UB04 Release of Info Certification Code I: Informed consent to release medical information for conditions or diagnoses regulated by Federal Statutes.

Overview

When to Use

Step-by-Step Claim Example

Scenario: A hospital treats a patient for opioid use disorder in an inpatient detoxification program. The patient signs a 42 CFR Part 2-compliant consent form authorizing release of treatment information to Medicare for billing purposes.

Step 1: Complete all patient demographic information in Fields 1-11 (patient name, address, birthdate, sex). ^[1] specifies that Field 08 requires patient name and identifier, and Field 10 requires patient birthdate.

Step 2: Enter the admission date in Field 12 and discharge status in Field 17. For this inpatient stay, use admission date 01/15/2024 and discharge status code 01 (discharged to home).

Step 3: In Field 52 (Release of Information Certification), enter Code I. This indicates the provider has informed consent to release medical information for conditions regulated by federal statutes (42 CFR Part 2). ^[1] notes that the A/B MAC must be able to capture all NUBC-approved input data.

Step 4: Complete revenue codes in Field 42 (e.g., 0100 for general inpatient services) and diagnosis codes in Fields 67-75 (e.g., F11.20 for opioid dependence).

Step 5: Submit the claim to the appropriate payer. The provider retains the institution copy and submits remaining copies to the A/B MAC or managed care plan. ^[1] states that where the provider knows a managed care plan will pay, it sends the bill directly to that plan.

Common Mistakes & Audit Red Flags

1. Using Code I without proper federal consent documentation – This is a major audit red flag. Payers may request the signed consent form, and if it does not meet federal statute requirements (e.g., 42 CFR Part 2 consent elements), the claim may be denied or subject to recoupment. ^[1] notes that the A/B MAC must be able to capture all NUBC-approved input data for audit trail purposes.

2. Using Code I when only HIPAA authorization exists – Code I is specifically for conditions regulated by federal statutes beyond HIPAA. Using it for general medical conditions not subject to federal privacy laws is incorrect and may trigger audits.

3. Omitting the code entirely for federally regulated conditions – Failing to use Code I when required can result in claim rejection or payment delays, as the payer may not process the claim without proper certification.

4. Confusing Code I with other Field 52 codes – Code A (patient authorization) is for general HIPAA authorization, while Code I is for federal statute-specific consent. Using the wrong code can lead to compliance issues.

5. Not updating consent when conditions change – If the patient revokes consent or the consent expires, the provider must not continue using Code I. ^[2] emphasizes that providers must follow all applicable regulations.

Related Codes/Fields

Field/Code	Description	Source
Field 52, Code A	Patient authorization to release medical information (general HIPAA)	[1]
Field 52, Code B	Provider authorization to release medical information	[1]
Field 52, Code C	Medicare mandated release of information	[1]
Field 52, Code D	Patient refusal to release medical information	[1]
Field 52, Code I	Informed consent to release medical information for conditions/diagnoses regulated by Federal Statutes	[1]
Field 18-28 (Condition Codes)	Used to indicate specific conditions, including those related to federal statutes	[1]
Field 67-75 (Diagnosis Codes)	ICD-10-CM codes for the conditions being treated	[1]

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References

[1] CMS Chapter 25 — https://www.cms.gov/regulations-and-guidance/guidance/manuals/downloads/clm104c25.pdf

[2] MassHealth UB-04 Guide — https://www.mass.gov/doc/ub-04-billing-guide-0/download