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June 3, 2025

Understanding Dental Code D9961 – Duplicate/copy patient's records

Learn when and how to use D9961 dental code for duplicating patient records, with practical billing tips and compliance best practices for dental offices.

Understanding Dental Code D9961

When to Use D9961 dental code

The D9961 dental code is designated for the duplication or copying of a patient’s dental records. This CDT code is used when a patient, another provider, or an insurance company requests a copy of dental records, including radiographs, photographs, treatment notes, or other clinical documentation. It is not intended for routine record-keeping or internal office use, but specifically for instances where a duplicate set is provided to an external party. Common scenarios include patient transfers, specialist referrals, legal requests, or insurance audits.

Documentation and Clinical Scenarios

Proper documentation is crucial when billing for D9961. Always record the request for records in the patient’s chart, specifying who requested the records, the date of the request, and exactly what was duplicated. Attach a copy of the request letter or form to the patient’s file. Clinical scenarios where D9961 is appropriate include:

  • A patient is moving and requests their records be sent to a new dentist.
  • An orthodontist requests full records before beginning treatment.
  • An insurance company requests documentation to process a claim or appeal.
  • A legal entity requests records for a case review.

In all cases, ensure HIPAA compliance by obtaining written authorization from the patient before releasing any records.

Insurance Billing Tips

When billing D9961, keep in mind that most dental insurance plans do not reimburse for duplication of records, as this is often considered a non-covered administrative service. However, it is best practice to inform patients of any fees in advance and to include the D9961 code on the patient ledger and any statements. If submitting to insurance, clearly document the reason for the request and attach supporting documentation. For offices that charge a fee, ensure the amount is reasonable and compliant with state regulations regarding medical record duplication fees.

For claim denials, include a copy of the patient’s written request and a detailed breakdown of what was duplicated. If the request is related to a claim appeal, reference the original claim number and include all supporting documentation. For more information on claim appeals, see our guide to miscellaneous CDT codes.

Example Case for D9961

Scenario: A patient is relocating to another state and requests their complete dental records, including X-rays and periodontal charting, be sent to their new provider. The office receives a signed authorization form. The front desk team documents the request, duplicates the records, and bills the patient a reasonable fee using D9961. The patient is informed of the fee in advance, and the transaction is recorded in the patient’s account. The records are sent securely, and a note is made in the chart confirming the date and method of delivery. This process ensures compliance, transparency, and proper billing for the service provided.

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FAQs

Is there a limit to how much a dental office can charge for duplicating records using D9961?
Can D9961 be used for providing original records instead of copies?
What are the HIPAA considerations when handling requests billed under D9961?

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