Effective February 1, 2026, the Texas Department of Insurance (TDI) will require all applicable health plans to use state‑mandated uniform Coordination of Benefits (COB) questionnaires. Health plans must also accept these forms when submitted by either Providers or members.
This requirement applies to Texas‑licensed commercial plans, Medicaid Managed Care Organizations, CHIP, and nonprofit health plans. It does not apply to Medicare programs.
Regulatory Authority:
This change is directed by House Bill 388 (89th Texas Legislature, 2025) and is implemented through 28 Texas Administrative Code §3.3520, adopted by TDI in December 2025.
What Providers Need to Know:
Beginning February 1, 2026, TDI requires the use of two standardized forms for reporting other health coverage:
- LHL138 – Patient Health Plan Coverage (completed by Providers) [PDF]
- LHL139 – Enrollee’s Other Health Plan Coverage (completed by members) [PDF]
Community First will accept and process COB information submitted using these forms in accordance with TDI rules.
Operational Impact for Providers:
Providers may submit the LHL138 form whenever other health coverage information is identified. Incorporating the uniform form into your scheduling, intake, registration, billing, or claims workflows will help support timely and accurate COB processing and reduce delays.
The underlying COB rules remain the same. Order of payment rules, the birthday rule, Medicare and Medicaid COB laws, and allowable expenses or benefit design are unchanged. Only the format of the COB questionnaires is new.
Additional Information:
Providers should ensure teams are aware of the change, especially in settings where dual coverage is common, such as hospitals, large provider groups, and Federally Qualified Health Centers (FQHCs).
Action: Providers are encouraged to share this information with their staff. If you have any questions about this notice, please email Provider Relations at ProviderRelations@cfhp.com or call 210-358-6030. You can also contact your Provider Relations Representative directly.
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