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    OpenPayerPolicy UpdatesAdministrative/Operational PolicyCenCal Health Appeals Policy Update | OpenPayer
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    CurrentCenCal HealthPolicy MS-23

    Member Appeals of Adverse Benefit Determinations

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    Governs CenCal Health’s intake, documentation, review, resolution, notification, and continuation-of-benefits processes for Member Appeals of adverse benefit determinations.

    Policy Summary
    PayerCenCal Health
    PolicyMember Appeals of Adverse Benefit Determinations
    Policy CodePolicy MS-23
    Change TypeAdministrative and compliance updateno material clinical or coverage changes
    Effective DateJul 1, 2023
    Last ReviewOct 1, 2024
    Next Review DateN/A
    Key ActionProviders must obtain the Member’s required written consent before filing an Appeal on the Member’s behalf.
    SourceLink
    POLICY UPDATE CHANGES

    No material clinical or coverage changes in this revision.

    60 daysAppeal filing deadline
    30 daysStandard resolution
    72 hoursExpedited resolution
    5 daysWritten acknowledgement
    2 business daysInitial documentation forwarding

    Member Appeal Eligibility and Review Criteria

    General Appeal eligibility

    A Member Appeal may be initiated when the Member or authorized representative disagrees with a benefit-related decision associated with an NOA or NABD.

    ALL of the following

    • Appeal concerns a CenCal Health benefit-related decision or adverse prior authorization determination associated with an NOA or NABD
    • Filed by one of the following

      • Appeal is filed by the Member or an appointed representative authorized by the Member
      • Appeal is filed by a provider on the Member's behalf with the Member's participation and required written consent
    • Appeal is filed within 60 calendar days from the date on the NOA or NABD

    Clinical and expedited review criteria

    Clinical Appeals are routed for clinical review, and expedited handling is available when the request meets DHCS criteria.

    ANY of the following

    • ALL of the following

      • The Appeal requires clinical review
      • The Clinical Quality Nurse assembles the required documentation packet for a qualified physician reviewer
    • ALL of the following

      • Member or provider requests expedited handling; a provider request must include the Member's written consent
      • The Chief Medical Officer or Medical Director determines that the request meets DHCS expedited criteria
      • The expedited Appeal is resolved within 72 hours, or 3 calendar days

    Member procedural protections

    Members retain the following procedural protections during the Appeal.

    ALL of the following

    • Member receives information about continuation of benefits or Aid Paid Pending when applicable
    • Member receives a written resolution explaining the Plan's decision and rationale; for a clinical Appeal, the notice includes the specific criterion or an excerpt of the criterion used
    • Member is informed of the right to reasonable access to, and copies of, documents relevant to the Appeal at no cost, subject to applicable HIPAA requirements
    • Member is informed of the right to request the actual benefit provision, guideline, protocol, or other criterion used for the decision, and a list of the titles and qualifications of individuals who participated in the review
    • Final notice includes the Member's right to request a State Fair Hearing

    Pharmacy benefit Appeal routing

    Medi-Cal pharmacy benefit Appeals are generally outside CenCal Health's Appeal process, except for Physician Administered Drugs.

    ANY of the following

    • Service is a Physician Administered Drug and the Appeal remains within CenCal Health's process
    • ALL of the following

      • Appeal concerns another Medi-Cal pharmacy benefit
      • Appeal is adjudicated through the Medi-Cal Rx State Fair Hearing process
      • Member or appointed representative may contact the Medi-Cal Rx Customer Service Center for questions, clarification, or to provide additional information

    Specialized Appeal pathways

    Specialty mental health and experimental or investigational Appeals follow specialized routing or procedural requirements.

    ANY of the following

    • ALL of the following

      • Appeal pertains to specialty mental health services
      • Appeal is forwarded to the applicable county behavioral health entity
    • Appeal concerns mild-to-moderate behavioral health services and is initiated and investigated by CenCal Health
    • ALL of the following

      • CenCal Health has denied a treatment, procedure, or service as experimental or investigational in a Knox-Keene licensed program
      • ANY of the following

        • Member requests a face-to-face meeting or hearing with CenCal Health's Medical Director or physician designee within 5 calendar days
        • Member requests Independent Medical Review; the Member is not required to file an Appeal with CenCal Health first

