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N239 Remark Code: Invalid Financial Relationship Form

N239 means the physician financial relationship form sent to the payer was incomplete or invalid. Payers that use this form rely on it to check whether a referring physician has a financial interest in the entity furnishing the service, which can affect payment under self-referral rules.

Quick facts

Code
N239 (RARC N239)
Status
Active In use since August 1, 2004.
Code set
Remittance Advice Remark Codes (RARC)
Group codes
  • CO (Contractual Obligation): The claim was denied or held because the disclosure form did not meet requirements. The provider resolves it; the patient is not liable.
Official description
Incomplete/invalid physician financial relationship form.
X12 Remittance Advice Remark Codes, retrieved September 25, 2026
Last verified
against the official X12 list.

What N239 means

Federal and state self-referral laws, along with some payer policies, restrict referrals by physicians to entities where they or their family members have a financial relationship, subject to exceptions. Some payers collect a physician financial relationship form to review these relationships. N239 says the form on file is not complete or valid. It may pair with CARC 213 (self-referral non-compliance) or CARC 252.

Common causes

  • Questions about ownership or compensation were left blank.
  • The form lists physicians or relationships that don’t match current arrangements.
  • It lacks a required signature or date.
  • The form was completed on an outdated version or for a different entity or location.

What to do

  1. Identify what the payer found missing or invalid, calling provider services if the remittance doesn’t say.
  2. Involve your compliance or legal team to confirm the current relationships and how they should be disclosed.
  3. Complete a new form with accurate, current information and appropriate signatures.
  4. Submit it through the payer’s channel and ask whether the claim will be reprocessed or needs resubmission.
  5. If CARC 213 was also used, discuss with counsel before appealing, since the issue may involve more than paperwork.

How to prevent it

Maintain an up-to-date register of physician financial relationships, reviewed at least whenever ownership or compensation changes. Keep disclosure forms current with each payer that requires them. This page does not provide legal advice; when relationships are complex, get qualified counsel.

Codes that may appear with N239

  • CO-213 (Non-compliance with the physician self referral prohibition legislation or payer policy.): Non-compliance with physician self-referral prohibition legislation or payer policy.
  • CO-252 (An attachment/other documentation is required to adjudicate this claim/service.): Documentation, the financial relationship form, is required.
  • CO-16 (Claim/service lacks information or has submission/billing error(s).): The claim or its support contains missing or invalid information.
  • M131 (Missing physician financial relationship form.): The physician financial relationship form was missing entirely.
  • CO-183 (The referring provider is not eligible to refer the service billed.): The referring provider is not eligible to refer the service billed.

N239 FAQ

What is a physician financial relationship form?

A disclosure of ownership, investment, or compensation relationships between physicians and an entity furnishing services. Payers that use one want to check whether referrals comply with self-referral rules.

Does N239 mean we violated self-referral rules?

No. It means the form was incomplete or invalid. Whether any relationship is a problem is a separate question, which may need legal or compliance advice.

Who should complete the form?

Usually the entity furnishing the service, with information from the physicians involved. Consult your compliance team before filing.