Section title: Requests for Interpretation
Appropriate use for N301 in HL22 loop on 271 Response.

For the 5010 270/271 TR3 Guide within the HL22 loop on a 271 response when the Patient is the Subscriber:

1).  Is it an inappropriate disclosure of PHI if the payer is placing a guarantor’s name in N301, and that guarantor is not the patient?

2).  Outside of the disclosure issue, is it okay to have a name in an address line?


We have a situation where a payer is returning a 271 where the subscriber is the patient and there is a person name in 2100C N301.  The payer has stated that they are putting the name of the guarantor in N301.  Sometimes it matches the subscriber's name, other times it does not.





N3*FIRST AND LAST NAME*123 Fake Street, APT 990


RFI Response

It is outside the scope of X12 to comment on whether it is an inappropriate disclosure of PHI.  It is up to the entities involved to make this determination and decide what actions they consider necessary if they deem it to be an inappropriate disclosure of PHI.

Currently, the 270/271 nor the EDI standard prohibit the use of a name in N301, however sending a name in the N301 is not an intended use of the address information segment/element(s) as the standard and the TR3 both note this is to be used for ‘address information’ and recipient names are not typically defined within the TR3s as part of the address information.

RFI Recommendation

The ‘in care of’ and/or guarantor/responsible party’s name when using the postal service is recognized as an addressee and is typically then followed by a physical street address or PO Box, within the 270/271, in N301, and second address line, such as a suite or apartment, in N302.  The addressee, in the 271 is recommended to be conveyed in the NM103/NM104 of the 2120C/D loop as a better fit within the current 005010X279A1 when the guarantor/responsible party has financial and/or legal authority.  Using the 2120C/D, NM101 would contain code value “LR” (Legal Representative) when the guarantor/responsible party is or can be legally and/or financially responsible.  Using the 2120C/D also then allows for additional communication information to be returned for that guarantor/responsible party in the N3/N4 and PER segments when the address/contact information is different than that of the patient.

If the guarantor/responsible party is not legally and/or financially responsible, it is recommended to use the ‘care of’ in NM103 of either the 2100C or D loop (i.e., Subscriber Last Name c/o Responsible Party Name).  Although it is not prohibited, the last resort would be to use the N301 as the guarantor/responsible party name, understanding the risks and subsequent EDI transaction implications this may cause.

WG1 has submitted a maintenance request (MR) to initiate a request to support a way of recognizing a guarantor/responsible party in addition to the subscriber or dependent to a future 270/271 TR3.  This MR may apply more uniformly and consistently to the broader set of transactions in healthcare.

Related RFIs: 1825, 1934