CO-110: Billing date before the service dates

The payer is telling you the claim header billing date cannot be earlier than the service from or through dates. In plain terms, the payer thinks you billed the claim before the treatment happened, so it treats the charge setup as invalid. Mechanically, the payer edits the UB-04 or CMS-1500 statement or billing date against each service line date range. When the header date is earlier than the service date, the claim denies with CO-110 and the charge moves to provider write off unless you fix the dates and resubmit.

In behavioral health, CO-110 shows up a lot on per diem UB-04 claims when statement dates are copied forward wrong. For example, a PHP or IOP claim where the billing software keeps last month's bill date, but staff update only the service from and through dates, triggers this edit with commercial plans and Medicaid MCOs. Residential or detox stays are also at risk when census staff key the admit date, but the biller uses an older billing date or a prior cycle's bill. Payers that carve out behavioral health sometimes apply extra front-end edits on dates, so even a one-day mismatch between billing date and the first service date can bounce the whole claim. Telehealth SUD visits and group services can fail in the same way when a template creates a batch with an old billing date. If claims sit in a queue and are released later without updating the billing date, CO-110 hits, which burns days on the clock for timely filing while you correct and resend.

• Check the 837 or paper claim to compare the billing or statement date against all service from and through dates.
• Confirm the actual dates of service in the EHR schedule, progress notes, and census reports for the level of care billed.
• Correct the billing or statement date in your practice management system so it is on or after the earliest service date, then regenerate the claim.
• For UB-04 per diem claims, verify the statement from and through dates match the residential, PHP, IOP, or detox stay reported.
• Resubmit as a corrected claim following the payer's rules, and note "corrected billing date" in the claim comments or cover sheet if allowed.
• If payment is still denied or timely filing is questioned, submit a short appeal with screen prints or census logs supporting the true service period.

• Set billing-system rules that block release of any claim where the billing or statement date is earlier than the earliest service line date.
• Train billers not to reuse old claim shells or templates without refreshing all header dates, especially for PHP, IOP, and residential cycles.
• Include a date-check step in month-end census and billing reconciliation so service, admission, discharge, and billing dates line up.
• Run a weekly pre-submission report for behavioral claims flagged with date inconsistencies and fix them before files go to payers.