UB04 Field 80: Remarks

Field 80 (Remarks) on the UB-04 claim form is a situational data element used to convey additional information not captured elsewhere on the claim. ^[1] explicitly states that FL 80 is “Situational,” meaning it is not required on every claim but must be completed when specified by the payer or program. ^[2] includes FL 80 in its UB-04 hospital billing instructions, confirming its place on the form. ^[2] lists FL 80 under the “Remarks” heading on page 49 of its instructions. Because the field is free‑text, providers must ensure that any remarks entered are clear, concise, and directly relevant to the claim’s adjudication.

When to Use

Field 80 should be used only when a specific payer or program mandates additional narrative information that cannot be placed in other designated fields. ^[3] provides a clear example: for Durable Medical Equipment (DME) billings, the provider must show the rental rate, cost, and anticipated months of usage in FL 80 so that the Medicare Administrative Contractor (A/B MAC or HHH) can determine whether to approve rental or purchase of the equipment. This is a mandatory use case for DME claims submitted to Medicare. ^[3] also notes that when Medicare is not the primary payer because of workers’ compensation, automobile medical, no‑fault, liability insurance, or an employer group health plan (EGHP), remarks may be needed to clarify the primary payer situation. ^[1] reinforces the situational nature of the field, meaning providers should not routinely populate FL 80 unless instructed by the payer. ^[2] does not specify exact state requirements for remarks, but its inclusion suggests that providers should consult their state’s billing manual for guidance.

Step-by-Step Claim Example

Consider a DME supplier billing Medicare for a rented oxygen concentrator. The claim is submitted on a UB-04 form. According to ^[3], the provider must enter the rental rate, cost, and anticipated months of usage in Field 80. The steps are:

1. Complete all other required fields on the UB-04 (e.g., patient information, revenue codes, HCPCS codes, dates of service).
2. In Field 80, type the following remark: “Rental rate $150/month, cost $900, anticipated 6 months usage.” This information allows the Medicare Administrative Contractor to evaluate whether rental or purchase is more appropriate.
3. If Medicare is not the primary payer (e.g., due to workers’ compensation), the provider may also include a remark such as “WC primary – Medicare secondary” to alert the payer. ^[3] mentions that when Medicare is not primary because of WC, automobile medical, no‑fault, liability, or EGHP, remarks may be needed.
4. Submit the claim. The payer will use the remarks in FL 80 to make coverage and payment decisions. ^[1] confirms that FL 80 is situational, so this step is only performed when required.

Common Mistakes & Audit Red Flags

Because Field 80 is situational, common mistakes often involve either omitting required remarks or including unnecessary information. ^[3] specifically requires DME suppliers to include rental rate, cost, and anticipated months of usage; failure to do so may result in the Medicare Administrative Contractor being unable to determine rental versus purchase, potentially leading to claim denial or incorrect payment. Another red flag is using FL 80 to duplicate information already present in other fields (e.g., repeating the diagnosis code or procedure code), which can confuse adjudicators and may be considered an audit risk. ^[1] emphasizes that the field is situational, so populating it on every claim without a valid reason could be flagged as unnecessary data. Additionally, entering ambiguous or incomplete remarks—such as “see attached” without actually attaching documentation—can lead to processing delays. Providers should also be aware that state Medicaid programs, like Maryland Medicaid, may have specific remark requirements; failing to comply with state instructions could result in claim rejection. ^[2] lists FL 80 in its instructions, implying that state auditors may review remarks for compliance.

Related Codes/Fields

The following table lists UB-04 fields that are commonly referenced alongside Field 80 or that may interact with remarks. All field names are taken from the Maryland Medicaid UB-04 instructions. ^[2]

Field Number	Field Name	Source
FL 63	Treatment Authorization Code	[2]
FL 64	Document Control Number (DCN)	[2]
FL 65	Employer Name (of the Insured)	[2]
FL 66	Diagnosis and Procedure Code Qualifier (ICD Version Indicator)	[2]
FL 67	Principal Diagnosis Code and Present on Admission Indicator	[2]
FL 71	PPS Code	[2]
FL 74	Principal Procedure Code and Date	[2]
FL 76	Attending Provider Name and Identifiers	[2]
FL 77	Operating Physician NPI/QUAL/ID	[2]
FL 78	Other Physician ID – QUAL/NPI/ID	[2]
FL 79	Other Physician ID – QUAL/NPI/ID	[2]
FL 80	Remarks	[3], [1], [2]
FL 81a-d	Code-Code Field (e.g., Taxonomy Code)	[2]

These fields often work together; for example, a treatment authorization code (FL 63) may be referenced in remarks, or a DCN (FL 64) may be noted when additional documentation is attached. Providers should ensure that remarks in FL 80 do not contradict information in these related fields.

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References

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

[2] Maryland Medicaid — FL 80 — https://health.maryland.gov/mmcp/provider/Documents/ffs-billing/UB04-Hospital-Billing-Instructions%20%281%29.pdf

[3] CMS Chapter 25 — FL 80 — https://www.cms.gov/regulations-and-guidance/guidance/manuals/downloads/clm104c25.pdf