Philadelphia's CBH Now Reverses Claims for Other Insurance and Won't Repay Them

Community Behavioral Health, Philadelphia's Medicaid behavioral health plan, changed how it recovers payments when a member turns out to have other insurance. Provider Bulletin 26-21, dated October 15, 2026 and "effective immediately," says CBH "will reverse identified claims associated with third-party liability (TPL) recovery and will no longer reprocess the claims." It replaces Bulletin 25-12 from March 2025.

What stopped

Under 25-12, a reversed claim was reprocessed straight away. If the member's other coverage was "inactive at the time of adjudication, the claims will be paid when reprocessed." So a claim flagged on out-of-date TPL data got paid again without anyone at the practice touching it. That step is gone. A reversed claim now stays reversed until you act, whether or not the other coverage is still in force.

Two other things from 25-12 aren't in the new bulletin. It no longer says recovered claims can be identified "on the 835 payment remittance." The list of recovered claims now comes with the post-payment recovery letter "via Box." It also drops the denial code 479 ("Carrier Identification Missing") language. If your billing team found recoveries by reading the 835, the Box file is where they'll be now.

What you have to do, and by when

• Resubmit: after coordinating benefits with the primary insurer, resubmit "with the Explanation of Benefits (EOB) or final determination documentation within 90 days of the post-payment recovery letter date." The 90 days aren't new. Before, though, reprocessing settled many claims without you. Now every claim goes through this route.
• Dispute: if you can document that the member has no other coverage, you can file the TPL discrepancy process with the claims. That now runs "via the appeal module in the converter application."
• Who else collects: "Any recoveries CBH is unable to complete will be pursued by the DHS."

Why IBHS providers should look first

The bulletin applies to every CBH provider and doesn't mention IBHS or ABA. For IBHS, the exposure is any child CBH's records show with other coverage. When a family drops or changes an employer plan and that never reaches CBH's eligibility file, you're the one who has to prove it. Under the old process, reprocessing settled it.

The limits

The bulletin doesn't say how far back CBH looks when it finds TPL, how often recovery letters go out, or whether claims recovered before October 15 come under the old rules or the new ones. It covers CBH only. The other Pennsylvania BH-MCOs run their own TPL processes.

What you must know or do

• Billing leads: find out who at your practice receives CBH's Box links. Put each recovery letter's date plus 90 days on a calendar the day it arrives.
• Billing leads: for every reversed claim, check the member's other coverage on the date of service before resubmitting. Where it had ended, gather the termination proof and use the discrepancy route rather than billing a plan that will deny you.
• Intake staff: at each reauthorization, ask families whether their other insurance has changed, and record the answer with the date. That record is your evidence if CBH's file is wrong.
• Questions: CBH's TPL manager is listed on the bulletin, Jennifer.Soto@phila.gov.