    Appeal Coding and Required Timeframes

    Clinical versus non-clinical Appeal codingmixed
    No codes listed
    TARs and RAFs are treated as prior authorizations requiring clinical-necessity review when associated with an adverse benefit determinationmixed
    No codes listed
    Appeal filing deadline
    Filing periodWithin 60 calendar days from the date on the NOA or NABD.
    Who may fileThe Member or an appointed representative may file the Appeal; a provider may file with the Member's participation and written consent.
    Continuation informationCenCal Health advises Members how to continue benefits during the in-plan Appeal process through the State Fair Hearing, when applicable.
    Initial documentation forwarding
    Standard forwarding deadlineForward initial Appeal documentation to clinical reviewers within 2 business days of receipt.
    Expedited requestsForward documentation for an expedited Appeal immediately.
    Documentation reviewedThe process supports review of medical records, chart notes, and associated documentation by the Plan's physician reviewer.
    Standard Appeal evidence submission
    Member submissionsMembers may submit evidence, testimony, arguments, comments, documents, or other information in support of an Appeal.
    Submission timingAdditional information may be submitted at any time during the applicable review timeframe.
    Review timeframesThe standard review timeframe is 30 calendar days; expedited Appeals are reviewed within 72 hours when accepted.
    Expedited Appeal resolution
    Qualifying requestAn expedited request must meet DHCS criteria as determined by the Chief Medical Officer or Medical Director.
    Resolution deadlineA qualifying Expedited Appeal must be resolved within 72 hours, or 3 calendar days.
    Nonqualifying requestA request that does not meet expedited criteria follows the standard 30-day Appeal process, with verbal and written notification of the downgrade.
    Appeal acknowledgement
    Acknowledgement deadlineCenCal Health provides written acknowledgement within 5 calendar days of receiving the Member's Appeal.
    Acknowledgement contentsThe acknowledgement identifies the receipt date, summarizes the issue, and advises that the issue will be resolved within 30 calendar days.
    Contact informationThe acknowledgement includes the Grievance and Appeals Coordinator's name, phone number, and the Plan address.
    Final Appeal resolution
    Written decision deadlineCenCal Health issues the written Appeal decision no later than 30 calendar days from receipt.
    Decision explanationThe written resolution provides a clear and concise explanation of the Plan's decision.
    Clinical Appeal detailFor a clinical Appeal, the final letter includes the specific criterion used, or an excerpt of that criterion, and the credentials, titles, and specialties of participating reviewers.
    State Fair Hearing after Plan failure
    Hearing deadline after Plan failureIf CenCal Health fails to meet the required Appeal timeframes, the Member may initiate a State Fair Hearing within 120 calendar days of the failure.
    Hearing deadline after resolutionWhen disagreeing with a denial, termination, or modification, the Member may request a State Hearing within 120 calendar days from the Notice of Appeal Resolution date.
    Deemed exhaustionThe 120-day period may run from the applicable missed deadline or from receipt of a deficient written NAR or NOA.
    Experimental or investigational face-to-face review
    Program applicabilityThis face-to-face review process applies to CenCal Health's Knox-Keene licensed programs.
    Meeting deadlineA Member may request a face-to-face meeting or hearing with the Medical Director or physician designee within 5 calendar days.
    Independent Medical ReviewThe denial is subject to the Independent Medical Review process, and the Member is not required to file a Plan Appeal first.

    Operational Requirements for Providers and Staff

    Documentation Required

    Provider-Filed Appeal Consent

    A provider may file an Appeal on a Member’s behalf only with the Member’s participation and written consent authorizing the provider to act. The Appeal will not be initiated until the signed consent is received.

    • Obtain written Member consent before initiating a provider-filed Appeal.
    • A Member may also appoint a representative with verbal authorization or an Appointment of Representative Form.
    Documentation Required

    Provider Documentation for Appeal Review

    For clinical Appeal review, provide complete and pertinent documentation so the physician reviewer can evaluate the request, including the original denial and Appeal history, current medical records, provider responses, and prior actions related to the denial.

    • Medical records, chart notes, and associated clinical documentation.
    • Dates of service and other information requested to validate the Appeal.
    • Previous denial and Appeal history, current provider responses, and any prior actions taken.
    Prior Authorization

    Prior Authorization Adverse Determination Review

    CenCal Health initiates Appeals involving coverage disputes or requests to reverse a prior authorization decision for medical necessity when the matter is associated with a Notice of Action (NOA) or Notice of Adverse Benefit Determination (NABD). Prior authorizations resulting in an adverse determination, including TARs and RAFs, are automatically treated as requiring clinical review and are referred to a physician reviewer who was not involved in the original decision.

