny.gov/CMS-1500/WCB-CARC-RARC-codes.pdf
- Codes maintained by X12. Visit x12.org for official definitions.