Skip to main content

CO-P19 Denial Code: Zero Relative Value in Fee Schedule

CO-P19 means the procedure is listed in the jurisdiction's fee schedule with a relative value of zero, so the property and casualty payer calculates no payment for it. The service is typically considered bundled, not separately payable, or not covered under that schedule.

Quick facts

Code
CO-P19 (CARC P19)
Status
Active In use since November 1, 2013.
Code set
Claim Adjustment Reason Codes (CARC)
Group codes
  • CO (Contractual Obligation): The usual group. No payment is due under the fee schedule, and state rules generally bar billing the claimant.
Official description
Procedure has a relative value of zero in the jurisdiction fee schedule, therefore no payment is due. To be used for Property and Casualty only.
X12 Claim Adjustment Reason Codes, retrieved September 25, 2026
Last verified
against the official X12 list.

What CO-P19 means

CARC P19 says procedure has a relative value of zero in the jurisdiction fee schedule, therefore no payment is due. X12 limits it to property and casualty claims. It replaced deactivated CARC W8.

Many state workers’ comp and auto fee schedules are built on relative values: each code is assigned units, which are multiplied by a conversion factor to get the allowed amount. A code with zero units produces a zero allowance. Zero values usually mean the service is always included in another service, is used only for reporting, or isn’t separately payable under that state’s system.

This differs from CO-P18, where the code isn’t listed at all. With P19, the code is in the schedule, and the schedule deliberately assigns it no payment.

Common causes

  • Bundled services that the state schedule values at zero because they’re part of another service.
  • Reporting-only or tracking codes billed with a charge.
  • Services the state excludes from payment.
  • Wrong fee schedule version applied, where an older or newer version values the code differently.

How to handle it

  1. Confirm the relative value for the code in the state schedule for the date of service.
  2. Check the version and region the payer used.
  3. If the payer used the wrong schedule, request reconsideration with the correct values.
  4. If the value is zero, accept the adjustment. Check whether another, payable code better describes the service; if so, correct and resubmit.
  5. Don’t bill the claimant for zero-value services on P&C claims unless state rules allow.

How to prevent problems

  • Load the state schedule’s relative values into your billing system, including zero-value codes.
  • Set zero-value codes to a zero charge or flag them so they don’t create open balances.
  • Review annual updates, since values can change between versions.

Specialty notes

Surgical and anesthesia practices billing under workers’ comp should know which codes carry zero value in each state’s schedule, since supply and add-on codes are common examples.

Remark codes that may appear with CO-P19

  • N643 (The services billed are considered Not Covered or Non-Covered (NC) in the applicable state fee schedule.): The services are considered not covered in the applicable state fee schedule.
  • N390 (This service/report cannot be billed separately.): The service or report can't be billed separately.
  • CO-W8Deactivated (Procedure has a relative value of zero in the jurisdiction fee schedule, therefore no payment is due.): The deactivated code that CARC P19 replaced.
  • CO-P18 (Procedure is not listed in the jurisdiction fee schedule.): The code isn't listed, and a comparable service was paid.
  • CO-P14 (The Benefit for this Service is included in the payment/allowance for another service/procedure that has been performed on the same day.): The service is included in another same-day service.
  • CO-246 (This non-payable code is for required reporting only.): A non-payable code for required reporting only, used outside P&C.

CO-P19 FAQ

Why would a code have zero relative value?

Fee schedules based on relative values assign zero to services that are always bundled into another service, are reporting-only, or aren't payable under that system. A state may also set some codes to zero by policy.

Can I appeal CO-P19?

Only if the payer used the wrong schedule, date, or code. If the state schedule assigns zero to the code, payment generally isn't available.

Should I stop billing zero-value codes?

Not always. Some states require reporting codes even when they aren't paid. Follow the state's billing rules.

Is CO-P19 used by health plans?

No. X12 limits it to property and casualty claims.

Is CO-P19 the same as a bundling denial?

Often the effect is similar, but the reason is different. CO-P19 comes from the schedule's zero value for the code; CO-P14 comes from a rule bundling one service into another performed the same day.