CO-190 denial code
Payment is included in the allowance for a Skilled Nursing Facility qualified stay
How to fix it
Confirm the patient's SNF status on the date of service. Where bundled, bill the facility rather than the payer.
How to prevent it
Check SNF status at registration; consolidated billing catches practices repeatedly.
The CO prefix marks this a contractual obligation. The balance is absorbed by the provider under the payer agreement and cannot be transferred to the patient.
In practice
A therapy practice provides services to a nursing home resident and bills the plan directly. The resident is in a covered Part A stay, and the claim returns CO-190 under consolidated billing.
During a covered skilled nursing stay, most services are included in the facility's payment. The facility receives a bundled rate and is responsible for paying the providers who deliver care within it.
The claim goes to the facility rather than the plan. Where an arrangement with the facility does not already exist, that is the conversation to have, ideally before further services are delivered.
What sits behind it
Consolidated billing catches practices repeatedly because the patient's status is invisible from the encounter. A therapist seeing a patient at a nursing home has no way to know from the visit itself whether the stay is a covered Part A stay or a custodial one billed differently.
The exclusions are narrow but real. Certain physician professional services and a defined list of high-cost items fall outside consolidated billing and remain separately billable, and knowing which applies to your service category is worth establishing once.
The practical control is asking. Confirming Part A status with the facility before delivering services, and having a written arrangement covering payment, converts an unrecoverable denial into an ordinary receivable.
Related codes
Terms used here — NCCI Edits · Denial · Revenue Cycle Management
How we handle it — Claims Management · Denial Management · Revenue Cycle Management
Primary sources
The rules behind CO-190, at the bodies that publish them.
- NCCI Policy Manual for Medicare Services (opens in a new tab)
Centers for Medicare & Medicaid Services — The reasoning behind the edits, chapter by chapter. Where the edit files tell you two codes conflict, this explains why — which is what an appeal has to address.
- National Correct Coding Initiative (NCCI) edits (opens in a new tab)
Centers for Medicare & Medicaid Services — The procedure-to-procedure and medically-unlikely edits behind most bundling denials. Checking these before submission prevents the denial entirely.
- Medicare Claims Processing Manual (opens in a new tab)
Centers for Medicare & Medicaid Services — The operative manual for how Medicare claims must be coded, submitted, adjusted and appealed. When a payer policy and a vendor's advice disagree, this settles it.
Looking for a different code? Search all 190 CARC and RARC codes
Questions about CO-190
The facility, which receives a bundled payment covering most services delivered during the covered stay and is responsible for paying the providers who furnish them. The plan will not pay the rendering provider separately, so the claim has to go to the facility.
Yes, though the list is narrow. Certain physician professional services and a defined set of high-cost items remain separately billable. Establishing once whether your service category falls inside or outside the bundle prevents repeated denials.
Ask the facility before delivering services, because the encounter itself gives no indication. A patient in a covered Part A stay and one in custodial care look identical to a visiting provider, and the billing consequences are entirely different.
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