UB04 Condition Codes Code D8: Change from Medicare Secondary to Primary

Overview

This change typically occurs when the insurance that previously paid primary (e.g., employer group health plan, liability insurance) is no longer in effect or is no longer primary, and Medicare assumes primary payment responsibility. Accurate use of D8 ensures that Medicare processes the claim correctly as primary payer and that provider reimbursement is not delayed or denied due to payer order errors.

When to Use

Use Code D8 when the patient’s payer hierarchy changes so that Medicare becomes the primary payer. It is often accompanied by other condition codes that explain why Medicare was secondary previously (e.g., Code 28 for EGHP secondary or Code 29 for LGHP secondary). The claim must also reflect the correct payer sequence on the electronic or paper UB‑04.

Step-by-Step Claim Example

Scenario: A 68‑year‑old patient with Medicare Part A and Part B was covered by an employer group health plan (EGHP) through a spouse’s active employment. The spouse retires, and EGHP coverage ends. The provider is submitting an inpatient hospital claim for services rendered after the EGHP termination date.

Steps for completing fields 18‑28 on the UB‑04:

4. Complete other required fields such as patient demographics, dates of service, revenue codes, charges, and ICD‑10‑CM diagnosis codes.

After submission, Medicare should process the claim as primary payer. The provider should retain documentation confirming that the EGHP ended (e.g., termination letter) for audit purposes ^[1] (general instructions on claim completion).

Common Mistakes & Audit Red Flags

• Using D8 when coverage change has not occurred – submitting D8 without a verifiable change in payer status can trigger recoupment and audit penalties.
• Missing supporting condition codes – failing to include prior secondary status codes (e.g., 28, 29) may confuse Medicare about why the change happened and cause delays.
• Incorrect date placement – the claim to‑and‑from dates on the UB‑04 must fall after the effective date of the primary change; otherwise, Medicare may reject the claim.
• Leaving contradictory codes – simultaneously using D8 and a code indicating Medicare is secondary (e.g., Code 06 for ESRD employer coverage) creates a conflict and likely results in denial.
• Not updating the MSP questionnaire – providers must ensure the patient’s MSP information is current in Medicare’s system; a D8 on the claim will not override an outdated MSP record.

To avoid red flags, always verify the change event (e.g., employer coverage termination date) and use D8 only when the primary/secondary shift is documented ^{[2] [1]}.

Related Codes/Fields

The table below lists related condition codes that often appear with D8 on UB‑04 claims and the fields where condition codes are reported.

Code	Meaning	Related Use
D8	Change from Medicare Secondary to Primary	Primary code for payer status change
06	ESRD patient in first 30 months covered by EGHP	Medicare secondary during initial ESRD period
28	Patient/spouse EGHP is secondary to Medicare	Previously secondary due to employer coverage
29	Disabled beneficiary/family LGHP is secondary to Medicare	Previously secondary due to LGHP coverage
09	Neither patient nor spouse is employed	Often used when EGHP no longer exists
10	Patient/spouse employed but no EGHP coverage	Supports primary change when employer coverage ends
Field	Location on UB‑04	Description
18–28	Condition Codes (6‑digit positions)	Enter D8 and other applicable condition codes
31–34	Occurrence Codes & Dates	Show dates of insurance termination or coverage change
50	Payer Identification	List Medicare as Payer A (primary) after the change

All codes and field definitions are from ^[2] and ^[1].

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References

[1] MassHealth UB‑04 Guide — https://www.mass.gov/doc/ub-04-billing-guide-0/download

[2] Noridian Condition Codes — https://med.noridianmedicare.com/web/jea/topics/claim-submission/condition-codes