Optum Comprehensive Payment Integrity (CPI)
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Describes the Optum CPI pre-pay claim editing process for facility and professional claims for Arizona Complete Health (Centene-affiliated), including medical record requests, review, denials, and dispute rights affecting providers who submit claims.
No material clinical or coverage changes in this revision.
Documentation & Coverage Criteria
Support and documentation requirements
Claims may be denied or adjusted if medical records do not support billed services or are not received; submission of records does not guarantee payment.
ALL of the following
- Providers should submit requested records to the address or method specified in the MRR within 30 calendar days of the MRR date.
- Specific provider contract timeframes may apply and supersede this timeframe where applicable.
ALL of the following
- Submitted or resubmitted records that are incomplete, missing pages, or lack sufficient detail (e.g., missing E/M notes, treatment information, unit documentation, time records) may result in inability to verify billed charges and lead to denial.
- If Optum does not receive the requested records, Optum will make a determination based on available information which may result in the claim being denied or the denial being upheld. If records are not received by 120 days after initial request, a denial letter may be issued.
ALL of the following
- Upon receipt, Optum will review medical records (target ~7 business days) and trained coding professionals will determine whether billed services are supported.
- The provider's submission of records is not a guarantee of payment; Optum makes a recommendation to the Health Plan to pay, deny, or replace billed services based on documentation. Providers will receive a detailed Optum letter explaining denial rationale if payment is denied.
ALL of the following
- Patient demographics and date(s) of service must match the claim.
- Units, modifiers, CPT/HCPCS codes, place of service, and provider signature/attestation (including signature date within 30 days of service) must be supported in the record (some items not in scope for inpatient review).
ALL of the following
- MRR will include directions for submission (secure internet upload, mail, or physical media) and contact information; follow the MRR instructions.
ALL of the following
- Providers have dispute rights for denials; Optum/Centene processes disputes per plan procedures.
ALL of the following
- Submission of records does not constitute medical necessity determination; Optum may deny services not supported by documentation even if prior authorization exists.
ALL of the following
- Provider response: 30 calendar days to submit records from MRR.
- Optum review target: within 7 business days after receipt.
- If no records received by 120 days, denial letter may be issued.
ALL of the following
- If payment of the claim line is denied, providers will receive a detailed letter from Optum and Centene will also send denial explanations via EOP.
ALL of the following
- Providers should maintain and submit complete records to avoid denials or adjustments; failure to provide adequate documentation can result in claim denials, adjustments, or referral for further investigation.
ALL of the following
- Trained coding professionals examine documentation and recommend pay/deny/replace to the Health Plan based on whether records support the billing.
ALL of the following
- Submission of records does not guarantee payment and Optum may deny billed services not supported by records. Specific contract timeframes may apply.
ALL of the following
- Follow contact and submission instructions included in the MRR (see MRR for secure upload URL and PIRT contact information).
Documentation and administrative rules
Policy governs documentation required for payment review and clarifies legal and administrative hierarchy.
ALL of the following
- This payment policy is a guide to payment and a component of the guidelines used to assist in coverage and payment determinations; it is not a contract or guarantee regarding payment or results. Coverage and payment determinations are subject to plan documents and applicable law.
ALL of the following
- If state Medicaid provisions conflict with this payment policy, state Medicaid provisions take precedence.
- For Medicare members, applicable National Coverage Determinations (NCDs) and Local Coverage Determinations (LCDs) should be reviewed prior to applying this policy.
ALL of the following
- This payment policy is the property of Centene Corporation; unauthorized copying, use, or distribution is prohibited.
ALL of the following
- Provide specified complete documentation upon request, including but not limited to physician office records, orders, plans of care and recertifications signed by a qualified provider, pre/post-operative notes, therapy documentation/logs with minutes, test results, OASIS for home health (with required fields), UB-04/HCFA 1500 forms, anesthesia and operative reports, consults, discharge summaries, lab/pathology reports, medication administration records (including NDCs), and other items listed in the MRR.
ALL of the following
- All six digits of the diagnosis code must exactly match between fields as documented; OASIS fields M2200 and M0110 cannot be blank or contain 'N/A'.
