CommonContractual Obligation (CO)Bundling & Unbundling

CO-97: Benefit included in payment for another adjudicated service

CO-97 means the payer considers the benefit for this service included in the payment or allowance for another service or procedure that has already been adjudicated. It is a bundling adjustment, not an exact-duplicate denial.

Common Causes

  • A component service was billed separately from a more comprehensive procedure
  • An NCCI procedure-to-procedure edit applies to the code pair
  • The service is included in a global surgical or other bundled payment
  • The payer applied a plan-specific bundling or multiple-procedure rule
  • Distinct services were documented but an appropriate supported modifier was omitted or reported incorrectly

How to Diagnose CO-97 Before You Resubmit

CO-97 is different from CO-18. CO-18 identifies an exact duplicate claim or service. CO-97 says the benefit for one service is included in payment for another service. Treating CO-97 as a duplicate can cause staff to miss valid bundling corrections or submit an unnecessary replacement claim.

  1. 1Which other service or procedure did the payer adjudicate on this claim or encounter?
  2. 2Does an NCCI procedure-to-procedure edit, global package, multiple-procedure rule, or payer policy explain the adjustment?
  3. 3Was the denied line a component of the more comprehensive service?
  4. 4Were the services distinct by encounter, anatomical site, session, lesion, or practitioner?
  5. 5Does the documentation clearly support that distinction?
  6. 6Does the applicable edit permit a modifier, and which modifier does the payer require?
  7. 7Did the payer calculate the allowance correctly under the contract?

How to Resolve CO-97

  1. 1Identify the other adjudicated service or procedure into which the payer bundled this line
  2. 2Review the remittance codes, payer policy, contract, and applicable NCCI edit
  3. 3Confirm whether the services were truly separate based on the medical record, date, site, encounter, and practitioner
  4. 4If the bundling is correct, post the contractual adjustment according to practice policy
  5. 5If the services are distinct and the edit permits a modifier, submit a supported corrected claim or appeal under payer instructions
  6. 6If the payer applied the bundling rule incorrectly, appeal with the code-pair policy and documentation

Worked example

What CO-97 Looks Like in a Real Work Queue

Scenario
A claim contains a comprehensive procedure and a component service on the same date. The payer pays the comprehensive code and adjusts the component line with CO-97.
Interpretation
The payer is saying the component's value is already included in the allowance for the comprehensive service. This is not evidence that the same claim was submitted twice.
Next step
Check the current NCCI and payer edit for the code pair. If the component was integral, post the contractual adjustment. If it was a genuinely distinct service and the edit permits separate reporting, confirm that the record supports the correct modifier before submitting a corrected claim or appeal.

How to Prevent CO-97 Denials

  • Check current NCCI and payer-specific bundling edits before claim submission
  • Document separate encounters, sites, sessions, lesions, or practitioners clearly when relevant
  • Use modifier 59 or an X{EPSU} modifier only when the record supports a distinct service and the edit permits it
  • Audit recurring CO-97 adjustments by code pair and payer instead of treating every line as a duplicate

CO-97 Frequently Asked Questions

Is CO-97 a duplicate denial?

No. CO-18 is the common exact-duplicate code. CO-97 indicates that payment for the service is included in the allowance for another adjudicated service or procedure.

Should staff automatically add modifier 59 to fix CO-97?

No. A modifier should be used only when the services were distinct, the documentation supports that distinction, and the applicable edit and payer policy permit separate reporting. Adding a modifier solely to bypass an edit creates compliance risk.

Can a practice bill the patient for CO-97?

Do not transfer the balance based only on CO-97. Review the contractual-obligation group code, payer contract, remittance, patient notices, and applicable law. A correctly bundled contractual adjustment is generally not a new patient charge.

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