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TRICARE Reimbursement Manual 6010.64-M, April 2021
Double Coverage
Chapter 4
Section 2
Double Coverage Review And Processing Of Claims
Issue Date:  
Authority:  32 CFR 199.8
Revision:  C-10, September 20, 2024
1.0  DEVELOPMENT
1.1  All Claims Require Double Coverage Review. All claims, regardless of dollar amount, require review for possible double coverage with the following exceptions:
1.1.1  Claims for the services of internal resource sharing providers;
1.1.2  Claims for services provided to Active Duty Service Members (ADSMs) (except for foreign military member claims, see Section 4); and
1.1.3  Claims for all Supplemental Health Care Program (SHCP) inpatients (TRICARE Operations Manual (TOM), Chapter 17, Section 3).
1.2  The contractor shall maintain double coverage documentation in its files. Double coverage information, including contractual arrangements must be obtained through any means that will provide a documented record or the claim shall be returned with a request for the needed information. See Chapter 4, Section 4. Other Health Insurance (OHI) information includes:
1.2.1  OHI policy and carrier.
1.2.2  Policyholder.
1.2.3  Type of coverage provided by the additional insurance policy.
1.2.4  Employer information offering coverage, if applicable.
1.2.5  Effective period of the policy.
1.3  The contractor systems are the database of record for OHI within the TRICARE Program and all database records are government property. As such, the database records are to be passed on to successor contractors. See the TOM, Chapter 2, Section 6, paragraph 2.0. Any process executed by the contractors to update their OHI database must not interfere with the contractors required claims processing timelines.
1.4  Examples of OHI coverage are:
1.4.1  Comprehensive medical coverage (Plans with multiple coverage types).
1.4.2  Medical coverage.
1.4.3  Inpatient coverage.
1.4.4  Outpatient coverage.
1.4.5  Pharmacy coverage.
1.4.6  Dental coverage.
1.4.7  Long-term care coverage.
1.4.8  Mental health coverage.
1.4.9  Vision coverage.
1.4.10  Partial hospitalization coverage.
1.4.11  Skilled nursing care coverage.
1.5  A person can have multiple types of OHI coverage for one policy. For example, for an OHI policy that covers medical and vision, the contractor shall maintain information on two OHI coverage types, one for medical coverage and one for vision coverage.
1.6  A person can have multiple OHI policies. Multiple OHI policies may have the same or different health insurance carriers, and/or the same or different OHI policy effective periods.
1.7  Contractors responsible for medical claims shall develop the OHI within 15 days but are not responsible for pharmacy coverage development. The contractors responsible for medical claims shall maintain medical OHI and provide it to covered entities as required. See paragraph 1.10.
1.8  The pharmacy contractor(s) shall develop and maintain pharmacy OHI. The pharmacy contractor(s) shall provide OHI to covered entities as required. See paragraph 1.10.
1.9  The dental contractor(s) shall develop and maintain dental OHI. The dental contractor(s) shall provide OHI to covered entities as required. See paragraph 1.10.
1.10  The following requirements apply to the Managed Care Support (MCS) contractor(s), overseas contractor(s), pharmacy contractor(s) and all associated fiduciary intermediaries.
1.10.1  Contractors, as covered entities, shall provide collected OHI records to other contractors as needed for the coordination of benefits. Transmissions must adhere to Health Insurance Portability and Accountability Act (HIPAA) data transaction standards.
1.10.2  If the beneficiary changes their region of enrollment, the losing contractor shall forward OHI records to the gaining contractor when requested (by phone or in writing) by the beneficiary or gaining contractor. The information forwarded shall include all beneficiary OHI data gathered in the losing contractor’s OHI database. See paragraph 1.2.
2.0  PROCESSING OF CLAIMS
With the exceptions noted in paragraph 1.11.0, the contractor shall have proof of any double coverage payments prior to adjudication of the claim.
2.1  No Evidence Of Double Coverage
If there is no information to suggest the claim could be covered by another health insurance plan or there is no information on the claim to suggest that the charges have been submitted to or paid by other insurance, the claim shall be processed.
2.2  Double Coverage Is Known
2.2.1  Whether it is a network or non-network claim, payment must be obtained from the primary insurance coverages or plans.
2.2.1.1  The contractor shall include procedures to ensure this requirement is met in all agreements with its network providers of care. If the provider of care is owned or operated by the contractor or is in a clinic or other facility operated by the contractor as an employee or subcontractor, the Other Health Insurance (OHI) shall also be collected by the contractor or its designee. If the claim indicates no OHI coverage, but the Defense Enrollment Eligibility Reporting System (DEERS) or contractor’s file indicates otherwise, a signed statement or verbal notice from the beneficiary or sponsor furnishing the termination date of the other coverage will be necessary for the contractor to inactivate the positive OHI record.