    • Submit the clinical records and supporting information needed to review the prior authorization dispute.
    • The initial review follows the applicable pre-service review and timeliness requirements.
    Note

    Independent Physician Reviewer Required

    The physician reviewer must be independent of the initial review and any prior decision. The reviewer may not be the original reviewing physician and may not be subordinate to a physician who participated in the initial review or decision.

    • Use a different physician for the Appeal review.
    • The reviewer may consult a practitioner in the same or a similar specialty who typically treats the condition.

    Unsupported block type: prior_auth

    Note

    Implement a Favorable Appeal Decision

    When an Appeal decision is favorable, Medical Management UM, CM, or the clinical designee must approve the service authorization in the Health Information System on the same business day and coordinate implementation with the G&A Coordinator.

    • Ensure services are scheduled as promptly as the Member’s condition requires and no later than 72 hours from the overturned decision.
    • Coordinate with the appropriate physician, facility, or pharmacy when services are needed within 72 hours.
    Note

    Route Medi-Cal Rx Pharmacy Appeals

    CenCal Health does not process pharmacy-benefit Appeals except for Physician Administered Drugs (PADs). Route other Medi-Cal Rx pharmacy Appeals to the Medi-Cal Rx Customer Service Center through Magellan Rx.

    • Transfer the Member or appointed representative to 1-800-541-5555; TTY 1-800-430-7077.
    • Medi-Cal Rx pharmacy Appeals use the DHCS State Fair Hearing process; contact with the Customer Service Center does not affect the right to request a State Hearing.
    • CenCal Health may provide Magellan Rx with requested assistance but does not resolve these Appeals.
    Note

    Route Mental and Behavioral Health Appeals

    Immediately forward specialty mental health Appeals to the applicable county mental health entity and advise the Member. CenCal Health staff initiate and investigate mild-to-moderate behavioral health Appeals and enter them in the online tracking system.

    • Forward specialty mental health Appeals to Santa Barbara County Behavioral Wellness Department or MHS-SLO, as applicable.
    • Offer a warm transfer and explain that the Appeal is being forwarded for resolution.
    • Forward documentation and summaries to the appropriate entity; the county QA Manager acknowledges receipt within one business day.
    Prior Authorization

    Process Expedited Appeals

    Expedited Appeal requests must be reviewed immediately and resolved within 72 hours (three calendar days) when DHCS expedited criteria are met. The G&A Coordinator immediately forwards the request to the Clinical Quality Nurse and Chief Medical Officer or Medical Director for criteria review.

    • Prepare the clinical review packet and physician review summary without delay.
    • Provide the outcome to the requestor within the 72-hour allowable review period.
    • The physician reviewer must be independent of the initial reviewer and any prior decision-maker.
    Note

    Process Favorable Appeal Decisions

    For a favorable Appeal decision, ensure the authorization is entered in the Health Information System the same business day and coordinate prompt implementation of the approved service.

    • Coordinate scheduling with the G&A Coordinator and the appropriate physician, facility, or pharmacy.
    • Services must be scheduled as promptly as the Member’s condition requires and, after an overturned decision, within 72 hours.
    Note

    Notify the Member of Appeal Disposition

    Notify the Member or appointed representative of the Appeal disposition by telephone when required and in writing using the required Notice of Appeal Resolution (NAR) or other mandated language. Written decisions must be mailed within the applicable timeframe, and expedited outcomes must be communicated within 72 hours.

    • Explain the decision and the criteria used to make it clearly and concisely.
    • Provide oral and written notification for expedited outcomes; send the written notification by certified U.S. mail.
    • Provide required language, accessibility, nondiscrimination, translation, and language-assistance information.
    Note

    Process Expedited Appeal Determinations

    Within 72 hours of receiving an Expedited Appeal, the Clinical Quality Nurse notifies the G&A Coordinator of the physician reviewer’s or designee’s determination. The G&A Coordinator then notifies the Member by telephone and in writing in a clear and concise manner.

