How does Counterclaim generate an insurance appeal letter?

Counterclaim uses a 5-agent AI pipeline. The Reader extracts claim data from your document. The Researcher identifies applicable state insurance law. The Writer drafts a formal appeal letter. The Adversary identifies weaknesses. The Editor rewrites the letter to eliminate all weaknesses. The final letter is ready to print and mail in minutes.

Is Counterclaim free to use?

Yes - Counterclaim is free during the launch period. Upload your denial letter and receive a complete adversary-tested appeal letter at no cost. No account required.

What types of insurance denials can Counterclaim handle?

Counterclaim handles all major denial types: medical necessity (CO-50), prior authorization (CO-11), experimental treatment (PR-1), fee schedule (CO-45), timely filing (PR-27), not covered (CO-4), step therapy (PR-50), and missing information (CO-16).

What file formats does Counterclaim accept?

Counterclaim accepts PDF files, JPG and PNG photos, and scanned documents of your denial letter or Explanation of Benefits (EOB).

Does Counterclaim provide legal advice?

No. Counterclaim generates appeal letters based on publicly available legal and clinical information but does not constitute legal advice. For complex cases, consult a licensed healthcare attorney or certified patient advocate.

What does CO-22 mean on my Explanation of Benefits?

CO-22 means 'this care may be covered by another payer per coordination of benefits.' Your insurer is asserting that a different insurance plan should be billed first or instead. It is not saying the service is excluded, it is saying the claim went to the wrong plan in the payment order, or that the insurer's records show other coverage that needs to be reconciled.

What is coordination of benefits?

Coordination of benefits (COB) is the set of rules that decide which plan pays first when you are covered by more than one health insurance policy. The 'primary' plan pays up to its limits first, then the 'secondary' plan may cover remaining eligible costs. COB prevents both plans from paying the same expense twice and establishes a clear payment order.

How do I know which insurance is primary?

Common COB rules: your own employer plan is usually primary over a plan you have as a dependent; for a child covered by both parents, the 'birthday rule' makes the plan of the parent whose birthday falls earlier in the calendar year primary; an active employee's commercial plan is generally primary over Medicare; and COBRA or retiree coverage is generally secondary to active employer coverage. Your insurer's member services line can confirm the order on file.

What if the insurer has wrong 'other insurance' information on file?

This is one of the most common causes of a CO-22 denial. If the insurer's records show other coverage you no longer have (or never had), call member services and ask them to update or terminate the outdated coordination of benefits record. Many insurers send an annual COB questionnaire, failing to return it can trigger an automatic CO-22 hold. Once the record is corrected, ask the provider to resubmit the claim.

What if my injury should be covered by auto or workers' compensation?

If the care relates to a car accident or a workplace injury, your health insurer may issue CO-22 expecting auto medical payments coverage, no-fault insurance, or workers' compensation to pay first. If that other coverage denies the claim or is exhausted, obtain that denial in writing and submit it to your health insurer so it can process the claim as the responsible payer.

CO-22

How to Resolve a CO-22 'Covered by Another Payer' Denial

Claim denied with CO-22 because another insurance should pay first? This coordination of benefits denial is usually a sequencing error. Learn how to fix the order and get your claim paid.

What does CO-22 mean?

A CO-22 denial means your insurer believes the care may be covered by another payer under coordination of benefits (COB) rules. In plain terms, the insurer thinks a different plan should pay first (or instead), so it is refusing to pay until the claim is submitted to the correct primary payer. CO-22 is a sequencing problem, not a coverage exclusion.

Why insurers issue CO-22 denials

When you are covered by more than one health plan (for example your own employer plan plus a spouse's plan, or a commercial plan plus Medicare), coordination of benefits rules determine which plan pays first. CO-22 is issued when the insurer's records suggest another plan is primary, when the COB information on file is outdated, or when a claim that should have gone to auto, workers' compensation, or liability coverage was sent to the health plan instead. Often the insurer simply has stale 'other insurance' data on file that you can correct in one phone call.

Appeal strategy

First determine which plan is actually primary under the standard COB rules (the 'birthday rule' for dependent children, employer plan before retiree or COBRA coverage, and commercial before Medicare in most active-employee situations). Submit the claim to the primary payer first, then submit the primary plan's Explanation of Benefits to the secondary plan so it can pay the balance. If the insurer has incorrect other-insurance information on file, call member services and ask them to update or remove the outdated COB record, then have the provider resubmit.

Frequently asked questions about CO-22

CO-50

Medical Necessity Denial (CO-50)

CO-11

Prior Authorization Denial (CO-11)

CO-55

Experimental Treatment Denial (CO-55)

CO-45

Exceeds Fee Schedule Denial (CO-45)