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RARC M39 · Remittance Advice Remark Code

RARC M39 Remark Code: The patient is not liable for payment for this service as the advance notice of…

Reviewed by QuickIntell RCM Editorial Team · Last reviewed

Updated

Not an ICD-10 code. RARC M39 is a remittance-advice remark code published by X12 and carried on the 835 LQ segment. Any ICD-10 code with the same letters and digits (e.g., ICD-10 M15 osteoarthritis, N130 other urinary tract disorders) is a separate, unrelated code set used in diagnoses on the 837. Confirm the context before acting on this page.

TL;DR

RARC M39 (X12 The patient is not liable for payment for this service as the advance notice of non-coverage you pr…). Commonly paired with CARC 96, CARC M27. RARC M39 invalidates the ABN — the notice did not meet Medicare's ABN compliance rules.

Official X12 description

“The patient is not liable for payment for this service as the advance notice of non-coverage you provided the patient did not comply with program requirements.”

Source: X12 Remittance Advice Remark Codes. X12 publishes and maintains the RARC set; always verify against the current release before building a claim workflow.

Paired CARC codes

RARC M39 almost never appears alone — it accompanies one of the CARCs below on the same 835 remittance line. Fix the CARC and the RARC typically clears; the RARC alone is informational.

Paired CARCWhat the CARC means
CARC 96Non-covered charge(s).
CARC M27See X12 External Code Lists

What RARC M39 actually means

RARC M39 invalidates the ABN — the notice did not meet Medicare's ABN compliance rules. Provider absorbs; fix ABN process for future services.

Common root causes

  • ABN form/content/timing did not meet CMS rules.

Prevention checklist

  • ABN workflow audit against CMS ABN compliance checklist.

Resolution & appeal strategy — step by step

Because RARC M39 is supplemental to a CARC, the resolution path usually starts by fixing the underlying adjustment reason. A formal appeal of the RARC alone is rarely necessary.

  1. 1Not appealable — ABN invalidated.
Sample reconsideration language referencing RARC M39
[Provider letterhead] Re: Reconsideration — Claim #{claim_number}, CARC 96 / RARC M39 Member: {member_name} · Member ID: {member_id} Date(s) of Service: {dos} The 835 remittance on {remittance_date} carried RARC M39: "The patient is not liable for payment for this service as the advance notice of non-coverage you provided the patient did not comply with program requirements." We request reconsideration. The attached documentation rebuts the remark code: 1. [State the fact that rebuts the remark — authorization number, primary 835, modifier rationale, LCD citation, etc.] 2. [Reference the paired CARC and the corresponding fix] 3. [Attach the supporting document listed in step 1] Attached: {list supporting documents} Please process this line under the member's benefits. Contact the billing office at {provider_phone} for questions. Sincerely, {billing_manager_name}, {credentials}

Edit the bracketed fields before sending. Payer-specific reconsideration forms are often required — check the provider portal first.

How common is RARC M39?

Platform frequency
Pending ETL

Platform frequency ranks publish once the anonymized denial-rate pipeline reaches the publication threshold (strategy §12 Phase 2).

How QuickRCM handles RARC M39

QuickRCM reads RARC M39 alongside its paired CARC in the 835 LQ segment and routes the line to the correct worker queue with the right documentation already attached:

  • Denial routing rules tuned to the CARC+RARC pair — the paired combination tells QuickRCM which documentation the payer will accept.
  • Reconsideration template for this exact remark code pulls the supporting facts from the claim automatically.
  • Pre-submission scrubs that catch the preventable drivers surfaced on this page before the 837 leaves the clearinghouse.
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Frequently asked questions — RARC M39

What does RARC M39 mean?

RARC M39 is an X12 Remittance Advice Remark Code. The official X12 definition is: "The patient is not liable for payment for this service as the advance notice of non-coverage you provided the patient did not comply with program requirements." It is supplemental to a Claim Adjustment Reason Code (CARC) on the same 835 line.

Which CARC is paired with RARC M39?

RARC M39 is most commonly paired with CARC 96, CARC M27. The CARC is the financial adjustment reason; the RARC is the informational remark. Fix the paired CARC first — the RARC usually clears with the corrected claim.

How do I resolve a RARC M39 remark on a remit?

Start from the root cause: ABN form/content/timing did not meet CMS rules. First step: Not appealable — ABN invalidated. Because RARCs are supplemental, the resolution is almost always to address the paired CARC rather than appeal the RARC alone.

Where does RARC M39 appear on the 835 ERA?

RARC M39 is carried on the 835 Loop 2110 LQ segment alongside the CARC in the CAS segment of the same service line. The code and its X12 description also print on the paper EOB in the "Remark Code" or "Remark" column next to the corresponding denial or adjustment reason.

Is RARC M39 the same as ICD-10 code M39?

No. RARC M39 is a remittance-advice remark code published by X12 and carried on the 835. Any ICD-10 code with the same letters and digits is a diagnosis code on the 837 HI segment — a completely different code set maintained by the WHO/CMS. Use the transaction context (835 = RARC; 837 = ICD-10) to disambiguate.

Disclaimer

This page is operational reference for medical-billing professionals. It is not legal, clinical, or contractual advice. X12 code descriptors are maintained by the X12 External Code Lists; always verify against the current X12 release and the payer's own published policy before submitting or appealing a claim.