    • Communicate whether the request met expedited criteria and the outcome of expedited review.
    • Send the written notice by certified U.S. mail.
    • If the request does not meet expedited criteria, initiate standard 30-day Appeal review.
    Note

    Convert Nonqualifying Expedited Requests to Standard Review

    If an Expedited Appeal request does not meet DHCS criteria, convert it to the standard 30-day Appeal process. Notify the requestor verbally, followed by written notice that the request was downgraded, and advise the Member of the right to file a Grievance regarding the downgrade.

    • Initiate standard review without delay.
    • Include the downgrade explanation in the acknowledgment or written notice.
    Note

    Provide Further Appeal Rights

    Notify the Member in the NAR that they may request a Department of Social Services State Hearing if they disagree with a denial, termination, or modification of a prior authorization service request.

    • The Member may request a State Hearing within 120 calendar days from the date of the NAR letter.
    • Include the DSS “Your Rights” enclosure and DHCS-approved instructions for requesting a State Hearing.
    • In deemed-exhaustion cases, provide the applicable 120-day period measured from the missed or deficient notice timeframe.

    Unsupported block type: prior_auth

    Documentation Required

    Quality Review Final Appeal Notices

    The G&A QI Manager reviews every final Appeal letter before issuance to confirm that it clearly explains the decision and identifies the criteria used to make the determination.

    • Complete QI Manager review and approval for all final Appeal correspondence.
    • Ensure required mandated language and culturally and linguistically appropriate notice requirements are included.

    Key Appeal Terms

    Adverse Benefit Determination / Notice of Action
    Notice meaningAn Adverse Benefit Determination or Notice of Action is the Plan notice associated with a benefit-related decision that may be appealed.
    Covered decisionsThe notice may involve a coverage dispute or an adverse prior authorization decision involving medical necessity.
    Appeal periodA Member may appeal the NOA or NABD within 60 calendar days from the date on the notice.
    Appointed representative
    DefinitionAn appointed representative is a person authorized by the Member to act on the Member's behalf in an Appeal.
    Minimum authorizationThe Member must provide at least verbal authorization for the representative to act.
    Written documentationThe Member may complete and submit an Appointment of Representative Form when it is not already on file with the Plan.
    Expedited Appeal
    DefinitionAn Expedited Appeal is a request requiring immediate review because it may meet DHCS expedited criteria.
    Resolution timeframeIf accepted, the request must be resolved within 72 hours, or 3 calendar days.
    Standard conversionIf the request does not meet expedited criteria, it follows the standard 30-day Appeal process and the requestor receives verbal and written notice of the downgrade.
    Non-clinical Appeal
    DefinitionA non-clinical Appeal concerns an administrative matter, such as a billing dispute or non-clinical out-of-network service.
    Initial pathwayThe Clinical Quality Nurse reviews the documentation and verifies that the Appeal has no clinical component within 2 business days of receipt.
    Review authorityThe Member Services Grievance-QI Manager completes the non-clinical review, documents the issues and findings, and follows up when necessary.
    Medi-Cal Rx
    DefinitionMedi-Cal Rx is the California Department of Health Care Services pharmacy program that assumed grievance and Appeal responsibilities for Medi-Cal pharmacy benefits other than Physician Administered Drugs.
    CenCal Health exceptionCenCal Health continues to process pharmacy benefit Appeals for Physician Administered Drugs.
    Other pharmacy AppealsOther Medi-Cal pharmacy Appeals proceed through the DHCS State Fair Hearing process, and Members may contact the Medi-Cal Rx Customer Service Center.
    Department of Social Services (DSS)
    DefinitionThe Department of Social Services is the county agency that determines eligibility for public assistance programs.
    ProgramsPrograms include Medi-Cal, CalWORKs, Aid to Families with Dependent Children, CalFresh, and general assistance.
    Appeal roleDSS is identified in connection with State Hearing rights for Members who disagree with a Plan denial, termination, or modification of services.
    Policy Summary
    PayerCenCal Health
    PolicyMember Appeals of Adverse Benefit Determinations
    Policy CodePolicy MS-23
    Change TypeAdministrative and compliance updateno material clinical or coverage changes
    Effective DateJul 1, 2023
    Last ReviewOct 1, 2024
    Next Review DateN/A
    Key ActionProviders must obtain the Member’s required written consent before filing an Appeal on the Member’s behalf.
    SourceLink
    On This Page
    Member Appeal Eligibility and Review CriteriaAppeal Coding and Required TimeframesOperational Requirements for Providers and StaffKey Appeal Terms

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