Denial codes · Denial code
CO-97 on a nutrition claim: the service was bundled into another one
By Javier Alvarez · Updated · 5 min read
| Official description | The benefit for this service is included in the payment/allowance for another service/procedure that has already been adjudicated. |
|---|---|
| Group code | CO: do not bill the patient |
| Common remark codes | M15, M80, N19, N20 |
| Where the policy is named | 835 loop 2110 REF (Healthcare Policy Identification), if the payer sends it |
| Medicare MNT rule | DSMT and MNT may not be provided on the same day to the same beneficiary |
| Fix route | Corrected claim if miscoded; appeal with records if truly separate |
CO-97 is the payer saying "we already paid for this." Not that the visit wasn't covered, not that something was missing: the payer believes the service on this line is part of another service it already processed, so it pays that one and zeroes this one. On nutrition claims, it almost always traces back to two services on the same date for the same patient.
What CO-97 means (official X12 wording)
The X12 Claim Adjustment Reason Code list defines CARC 97 as:
"The benefit for this service is included in the payment/allowance for another service/procedure that has already been adjudicated."
The usage note points you to "the 835 Healthcare Policy Identification Segment (loop 2110 Service Payment Information REF), if present." If your clearinghouse shows it, that reference names the payer policy that did the bundling, which is exactly what you need if you plan to dispute it.
Remark codes you may see with CO-97
| Remark code | Official X12 description | What it tells you |
|---|---|---|
| M15 | "Separately billed services/tests have been bundled as they are considered components of the same procedure. Separate payment is not allowed." | The payer sees your two lines as one service |
| M80 | "Not covered when performed during the same session/date as a previously processed service for the patient." | A same-date conflict with a claim that was processed first |
| N19 | "Procedure code incidental to primary procedure." | Your line is considered minor next to another code |
| N20 | "Service not payable with other service rendered on the same date." | A same-day pair the payer never pays together |
M80 has a practical twist: "previously processed" means the other claim may not be yours. If a hospital program, a physician in your group or another RD billed the patient on the same date and got processed first, your line is the one that gets bundled.
The usual causes on nutrition claims
1. MNT and DSMT on the same day (Medicare)
Medicare lets a beneficiary with diabetes use both benefits in the same year, but CMS is explicit: "DSMT and MNT may not be provided on the same day to the same beneficiary" (Pub. 100-04, Ch. 4 §300.1). Section 300.6 adds a duplicate edit that catches DSMT and MNT billed with the same date "from institutional providers and from a professional provider." So if the patient attended a hospital DSMT class in the morning and saw you for 97803 in the afternoon, one of the two will be denied. The CARC used for this edit varies; CO-97 and a duplicate code are both possible. More on DSMT billing in G0108 and G0109.
2. 97802 and 97803 on the same encounter
97802 is for the initial assessment and 97803 for reassessments and follow-ups. Splitting a long first visit into "some 97802 units and some 97803 units" looks like a bundling pair to most payer edit systems. Bill the whole first visit as 97802.
3. Group and individual MNT on the same date
Billing 97804 (group) and 97803 (individual) for the same patient on the same date can trigger a same-day edit with some payers, especially if the times overlap. If both really happened, the note has to show two separate sessions with separate start and stop times.
4. S9470 with 97802 or 97803
Some programs that pay the HCPCS nutrition code S9470 deny it when an MNT CPT code is billed on the same date; Texas's CSHCN program is one published example. See S9470.
5. Same-day visits within a group practice
If a physician or NP in your group sees the patient and you provide MNT on the same date, some payers treat the RD service as part of the provider's visit, particularly when both are billed under the same group NPI. Payer policies differ a lot here; read the specific policy named in the remit.
How to fix a CO-97
- Find the other service. Check your own claims for the same patient and date first. If nothing matches, call the payer and ask which claim the line was bundled into and which policy applied.
- Decide whether the claim was wrong or the edit was wrong.
- Coding error (97802 and 97803 on one visit, the wrong date on one of the lines): send a corrected claim, frequency code 7 in Item 22 with the payer's original claim number, showing the right code or date. Only correct a date if the record supports it.
- The services were separate and the payer's own policy allows both: appeal or request a reconsideration with both notes, showing separate times and purposes, and quote the policy.
- The pair is simply not payable together (MNT and DSMT for Medicare): there is no fix for this date. Change the schedule going forward.
- Be careful with modifier 59 and the X modifiers. They exist to show a distinct service, not to override an edit. Use them only when the note documents a truly separate service and the payer accepts them for these codes. See the NCCI edits page for how Medicare frames procedure-to-procedure edits.
- Do not bill the patient. The CO group code keeps it on your side.
For the appeal letter itself, use the template in How to appeal a denied nutrition claim.
How to prevent CO-97
- Ask about same-day services at scheduling. For Medicare patients with diabetes, ask whether they are in a DSMT program and when the classes are.
- Bill one MNT code per encounter. Initial visit: 97802 for all of it. Follow-up: 97803.
- Schedule group and individual sessions on different days when you can, or document them as clearly separate.
- Know your group's same-day rules with each payer before you co-schedule RD visits with provider visits.
- Keep a list of the bundling policies your payers cite on remits. They repeat.
CO-97 is often confused with a duplicate denial. If the payer thinks you sent the same line twice, the code is usually OA-18 instead. For every other code, see the denial code lookup.