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N728 Remark Code: Workers' Comp Insurer Has ORM

N728 means a workers' compensation insurer has reported ongoing responsibility for medical services (ORM) for this diagnosis. The payer considers the work injury carrier primary and expects related care to be billed there.

Code: N728 (RARC N728)
Status: Active In use since March 1, 2014.
Code set: Remittance Advice Remark Codes (RARC)
Group codes: CO (Contractual Obligation): The payer denies the service because the workers' compensation carrier is responsible. The patient is generally not liable for work injury care.
OA (Other Adjustment): Some payers report the other-payer determination under OA. It is a coordination matter, not a patient balance.
Official description: A workers' compensation insurer has reported having ongoing responsibility for medical services (ORM) for this diagnosis.
X12 Remittance Advice Remark Codes, retrieved September 25, 2026
Last verified: September 24, 2026 against the official X12 list.

What N728 means

When a workers’ compensation carrier accepts a work injury claim, it can report that it has ongoing responsibility for the injured worker’s related medical care. N728 says the payer has such a report for the diagnosis on your claim. The payer therefore denies or redirects the service, most often with CARC 19 or CARC 22.

Workers’ compensation is regulated state by state, so the billing forms, fee schedules, and rules on billing the patient depend on the jurisdiction.

Common causes

A patient treated for a workplace injury presented a health plan card and did not mention the work claim.
Follow-up visits for the injury were billed to the health plan after the first visit went to the carrier.
The diagnosis on an unrelated visit overlaps with the work injury.
The carrier closed the claim, but the ORM report still shows it as open.

How to fix it

Confirm the work injury details with the patient or employer: date of injury, carrier, and claim number.
Bill the workers’ compensation carrier using the forms and rules required in that state.
For care unrelated to the injury, review the diagnosis codes and ask the payer to reprocess.
If the carrier denies liability or has closed the claim, send its written decision to the payer that issued N728.

How to prevent it

Ask whether a visit relates to a work injury during scheduling, and keep workers’ compensation claim details on the account for every related encounter.

Codes that may appear with N728

OA-19 (This is a work-related injury/illness and thus the liability of the Worker's Compensation Carrier.): This is a work-related injury or illness and the workers' compensation carrier's liability.
OA-22 (This care may be covered by another payer per coordination of benefits.): Another payer may be responsible under coordination of benefits.

N722 (Patient must use Workers' Compensation Set-Aside (WCSA) funds to pay for the medical service or item.): The workers' compensation case settled and a set-aside pays instead of the carrier.
N743 (Adjusted because the services may be related to an employment accident.): The payer only suspects a work accident and wants it clarified.
N725 (A liability insurer has reported having ongoing responsibility for medical services (ORM) for this diagnosis.): The same situation with a liability insurer.
CO-P2 (Not a work related injury/illness and thus not the liability of the workers' compensation carrier): The reverse: the workers' compensation carrier says the injury is not work related.

N728 FAQ

Can I bill the patient for a work injury after N728?

In most states, providers cannot bill injured workers for accepted work injury care. Bill the workers' compensation carrier and follow that state's rules.

What if the workers' comp carrier denies the claim?

Get the carrier's written denial, for example a finding that the condition is not work related, and send it to the payer that issued N728 with a request to reprocess.

What information do I need to bill the WC carrier?

Typically the employer, the date of injury, the carrier and claim number, and the adjuster's contact. Many states also require specific forms or reports.

Important: read before using this information

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