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N391 Remark Code: Missing Emergency Department Records

N391 means the payer needed the emergency department records for this visit to process the claim, and they were not received.

Quick facts

Code
N391 (RARC N391)
Status
Active In use since August 1, 2007.
Code set
Remittance Advice Remark Codes (RARC)
Group codes
  • CO (Contractual Obligation): The claim is denied or pended until the ED records are received. The provider must send them; the patient is not billed while the records are outstanding.
Official description
Missing emergency department records.
X12 Remittance Advice Remark Codes, retrieved September 25, 2026
Last verified
against the official X12 list.

What N391 means

Emergency department claims are often reviewed after the fact. The payer may be checking whether the visit meets its emergency definition, whether the level billed matches the documentation, or whether another party is liable. N391 says it asked for the ED records to do that review and never got them.

The remark usually accompanies CARC 252, 163, or 226.

Common causes

  • The records request letter went to the wrong department or address.
  • Records were sent without the claim number or request reference, and the payer couldn’t match them.
  • The attachment control number on the electronic claim didn’t match the documents sent.
  • Only the facility or only the professional records were sent when the payer wanted the other.
  • The response deadline passed before the records arrived.

What to do

  1. Find the request. Check the payer portal or call to learn what was requested, by when, and where to send it.
  2. Gather the ED record for the date of service: physician documentation, triage, nursing notes, orders, results, and disposition.
  3. Label the submission with the patient name, member ID, claim number, and date of service.
  4. Submit through the payer’s preferred channel, keeping proof of submission.
  5. Follow up in a couple of weeks to confirm the claim is being reprocessed.

If the deadline has passed, ask whether the payer will reopen the claim when records arrive or whether an appeal is required.

How to prevent it

Route all payer record requests to one queue with due dates. For payers that routinely review ED claims, consider sending records with the original claim as an attachment.

Codes that may appear with N391

  • CO-252 (An attachment/other documentation is required to adjudicate this claim/service.): An attachment or other documentation is required; N391 says it is the ED record.
  • CO-163 (Attachment/other documentation referenced on the claim was not received.): The attachment referenced on the claim was not received.
  • CO-226 (Information requested from the Billing/Rendering Provider was not provided or not provided timely or was insufficient/incomplete.): Information requested from the provider was not provided or not provided timely.
  • N392 (Incomplete/invalid emergency department records.): Used when ED records were received but are incomplete or invalid.
  • M127 (Missing patient medical record for this service.): Covers a missing patient medical record for the service in general.
  • N221 (Missing Admitting History and Physical report.): Used when the admitting history and physical report is missing.

N391 FAQ

Which records should I send?

Typically the ED physician's note, triage and nursing notes, orders, results, and disposition. Check the payer's request letter for exactly what it wants.

Why would a payer need ED records?

Common reasons are reviewing whether a visit met emergency criteria, confirming the level of service, or checking a related accident or other liability.

How do I send them?

Use the payer's attachment method: an electronic attachment with the claim's control number, upload through the portal, or fax or mail with the request letter.