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CARC 97 Bundling: what it means, and how to appeal it.
CARC 97 is the classic bundling denial. The payer is saying: this service is already paid for as part of another line. Sometimes that is correct and the claim should be adjusted. Sometimes it is wrong because the services were genuinely distinct, and the fix is a modifier plus documentation. Working every CARC 97 the same way is how practices write off dollars they could recover.
Last verified July 9, 2026 against the current ASC X12 CARC master list and the CMS NCCI PTP edit tables. Source: ASC X12, CMS NCCI
From the EDI Code Intelligence Lab
Common drivers: NCCI bundling edit includes the denied code inside the primary procedure's payment; missing modifier 59 or X modifier for a genuinely separate service; or an add-on code submitted without its required primary code.
- NCCI bundling edit includes the denied code inside the primary procedure's payment; missing modifier 59 or X modifier for a genuinely separate service; or an add-on code submitted without its required primary code.
- Look up the denied code pair in the NCCI (National Correct Coding Initiative) edit table.
- Check the modifier indicator: a '0' means the codes can never be billed together - post the adjustment.
- A '1' means modifier 59 (or X modifiers XS, XE, XP, XU) can separate them - only if documentation supports a distinct site, session, or procedure.
- If a valid modifier applies, resubmit.
- Verify the NCCI modifier indicator: '0' means unbundling is never allowed; '1' means a modifier works if the service was separate.
- If the indicator is '1' and modifier was omitted, file a corrected claim over a narrative appeal.
- If a modifier was appended and still denied, appeal with documentation of the distinct site, session, or location.
- For payer-specific edits more restrictive than NCCI, request the rationale.
- Load the current-quarter CMS NCCI edit table into your claim scrubber and update it quarterly when CMS publishes a new release.
- Train coders to apply modifier 59 or X modifiers only when the record genuinely documents a distinct service; reflexive use to bypass edits creates compliance risk.
- Run a monthly report of CARC 97 denials by code pair; for recurring distinct-service pairs, create a modifier-use protocol.
CARC 97 is a bundling determination. The RARC narrows what needs to be different.
The payer already paid something on a related line and considers this service part of that payment. The RARC on your remittance is what tells you whether you need a modifier (usually 59 or an X-modifier), a corrected claim, or an appeal against the NCCI edit itself.
Common RARC pairings with CARC 97
These pairings and definitions can also be found in the EDI Code Intelligence Lab. ASC X12 Definitions are sourced from x12.org/codes/remittance-advice-remark-codes. Business Scenarios are sourced from CAQH CORE required code combinations (v3100, February 2026).
| RARC | Official definition (ASC X12) | Business scenario (CAQH CORE) |
|---|---|---|
| M2 | Not paid separately when the patient is an inpatient. | Benefit for Billed Service Not Separately Payable |
| M15 | Separately billed services/tests have been bundled as they are considered components of the same procedure. Separate payment is not allowed. | Benefit for Billed Service Not Separately Payable |
| M80 | Not covered when performed during the same session/date as a previously processed service for the patient. | Benefit for Billed Service Not Separately Payable |
| M86 | Service denied because payment already made for same/similar procedure within set time frame. | Benefit for Billed Service Not Separately Payable |
| M97 | Not paid to practitioner when provided to patient in this place of service. Payment included in the reimbursement issued the facility. | Benefit for Billed Service Not Separately Payable |
| M109 | We have provided you with a bundled payment for a teleconsultation. You must send 25 percent of the teleconsultation payment to the referring practitioner. | Benefit for Billed Service Not Separately Payable |
| M112 | Reimbursement for this item is based on the single payment amount required under the DMEPOS Competitive Bidding Program for the area where the patient resides. | Benefit for Billed Service Not Separately Payable |
| M144 | Pre-/post-operative care payment is included in the allowance for the surgery/procedure. | Benefit for Billed Service Not Separately Payable |
| MA109 | Claim processed in accordance with ambulatory surgical guidelines. | Benefit for Billed Service Not Separately Payable |
| N19 | Procedure code incidental to primary procedure. | Benefit for Billed Service Not Separately Payable |
| N20 | Service not payable with other service rendered on the same date. | Benefit for Billed Service Not Separately Payable |
| N67 | Professional provider services not paid separately. Included in facility payment under a demonstration project. Apply to that facility for payment, or resubmit your claim if: the facility notifies you the patient was excluded from this demonstration; or if you furnished these services in another location on the date of the patient's admission or discharge from a demonstration hospital. If services were furnished in a facility not involved in the demonstration on the same date the patient was discharged from or admitted to a demonstration facility, you must report the provider ID number for the non-demonstration facility on the new claim. | Benefit for Billed Service Not Separately Payable |
This is one page. The Lab has every CARC and RARC in use today.
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This page helps you understand denial codes and build a starting point for resolution. Every denial has context that only the payer and the claim can provide. Before submitting an appeal or corrected claim, verify the payer's published policies and contact them directly with questions about your specific situation.