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N139 Remark Code: Non-Par Dentist Not an Appealing Party

N139 is an alert that, under the TRICARE regulation at 32 CFR 199.13, a non-participating provider is not an appropriate appealing party. To dispute the Dental Advisor's opinion, the provider must be appointed in writing by the beneficiary as their representative and file within 90 days of the letter.

Quick facts

Code
N139 (RARC N139)
Status
Active In use since October 31, 2002; last modified March 1, 2017.
Code set
Remittance Advice Remark Codes (RARC)
Group codes
  • PR (Patient Responsibility): When a non-participating provider's claim is reduced or denied, the balance is often left with the beneficiary, which is why the beneficiary's appointment matters.
  • CO (Contractual Obligation): If a provider-liability adjustment applies, the provider still needs representative status to appeal it.
Official description
Alert: Under 32 CFR 199.13, a non-participating provider is not an appropriate appealing party. Therefore, if you disagree with the Dental Advisor's opinion, you may appeal the determination if appointed in writing, by the beneficiary, to act as his/her representative. Should you be appointed as a representative, submit a copy of this letter, a signed statement explaining the matter in which you disagree, and any radiographs and relevant information to the subscriber's Dental insurance carrier within 90 days from the date of this letter.
X12 Remittance Advice Remark Codes, retrieved September 25, 2026
Last verified
against the official X12 list.

What N139 means

N139 is a procedural warning for dentists who do not participate with the TRICARE dental program’s carrier. The cited federal regulation limits who can appeal. A non-participating provider cannot appeal in their own name. The path is to have the beneficiary appoint the provider, in writing, as their representative.

What to do

  1. Talk with the beneficiary about the decision and whether they want to appeal.
  2. Get a signed written appointment naming you as the beneficiary’s representative.
  3. Assemble the appeal: the letter, your signed statement of disagreement, radiographs, and other supporting records.
  4. File within 90 days of the letter date with the subscriber’s dental carrier.

If you treat military families regularly, consider whether participating with the carrier would simplify appeals and payment.

Codes that may appear with N139

  • CO-216 (Based on the findings of a review organization or the payer's findings.): The decision was based on a review, here the Dental Advisor's opinion.
  • CO-169 (Alternate benefit has been provided.): An alternate benefit was provided after advisor review.
  • N140 (Alert: You have not been designated as an authorized OCONUS provider therefore are not considered an appropriate appealing party.): A similar rule for providers who are not authorized overseas (OCONUS) providers.
  • N138 (Alert: In the event you disagree with the Dental Advisor's opinion and have additional information relative to the case, you may submit radiographs…): Describes the second Dental Advisor review process.
  • N10 (Adjustment based on the findings of a review organization/professional consult/manual adjudication/medical advisor/dental advisor/peer review.): An adjustment based on a dental advisor or other review.

N139 FAQ

What must a representative submit?

Per the remark: a copy of the letter, a signed statement explaining the disagreement, and any radiographs and relevant information, sent to the subscriber's dental carrier.

How long do I have?

The remark states 90 days from the date of the letter.

Can the beneficiary appeal without me?

Yes. The beneficiary is an appropriate appealing party. The provider can support them with records and a narrative.