US Medical Billing
Payer Contracts & Reimbursement

The Single Case Agreement

A single case agreement covers one patient's care under terms agreed for that case alone, with a payer the practice has no participation agreement with. It is worth starting from an unintuitive point: in most situations that produce one, the plan is solving its own problem rather than doing the practice a favor — because it has an obligation to cover the service and no contracted provider who can furnish it.

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Key takeaways

Three situations, and only one is a negotiation

Practices tend to treat every single case agreement the same way — as a request to a payer that may or may not be granted. That framing is right for one of the three cases and wrong for the other two, and being wrong about it costs money in a way that never appears on a report.

The network cannot furnish the service
The plan covers the benefit and has no contracted provider who can deliver it — because of geography, subspecialty, capacity, or timing. This is the case where the plan is under an obligation, and the section below sets out where that obligation is written for the two big managed-care programs.
Continuity of care
A patient is mid-course when a contract ends or their coverage changes, and interrupting the treatment is the worse outcome for everyone. Not the same obligation as the first case, but not a blank page either — plans generally have their own continuity-of-care provisions, and where they exist the agreement is being fitted to a process rather than invented.
A genuine one-off
The patient chose this practice, the service is available in network, and nothing compels the plan to agree to anything. This is the pure negotiation, and it is the only one of the three where the practice's leverage is the whole story.

Establish which one you are in before making a request

Where the obligation is written

For the two large managed-care programs, the network-inadequacy case is addressed directly in federal regulation. Neither provision is about single case agreements as such — an agreement is simply one way the plan discharges the obligation — but knowing they exist changes how a practice reads the plan's position.

The out-of-network coverage obligation in the two big managed-care programs.
The out-of-network coverage obligation in the two big managed-care programs.
ProgramWhat the rule requires
Medicaid managed careUnder 42 CFR 438.206(b)(4) (opens in a new tab), where the network is unable to provide necessary covered services to a particular enrollee, the entity must adequately and timely cover them out of network — and must do so for as long as the network remains unable to provide them. Paragraph (b)(5) then requires the out-of-network provider to coordinate with the entity on payment, and requires that the cost to the enrollee be no greater than it would have been in network.
Medicare AdvantageUnder 42 CFR 422.112(a)(1)(iii) (opens in a new tab), the organization must arrange for and cover any medically necessary covered benefit outside the plan network, at in-network cost sharing, when an in-network provider or benefit is unavailable or inadequate to meet the enrollee's medical needs.

Both provisions turn on the same trigger — the network cannot meet the need — and both reach the same conclusion about the patient. Neither says anything about what the practice is paid, which is precisely the gap a single case agreement fills.

The consequence worth taking from this

Two boundaries. Commercial coverage outside these programs is governed by the plan's own terms and by state law, which vary and are not summarized here. And where an out-of-network situation is one the No Surprises Act addresses, that Act supplies its own protections and its own dispute route — a statutory process after the fact, as against a negotiated agreement before it. The Act's notice and consent rules and its independent dispute resolution process own that ground; none of it is restated here.

What the agreement has to settle

A single case agreement is a contract, and it has to do what a contract does: leave nothing important to be worked out later by whoever is looking at the claim. The list below is short and every item on it has a failure mode attached.

  1. Who, precisely

    The patient, the member identifier, and the billing entity — the same identifiers that will appear on the claim. An agreement naming a practice whose claims come in under a different billing identity has already introduced the mismatch that will deny it.
  2. What, and for how long

    The services or codes covered, or a clearly defined episode, and the date range. An open-ended agreement is comfortable to sign and hard to enforce, and a payer's reading of what it covered is the one the remittance will reflect.
  3. How much, stated as a basis

    Not an amount alone but the basis it comes from — a case rate, a per diem, a percentage of a stated schedule, or a fee schedule identified by name and version. A rate with no basis is unverifiable when the payment arrives, and cannot be reconciled against anything.
  4. Whether authorization is included

    This is the item that most often turns a good agreement into a denied claim. An agreed rate is not an authorization. If a separate authorization is still required, the agreement should say so and the practice should obtain it before the service — the prior authorization request checklist covers what that request needs.
  5. How the claim will be recognized

    The most consequential and the most often omitted. Something has to connect the submitted claim to the agreement — a reference number, a specific submission address or queue, a required field. Without it the claim arrives as ordinary out-of-network work and is adjudicated as such.
  6. Filing window, appeals, and the patient's share

    Which filing deadline applies, what appeal route exists if the claim is mishandled, and exactly what the patient owes — with the practice's balance-billing position stated rather than assumed.

