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Appeals

We are the Beneficiary and Family Centered Care Quality Improvement Organization, working to improve the quality of care for Medicare beneficiaries. Our site offers beneficiary and family-centered care information for providers, patients, and families. Welcome!

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Overview

Hospital Discharge Appeals

Patients who have Medicare (including Medicare Advantage), have the right to appeal a hospital discharge if they feel too sick to be discharged. The hospital gives patients a form called An Important Message from Medicare. This form tells patients how to appeal the discharge.  During the appeal, patients do not have to leave the hospital and do not have to pay for the extra days in the hospital.

Skilled Service Termination Appeals

Patients who have Medicare (including Medicare Advantage) also have the right to file a skilled service termination appeal if they do not agree with the decision that Medicare skilled services will be stopped. Facilities must give patients a letter called a Notice of Medicare Non-Coverage explaining how to appeal.

This Process Flow Chart (PDF) shows the appeals process on page 1 and the beneficiary complaint process on page 2.

Immediate Advocacy Discharge Assistance

Immediate Advocacy Discharge Assistance (also referred to as IADA) is available to Original (Fee-for-Service) Medicare patients who contact Acentra Health with concerns about a planned acute care hospital discharge. IADA applies when a hospitalized patient with Original Medicare has been told that discharge is planned, but they have questions or concerns related to the discharge process. IADA clarifies discharge plans and supports communication between the patient and hospital staff to ensure concerns are acknowledged. It's important to note that IADA is not an appeal. In addition, it does not affect appeal rights or deadlines and does not include clinical review, medical record review, determinations of medical necessity, or changes to discharge timing.

Patients or their representatives may request IADA by contacting Acentra Health, the BFCC-QIO, using the contact information provided on hospital discharge notices, or through the BFCC-QIO helpline.

For more information, watch our video, Immediate Advocacy Discharge Assistance Process

Hospital Observation Appeals

The Final Rule for Hospital Observation Appeals, published by CMS, introduces the process by which eligible Medicare Fee-for-Service (FFS) beneficiaries can appeal hospital decisions to reclassify their status from inpatient to outpatient receiving observation services.

  • CMS has published a fact sheet (PDF) regarding this rule.
  • Hospitals must deliver the Medicare Change of Status Notice (MCSN) to all beneficiaries eligible for this expedited determination process. Please see: New Notice & Appeals Process for Original Medicare Beginning February 14, 2025.
  • Medicare Change of Status Notice (MCSN) Manual Instructions (PDF) (November 2024)
  • Billing Instructions: Expedited Determinations Based on Medicare Change of Status Notifications (PDF) (December 2024)
  • Hospitals with questions about the new Hospital Observation Appeal process, should send a message to CMS at the following email: HospitalStatusQIOappeal@cms.hhs.gov

Updating Appeals Forms

  • We encourage providers to update their notices – the Important Message from Medicare (IM) and the Notice of Medicare Non-Coverage (NOMNC) – by changing “Kepro” to “Acentra Health” when convenient. Notices will not be made invalid if they have “Kepro” listed.  Copies of these forms can be found on the BNI page on the CMS web site.
  • Please be sure you are using the most updated notices (the Notice of Medicare Non-Coverage and the Detailed Explanation of Non-Coverage), which were last updated in January 2025. The updated notices, including Spanish versions, are available on the FFS & MA NOMNC/DENC page on the CMS website.
  • View our YouTube Videos, How to Complete the Important Message from Medicare and How to Complete the Notice of Medicare Non-Coverage, for details about completing and delivering the forms.

NOTE: If Acentra Health receives a NOMNC on the old form on or after January 1, 2025, the form will NOT be made invalid.

CMS Final Rule

On November 27, 2006, CMS published a final rule, CMS-4105-F: Notification of Hospital Discharge Appeal Rights. Beginning July 1, 2007, hospitals must deliver the Important Message from Medicare (IM) to inform all Medicare inpatients, including Medicare Advantage enrollees, Medicare as a Secondary Payor (MSP), and dual-eligible patients about their hospital discharge appeal rights.

Hospitals are required to give a Detailed Notice of Discharge (DND) to patients who choose to appeal a discharge decision. The DND outlines the specific reasons for discharge and applicable Medicare coverage guidelines.

Current versions of the Important Message from Medicare (IM), Form CMS-10065, and the Detailed Notice of Discharge (DND), Form CMS-10066, are posted on the Hospital Discharge Appeal Notices page of the CMS website under Downloads.

Hospital Requested Review (HRR)

HINN 10, or the Notice of Hospital Requested Review (HRR), is issued by hospitals when they request a Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO) review of a discharge decision without a physician's agreement. It applies to both Original Medicare beneficiaries and Medicare Advantage enrollees.

To initiate an HRR, the hospital staff should call Acentra Health, and then electronically send the medical record. HRRs are completed Monday to Friday and will be completed within two business days of the receipt of all pertinent information requested.

Expedited Determinations

Home health agencies (HHAs), skilled nursing facilities (SNFs), comprehensive outpatient rehabilitation facilities (CORFs), and hospices with patients that have Medicare are required to notify them of their right to an expedited review process when these providers anticipate that Medicare coverage of their services will end.

HHAs, SNFs, hospices, CORFs, and swing beds (under instruction) are required to provide a Notice of Medicare Non-Coverage to Medicare patients (including those patients with a Medicare Advantage plan) to alert them that a Medicare-covered item or service is ending and give patients the opportunity to request an expedited determination from a BFCC-QIO. A Detailed Notice is given when the BFCC-QIO review is requested in order to provide more explanation on why coverage is ending.

Related Links

  • Overview
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  • Medical Record Electronic Submission
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  • Update Your Contact Information
  • Become a Peer Reviewer
  • Case Status Check

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