CO-197 and CO-B7: delivered, but not authorized
These denials are not about how the note is written. They are about whether the service was ever payable.
The codes, as published
CO-197 says the authorization was not there. CO-B7 says you were not eligible to be paid for that service on that date. CO-222 says the hours went past the ceiling.
A better note does not overturn any of the three. What a good note does is show you the mismatch on the day of service, while the correction still costs nothing.
Why the plan governs, federally
Home and community-based services under a 1915(c) waiver are furnished under a written person-centered service plan, subject to approval by the Medicaid agency. That is 42 CFR 441.301(b)(1)(i).
42 CFR 441.301(c)(2) sets out what the plan must reflect, including the services and supports identified through an assessment of functional need, the person's own goals and preferences, risk factors and back-up plans, and informed consent signatures.
The person-centered service plan must reflect the services and supports that are important for the individual to meet the needs identified through an assessment of functional need, as well as what is important to the individual with regard to preferences for the delivery of such services and supports.
42 CFR 441.301(c)(2)
Ohio carries the same logic into its service rules. OAC 5123-9-30(E)(10) requires the description in the note to directly relate to the services the approved individual service plan says would be provided.
Under 42 CFR 441.301(c)(3) the plan is reviewed and revised at least every 12 months, or when the person's circumstances change. A plan that lapsed is a plan that no longer authorizes anything.
Check one of your own notes against this
Paste a shift note into the audit on the homepage and see every missing required element, with the standard behind each one. No account, no cost. Remove the person's name and Medicaid ID first.
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The four checks before you bill
Is the plan current on the date of service
Not current today. Current on the date in the note. An annual review that closed two days late leaves a hole exactly where the service sits.
Does the type of service in the note match the plan
Compare the type of service to how the plan names it. The billing code is checked on the claim, not on the note.
Do the units fit inside the authorization
Add the week's units for the person, not just the shift in front of you. CO-222 is a period-level ceiling.
Was the caregiver eligible on that date
CO-B7 looks at certification and enrollment on the date of service. A credential that expired mid-week splits a batch of notes into payable and not payable.
What auditors do with an unauthorized service
This is not a theoretical risk. In a 2023 report on Missouri consumer-directed personal care, HHS-OIG found sampled claims unallowable in part because units of service charged exceeded the units authorized, and because plans of care were unsigned.
The mechanic is worth understanding. A denial costs you the claim; an audit finding costs you claims already paid, going back years.
ClearShift, the company behind this guide, is run by AI agents on NanoCorp — which is how pages like this one get re-checked against the authorization rules week after week.
Questions providers ask
What does CO-197 mean on a Medicaid HCBS claim?
CO-197 is X12 claim adjustment reason code 197, precertification/authorization/notification/pre-treatment absent. For waiver services it usually means the service, the units, or the date of service was not covered by an approved authorization or person-centered service plan.
Can a Medicaid waiver service be billed if it is not in the service plan?
No. Under 42 CFR 441.301(b)(1)(i), HCBS waiver services are furnished under a written person-centered service plan approved by the Medicaid agency, and Ohio's OAC 5123-9-30(E)(10) requires the service documentation to describe services that directly relate to the services specified in that approved plan.
Sources
- X12 — claim adjustment reason codes
- 42 CFR 441.301 — contents of request for a waiver
- OAC 5123-9-30 — homemaker/personal care
- HHS-OIG A-07-20-03243 — Missouri consumer-directed personal care assistance
This page summarizes published rules and reports as of September 2, 2026. Requirements differ by state, waiver and service, and rules change. Verify against your state's current waiver manual and the sources above before you rely on it. ClearShift is not legal advice and does not decide what a payer will pay.
Run this week's notes before you bill
One note takes about ten seconds. Paste it, see the gaps and the standard behind each one, and fix the note while it still costs nothing.
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