Where in the world is the Annual Full Replacement COB File notice?

Do you have an Annual COB File plan?

For the past handful of years, CMS has published a Health Plan Management System (HPMS) notice reminding plans of the release of the Annual Full Replacement COB file.  Usually, the files are released between 3/20 – 4/14.  CMS is a bit behind but plans should expect this notice be distributed via HPMS soon.

In our experience, plans should still expect the COB re-sync files any day, and these files can only be identified based on larger files with higher volumes over a period of 3-5 days.  Because this is an annual process, we do not anticipate there will be a significant change in the timing of these files – just possibly the notice from CMS.

Reminders from our experts: Don’t load the files without having a plan in place!

  • The intended purpose of the file is to review your COB information in comparison to the once-a-year cumulative COB file. Don’t override updated information that has been submitted and not processed by ECRS.
  • Evaluate all PRM records and understand any impact to your members of applying un-validated information to pharmacy claims payment.
  • Cross-functionally evaluate using this file for the annual mailing. What is the impact on your call center or staff processing any returned COB information? Did you recently send a notice to the member within the last 6 months?


Madena’s Membership Suite™ COB module can assist plans in managing the annual full file as well as the daily files.  Our software is workflow enabled and highly configurable to your business rules combined with our industry leading expertise.  Our COB module will enable your organization to identify duplicates, create workflows based on record type or insurer and creates exports in your required format for ECRS submissions, print-mailing, data feed into your PBM, reporting to your Recovery contractor or any other business need.  Learn more by contacting Jennifer Young at jyoung@madenasolutions.com.

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