- Corrections to OASIS must be applied by the end of the episode.
ALL of the following
- Providers are expected to exercise professional medical judgment in providing care and are solely responsible for medical advice and treatment; submission of records and the policy do not substitute for clinical decision-making.
ALL of the following
- When requested, provide complete and signed documentation as specified in the MRR; incomplete documentation is a common reason for denial.
ALL of the following
- The payment policy is effective as determined by the Health Plan; Health Plan may change, amend, or withdraw the policy as needed, subject to law and regulation.
ALL of the following
- Providers, members and their representatives are bound to the terms and conditions through their contracts; where no contract exists, providing services or submitting claims constitutes agreement to be bound.
ALL of the following
- See the additional documentation section and the MRR for the specific list of document types that may be requested; the list in the policy is illustrative and not exhaustive.
Codes, Coding Rules & Guidance
| All ICD-10-CM, CPT, HCPCS, and DRG codes are eligible for claims editing as described according to State and/or CMS Guidelines. |
| diagnosis codes | All six digits of the diagnosis code must exactly match between fields; OASIS Fields M2200 and M0110 cannot be blank or contain N/A; corrections to OASIS must be applied by the end of the episode. |
Provider Submission, Requests & Disputes
Medical records request (MRR) — follow submission instructions and timelines
Optum will generate a medical records request (MRR) letter and send it directly to providers; the MRR will include directions on how or where to submit records. Providers must submit requested records via the methods specified in the MRR (secure internet upload, U.S. Mail, or CD/DVD). Secure internet upload URL: https://paymentintegrityportal.optum.com/upload; cover sheet instructions apply for hard copy submissions but are not required for secure upload. Providers are expected to respond promptly — initial response timeframe is 30 days; Optum will send a reminder if no response, and a denial letter will be issued if records are not received within 120 calendar days.
- Submit records via secure internet upload per MRR instructions: https://paymentintegrityportal.optum.com/upload
- Hard-copy submissions use the address in the MRR (OPTUM 458 Pike Road Huntingdon Valley, PA 19006) or carrier specified (FedEx, UPS); organize records behind the barcoded cover sheet unless using secure upload
- Respond within 30 days of the MRR; a follow-up reminder is sent if no response
- If records are not received within 120 calendar days, a denial letter will be issued (technical denial) and the claim may remain denied until records are submitted
Dispute rights and escalation — Optum first-level, Centene second-level
Providers have the right to dispute denials. Optum conducts the first-level dispute for CPI denials; if still disputed, Centene performs the second-level review and provides instructions for further appeals per the health plan's Quick Reference Guide or Provider Manual.
- If a claim line is denied after record review, provider receives a denial letter with rationale and first-level dispute instructions
- Optum will acknowledge and respond to first-level disputes and provide instructions for submitting a second-level dispute to Centene
- If disagreement remains after Centene's second-level review, follow the health plan QRG/Provider Manual for additional appeal options
Provide complete physician records and specified documentation for payment review
When requested for payment review, providers must supply complete physician office records and the specific documentation types listed in the MRR, including plans of care, physician orders, pre/post‑operative notes, therapy documentation, test results, OASIS for home health (with required fields completed), UB-04/HCFA 1500 forms, and others.
- Physician office records: office visit documentation, demographic/face sheet, history, lab and procedure results, correspondence and consult reports
- Plans of care (POC), treatment plans, evaluations, updates and recertifications — POC and recertifications should be signed by a qualified healthcare provider
- Preanesthetic evaluation; preoperative and postoperative notes; prescriptions; progress and psychiatric evaluation notes
- Therapy documentation (skilled nursing, PT, OT, ST, respiratory therapy, MSW) including notes and therapy logs with minutes provided
- Test orders/results/reports (pathology, radiology, laboratory) and toxicology reports
- OASIS for home health claims — Fields M2200 and M0110 cannot be blank or contain N/A; any correction must be applied by the end of the episode
- Uniform Billing form (UB-04) / HCFA 1500
Terms & Process Definitions
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