Quick Explanation
Denial code CO-71 indicates that the payer has determined the payment already made covers the entirety of the inpatient stay under a bundled payment arrangement, such as a Diagnosis-Related Group (DRG) or global rate. Consequently, no additional reimbursement is allowed for separate services, procedures, or professional fees billed during that specific hospitalization period.
Common Causes for CO-71
Denials with code CO-71 typically happen for the following specific reasons:
- Billing professional services or ancillary charges that are contractually bundled into the facility's global DRG/IPPS payment.
- Submitting split bills or separate line items for services that should be consolidated under a single inpatient claim.
- Attempting to collect additional payment from a secondary payer when the primary payer's contracted DRG rate represents payment in full.
- Misalignment in patient status tracking, such as billing an outpatient service that actually occurred during an active inpatient stay.
How to Prevent CO-71 Denials
To avoid receiving this denial in the future, implement these specific checks:
- Establish robust pre-billing edits to identify and consolidate services rendered during an active inpatient stay before submission.
- Verify payer-specific contracts to understand which professional fees, laboratory tests, or imaging services are bundled into the global DRG rate.
- Implement clear communication protocols between facility billing (Part A) and professional billing (Part B) departments to prevent overlapping claims.
- Train billing staff on CMS three-day payment window rules and inpatient transfer policies to ensure compliant billing of pre-admission services.
Appeal Letter Template for CO-71
If you believe this claim was denied incorrectly, you can use the following template to submit an appeal.
[Your Practice Header]
[Date]
[Payer Name]
[Appeals Department Address]
RE: Appeal for Claim [Claim Number]
Patient: [Patient Name]
ID: [Patient ID]
Date of Service: [Date]
Denial Code: CO-71 - Payment constitutes the full services for this hospitalization
Dear Appeals Department,
I am writing to appeal the denial of the above-referenced claim, which was denied with code CO-71: "Payment constitutes the full services for this hospitalization".
We are appealing the denial of this claim under code CO-71. Pursuant to CMS Inpatient Prospective Payment System (IPPS) guidelines and AMA coding rules, the professional services billed under CPT [Insert CPT Code] represent independent professional cognitive or surgical services that are separately billable and reimbursable under Medicare Part B or the commercial professional fee schedule. These services are distinct from the technical, facility-based services covered under the hospital's DRG payment. As the rendering provider is an independent practitioner whose professional fees are not contractually bundled into the facility's global rate, we respectfully request that you review the attached medical documentation and process this claim for separate payment.
Attached please find:
1. A copy of the original claim.
2. The relevant medical records supporting the service.
3. [Any other supporting documents].
We respectfully request that you reprocess this claim for payment.
Sincerely,
[Your Name]
[Title]
[Practice Name]
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