A verbal approval is not an agreement

Where single case agreements actually fail

Almost never on the rate. The rate is the part everyone concentrates on, which is exactly why it is rarely the problem.

  • The claim is not connected to the agreement. It submits like any other out-of-network claim, is adjudicated like one, and denies or underpays. The agreement was real; nothing on the claim said so.
  • The rate was agreed; the authorization was not. Two different approvals from two different parts of the payer, and having one does not produce the other.
  • The scope drifted. The episode ran longer, or additional services were needed. Whether the agreement covers them is a question best answered before they are furnished, and the answer is often an amendment rather than an argument.
  • Nobody owned it after signature. An agreement that is not attached to the account, and not known to whoever works the denial, is invisible at exactly the moment it matters. Whoever negotiated it should not be the only person who knows it exists.
  • The patient was told something different. The plan's obligation about cost sharing and the practice's own billing position have to match what the patient was told at the outset, or the agreement resolves the payer relationship and creates a patient one.

Treat it as a contract with a claim attached

Common questions

Will a payer agree to a single case agreement?

That depends entirely on the payer, the market, and the situation, and nothing here predicts it. What is worth establishing first is which situation you are in, because it changes the question. Where the plan's network cannot furnish a covered service the enrollee needs, the plan has an obligation to see that the service is covered — the federal rules for Medicaid managed care and Medicare Advantage both say so — and an agreement is simply one way it meets that obligation. Where the service is available in network and the patient chose your practice, nothing compels the plan to agree to anything, and the conversation is a request.

How much should we ask for?

This article does not name rates or percentages, and any figure it gave would be about someone else's market. What it can usefully say is that the number should be expressed as a basis rather than as a bare amount — a case rate, a per diem, or a percentage of a named and versioned schedule — because a rate with no basis cannot be verified when the payment arrives, and an underpayment against it cannot be demonstrated. The second point is that in the network-inadequacy case the patient's cost-sharing protection is already provided by rule, so it is not something to trade rate for.

The agreement is signed and the claim denied anyway. What went wrong?

Most often, nothing connected the claim to the agreement. Payer systems adjudicate a claim on what the claim says, and an out-of-network claim with no reference to a case agreement is an out-of-network claim. Check what the agreement specified about submission — a reference number, a particular address or queue, a required field — and whether the claim carried it. The second most common cause is an authorization that was never obtained because the rate discussion felt like approval. Both are fixable, and both are cheaper to prevent than to appeal.

Is a single case agreement the same as the No Surprises Act protections?

No, and the difference is one of timing and mechanism. A single case agreement is a contract the parties negotiate, usually before the care. The No Surprises Act supplies statutory protections in defined out-of-network situations, along with a dispute process that operates after a claim. They can both be in play, and which applies to a given episode depends on facts about the setting and the service. The Act's own rules — its notice and consent requirements and its independent dispute resolution process — are covered in the compliance cluster and are not restated here.

Authoritative sources

  • 42 CFR § 438.206 — Availability of services (opens in a new tab)

    Where a Medicaid managed care entity's provider network is unable to provide necessary covered services to a particular enrollee, it must adequately and timely cover those services out of network for as long as the network is unable to provide them; the out-of-network provider coordinates with the entity for payment, and the cost to the enrollee must be no greater than it would be in network.

  • 42 CFR § 422.112 — Access to services (opens in a new tab)

    A Medicare Advantage organization must arrange for and cover any medically necessary covered benefit outside the plan provider network, at in-network cost sharing, when an in-network provider or benefit is unavailable or inadequate to meet an enrollee's medical needs.

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