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November 10, 2020

Top Claim Submission Errors: Duplicate Claims and Requests for Anticipated Payment (RAPs)

Did you know how often duplicate claims are received by CGS and rejected? The submission of home health and hospice (HHH) duplicate claims and home health agency (HHA) duplicate RAPs are consistently top reject reasons for CGS. Data shows that from April-September 2020, there were a total of 55,346 duplicate claims and RAPs. During this period, 8,520 claims rejected with reason code 38200 and 46,826 RAPs rejected with reason code 38157. During this same period for 2019, there were a total of 23,097 duplicate claims/RAPs (10,848 claims and 12,249 RAPs). That's a 140% increase!

It is important for providers to be aware that duplicate billing errors impact the Medicare program negatively by increasing the cost to process Medicare claims. Providers are also negatively impacted by the consequences of duplicate billing such as:

  • Payment delays,
  • Identification as an abusive biller, or
  • The initiation of a fraud investigation if a pattern of duplicate billing is identified.

Reason Code 38200 – Claims will reject when the submitted claim is an exact duplicate of a previously submitted claim where the following fields are the same:

  • Medicare Beneficiary Identifier (MBI)
  • Type of Bill
  • Provider Number
  • Statement From and Through dates
  • Total Charges
  • Revenue Code
  • HCPCS and modifiers (if required)


Reason Code 38157 – Home health RAPs will reject when the submitted RAP is a duplicate of a paid RAP, or a suspended or denied home health claim with the same provider number, MBI and statement From date, but without a cancel date.  The RAP may also reject when the RAP and final claim are submitted at the same time. Always wait to submit the final claim until the RAP has finalized and is in status/location P B9997.  


Tips to Avoid Duplicate Billing

  • When using batch file transfer software, have an internal procedure in place to ensure batches of billing transactions are deleted from the software once they are submitted to Medicare.
  • Review Medicare Remittance Advice timely.
  • Stay current in posting payments received from Medicare.
  • Access the FISS Claim Inquiry Option (Option 12) to determine which claims have been submitted to Medicare. For instructions on using FISS Inquiry Option 12, see Chapter 3 - Inquiry MenuPDF of the Fiscal Intermediary Standard System (FISS) Guide.
  • Do not resubmit an identical billing transaction if you have already corrected the claim from the Return to Provider (RTP) file.
    • We encourage you to suppress the view of claims in your RTP file that you do not intend to correct. See Chapter 5 - Claims CorrectionPDFof the Fiscal Intermediary Standard System (FISS) Guide for instructions on suppressing the view of claims in RTP.
  • When appropriate, adjust rejected (R B9997) or paid (P B9997) claims instead of resubmitting them.

Please share this information with your billing staff or clearinghouse to help avoid duplicate submissions of home health and hospice claims and home health RAPs.


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