MedicaidAdministrativeHigh impact
All Provider Bulletin 402: Third-Party Liability Billing Requirements for Health Reimbursement Arrangements and Similar Instruments
MassHealth·MA·Claims & Billing
Effective date
Apr 1, 2025
We identified it
Jun 18, 2026
Summary
MassHealth requires providers to bill Health Reimbursement Arrangements (HRAs) and similar employer-funded instruments before billing MassHealth as secondary payer. Providers must immediately resubmit adjusted claims to MassHealth when they receive updated EOBs showing HRA payments, and must return duplicate payments to MassHealth when both sources pay the same claim.
Action Required
Immediately: Billing team must verify all MassHealth patients have been asked about employer-funded HRAs or similar instruments during eligibility verification. Update billing workflow to wait for final EOBs before submitting secondary claims to MassHealth. Establish process to monitor for adjusted EOBs and resubmit corrected claims to MassHealth within 24 hours of receipt. Create procedure to identify and return duplicate payments to MassHealth when both HRA and MassHealth pay the same claim. Failure to follow these requirements may result in recoupment under provider liability regulations.