UB04 Field 38: Responsible Party Name and Address

Overview

Field 38 (Box 38) on the UB-04 claim form is designated for the Responsible Party Name and Address. This field captures the name and mailing address of the individual or entity that is financially responsible for the patient’s charges. According to the Maryland Medicaid UB-04 Hospital Billing Instructions, FL 38 is listed among the standard form fields for both inpatient and outpatient claims ^[1]. However, the Centers for Medicare & Medicaid Services (CMS) explicitly states in Chapter 25 of the Medicare Claims Processing Manual that “Data entered will be ignored” for FL 38 and that the field is “Not Required” ^[2]. This directive is reinforced by CMS Transmittal R1915CP, which also confirms that FL 38 is “Not Required” ^[3]. Therefore, while the field exists on the form, its use is effectively optional for Medicare claims, and any data submitted will be disregarded by Medicare processing systems. Providers should be aware that other payers (e.g., state Medicaid programs, commercial insurers) may have their own requirements for this field, but the CMS guidance takes precedence for Medicare billing.

When to Use

For Medicare claims, CMS explicitly states that FL 38 is “Not Required” and that any data entered “will be ignored” ^[2]. This means that for Medicare Part A and Part B hospital claims, providers do not need to populate this field, and doing so will have no impact on claim processing. For non-Medicare payers, the requirement may vary. The Maryland Medicaid UB-04 instructions list FL 38 as a standard field for both inpatient and outpatient services ^[1]. This suggests that state Medicaid programs may expect the responsible party name and address when the patient is a minor, an incapacitated adult, or when a third party (e.g., a guardian or estate) is liable for payment. Providers should consult the specific billing guidelines of the primary payer before completing this field. In general, if the patient is the insured and is competent, the responsible party is the patient themselves, and the information may be captured elsewhere (e.g., in the patient demographic record). When in doubt, leaving FL 38 blank is acceptable for Medicare and many other payers, but state-specific rules should be verified.

Step-by-Step Claim Example

Consider a scenario where a hospital submits a UB-04 claim for a Medicare beneficiary who is a minor child. The child’s parent is the responsible party. According to CMS guidance, FL 38 is not required for Medicare claims, and any data entered will be ignored ^[2]. Therefore, the provider may choose to leave the field blank. However, if the same patient has a primary payer that is a commercial insurer requiring responsible party information, the provider would need to populate FL 38. For example, if the primary payer is a state Medicaid program that follows the Maryland Medicaid instructions, FL 38 is listed as a standard field in the Maryland Medicaid instructions ^[1]. In that case, the provider would enter the parent’s full name (e.g., “John Doe”) on the first line and the address (e.g., “123 Main St, Anytown, MD 12345”) on the subsequent lines. The field should be formatted as a standard name and address block, with no special punctuation. After completing the claim, the provider would submit it to the primary payer. If the primary payer denies or pays partially, and a secondary claim is sent to Medicare, the Medicare system will ignore the data in FL 38, as per CMS policy ^[3]. This example illustrates that the use of FL 38 is payer-dependent and that providers must follow the instructions of the specific payer being billed.

Common Mistakes & Audit Red Flags

One common mistake is entering responsible party data on Medicare claims, which is unnecessary because CMS will ignore the information ^[2]. While this does not cause a claim rejection, it can create confusion during audits if the data conflicts with other fields (e.g., FL 58 Insured’s Name). Another mistake is leaving FL 38 blank when a state Medicaid program or commercial payer requires it. For example, Maryland Medicaid lists FL 38 as a standard field, and failure to populate it when applicable could result in a claim edit or denial ^[1]. Providers should also avoid using FL 38 to report the patient’s own name and address if the patient is the responsible party; that information is typically captured in the patient demographic section (FL 12–13). Audit red flags include inconsistent data between FL 38 and other fields (e.g., FL 58 Insured’s Name) or using FL 38 for a purpose other than responsible party identification, such as listing a guarantor who is not legally liable. Since CMS explicitly states that data in FL 38 will be ignored, auditors may question why a provider is submitting information that has no processing value, potentially indicating a lack of understanding of billing requirements. To avoid these issues, providers should follow payer-specific instructions and, for Medicare, simply leave the field blank.

Related Codes/Fields

The following table lists related fields on the UB-04 that interact with or are adjacent to Field 38. All references are drawn from the provided sources.

Field Number	Field Name	Relationship to FL 38	Source
FL 39–41	Value Codes and Amounts	Required for Medicare; used to identify monetary data that may relate to responsible party liability	[2]
FL 58	Insured’s Name	Identifies the person whose insurance covers the claim; distinct from responsible party	[1]
FL 59	Patient Relationship to Insured	Indicates how the patient is related to the insured; may help determine responsible party	[1]
FL 60	Insured’s Unique ID	Unique identifier for the insured; used in coordination with FL 38 for payer identification	[1]
FL 61	Insured’s Group Name	Group name of the insured’s health plan; may be relevant when responsible party is the group	[1]
FL 62	Insured’s Group Number	Group number associated with the insured’s plan; used for billing coordination	[1]
FL 63	Treatment Authorization Code	Authorization code for services; may be required when responsible party is a third-party payer	[1]

These fields collectively support the identification of the party responsible for payment and the coordination of benefits. Providers should ensure consistency between FL 38 and related fields to avoid billing errors.

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References

[1] Maryland Medicaid — FL 38 — https://health.maryland.gov/mmcp/provider/Documents/ffs-billing/UB04-Hospital-Billing-Instructions%20%281%29.pdf

[2] CMS Chapter 25 — FL 38 — https://www.cms.gov/regulations-and-guidance/guidance/manuals/downloads/clm104c25.pdf

[3] CMS R1915CP — https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/downloads/R1915CP.pdf