2.2.1.2  The contractor shall have acceptable evidence of processing by the double coverage plan prior to processing the claim. If there is no such evidence submitted with the claim, the contractor shall deny the claim and send an Explanation of Benefits (EOB) to the beneficiary and to the provider.
2.2.2  The contractor shall take appropriate action to ensure that a sample of all Electronic Media Claims (EMC) is audited on a no less than annual basis with verification obtained from the provider to corroborate the submission of a zero OHI payment amount.
2.2.3  In addition the contractor shall, no less than annually, audit past EMC submissions to identify all providers who may show a pattern of submissions with OHI payment amounts of zero or of a nominal amount (e.g., $.01, $1.00, $5.00). All EMC providers who demonstrate a possible pattern of “plugging” nominal OHI payment amounts shall be referred to the contractor’s Program Integrity staff for further investigation.
2.2.4  Except for EMC claims, when Medicare is the primary payer, an Explanation of Medicare Benefits (EOMB) is required. This will enable the contractor to determine whether the provider accepted assignment under Medicare; if the provider accepts assignment, the provider cannot bill for any difference between the billed charge and the Medicare allowed amount. In addition, it will identify cost-share and deductible amounts as well as any allowable charge reductions.
2.2.5  For double coverage situations which do not involve the routine issuance of an EOB, the following shall be accepted in lieu of an EOB:
•  Documentation that the beneficiary belongs to the plan;
•  Documentation that there is a liability beyond the amounts paid by the primary payor;
•  Documentation that the liability is specified in the plan contract; and
•  Documentation of total liability on the claim.
2.2.6  The contractor shall establish an maintain the OHI record on DEERS coverage type for the patient and request completion of a double coverage questionnaire if a contractor becomes aware of the possible existence of OHI through means other than the adjudication of a pending claim (e.g., a provider returns all or a part of TRICARE payment because of payment by OHI). Depending upon the circumstances of the individual occurrence, reopening and adjustment of prior claims and/or a Program Integrity referral may also be appropriate. All affected claims shall be adjusted appropriately, although adjustment action may be temporarily deferred at the request of Program Integrity staff if such adjustment would compromise their investigation.
2.3  DRG-Based System
The contractor shall be able to identify OHI payments for all separately-billable components of the inpatient services on a claim. If the OHI EOB does not adequately identify the payments for each separately-billable component, or if claims for their charges are not received, the entire OHI payment is to be applied to the inpatient operating costs. This also applies to claims from higher volume mental health hospitals and units subject to the TRICARE Inpatient Mental Health Per Diem Payment System that are authorized to bill for institution-based professional services.
2.4  Medicare Claims
2.4.1  Claims processed on which Medicare is primary payer require review for possible double coverage. The contractor shall be required to build other health insurance files on these beneficiaries that identify coverages (primarily Medicare supplements) that may be primary to TRICARE. Contractors shall use any reasonably reliable indicator to identify other coverages including, but not limited to, crossover claims received from Medicare carriers and fiscal intermediaries, crossover files received from Medicare carriers and fiscal intermediaries, paper claims, information resulting from refunds, and information from providers.
2.4.2  The contractor shall ensure that providers are aware that if they receive any TRICARE payments that duplicate payments made by another coverage, they shall return the TRICARE payment. Since TRICARE remains secondary payer to all other coverages, contractors shall recover all payments that they subsequently identify as duplicating a payment made by any coverage, including Medicare supplements, that is primary to TRICARE.
2.5  Skilled Nursing Facility (SNF) Prospective Payment System (PPS)
Payment under the SNF PPS is dependent upon the PPS-specific information submitted by the provider with the TRICARE Claim (see Chapter 8, Section 1). However, if the beneficiary has OHI which has processed the claim as primary payer, it is likely that the information necessary to determine the TRICARE PPS payment amount will not be available. Therefore, special procedures have been established for processing SNF claims involving OHI. These claims will not be processed as PPS claims. Such claims will be allowed as billed unless there is a provider discount agreement. TRICARE payment will be the difference between the billed charge and the OHI payment. The only exception to this is cases when there is evidence on the face of the claim that the beneficiary’s liability is limited to less than the billed charge (e.g., the OHI has a discount agreement with the provider under which the provider agrees to accept a percentage of the billed charge as payment in full). In such cases, the TRICARE payment is to be the difference between the limited amount established by the OHI and the OHI payment.
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