Denials and Appeals in Medicaid Managed Care

macpac on PayerIndex
Our Take: A March 2024 MACPAC report finds that Medicaid managed care beneficiaries rarely appeal denials, and that states lack the data infrastructure needed to monitor whether denials are clinically appropriate or to publicly report plan denial and appeals outcomes. For skilled nursing facilities serving dual-eligible and Medicaid managed care patients, the absence of state-level oversight and transparency around denials reinforces the need for proactive internal tracking of denial patterns and consistent appeals to protect access and revenue. ▼

SNFs with Medicaid managed care contracts should not assume that state agencies are monitoring inappropriate denials — MACPAC confirms that federal rules don’t require it. Developing facility-level data on denial rates and appeal outcomes by plan gives SNFs the evidence needed to renegotiate contracts, escalate concerns to state regulators, and build the case for clinical appropriateness.


Denials and Appeals in Medicaid Managed Care

Chapter 2 looks at the monitoring and oversight of denials and appeals in Medicaid managed care and the beneficiary experience with the appeals process. Beneficiaries appeal few denials, and program operators do not collect comprehensive information about denials in Medicaid managed care. Federal rules do not require states to collect and monitor data needed to assess access to care, monitor the clinical appropriateness of denials, or require that states publicly report information on plan denials and appeals outcomes.

This chapter lays out the current federal requirements for the appeals process as well as for monitoring, oversight, and transparency; elaborates on state flexibilities within the current federal framework; and describes key challenges with the current structure. The Commission makes seven recommendations to improve the appeals process and enhance monitoring, oversight, and transparency efforts.

— MACPAC, March 2024

Raible, M. “Denials and Appeals in Medicaid Managed Care.” MACPAC, Mar. 2024. https://www.macpac.gov/publication/denials-and-appeals-in-medicaid-managed-care-5/.

More Posts Like This One

Find More Medicare Advantage Resources