Insights · Medicare

Medicare Advantage Appeals Deep Dive

An analysis of Medicare Advantage denial and appeals patterns across payers — who gets denied, who appeals, and who wins.

Overview of findings

Medicare Advantage payers process 50M+ prior auth and potentially deniable claims per year. Of the 50M+, only 7% tend to be denied and only 10% of the denied tend to be appealed (i.e., ~0.7% of all claims are appealed).

Finding #1: Appealed claims tend to be overturned or upheld at a 40-50% either direction.

Opportunity: Suggesting a real opportunity for payers to tighten their initial determination

Overall, less than 0.3% of the claims make it to an independent review process despite CMS mandating that claims appealed and not overturned get reviewed through the IRE. A key driver of this low volume in IRE can be attributed to the low rate of appeals (<10% of denied claims).

Furthermore, this independent review process tends to significantly favor the original determination by the payer– with historical rates of overturns hovering around 3-5%, with most recent data in 2023 suggesting a 3% rate. This suggests that the appeal process by payers is, on an aggregate, thorough.

That said, the IRE overturn volume is significant for payers to (1) optimize their Stars measures (in particular, C29 measure), and (2) understand where the most debate between payers and providers in the appeals process lays, pointing to two key signals:

Finding #2: ER, Therapies, Nursing Care and Clinical / Lab services tend to be the most contended services.

Opportunity: Payers should adopt better Medicare-aligned policies and tighten their adjudication process in this area

Finding #3: Amongst payers, there is a significant variation within payer overturn rates (e.g., Highmark and Elevance are ~1% overturns, whereas other Blues, Centene and CVS are 4-5% overturns)

350K+ claims are appealed annually; 190K are not overturned and referred to independent review

Claims and denials

50M

Claims

3.5M

Denials

~50M+ prior auth and claims are reviewed per year by MA payers

Of these ~7% are denied by payers

Appeals process

350K

Appeals

160K

Payer
overturns

190K

Indep.
reviews

~10% of denials are appealed

~46% of appeals overturned by the payer

54% of are upheld and go to an independent review

Amongst the independently reviewed, the majority rule in favor of the payer

Independent review by CMS vendor, 2023 all MA

171.9K
97%
5.4K
3%
In favor of payer
In favor of provider

Overturns in favor of provider (%)

Recently, only 3% of independent reviews get overturned in favor of the provider

This suggests an overall thorough first review is happening by payers on an aggregate

This rate of independently reviewed overturns has remained relatively consistent with time

Overturns by year, (% of all indep. reviewed appeals)

Rate of overturns vary by service category; with ER, labs and nursing home care standing out

Appeals by service and % of overturns by the IRE

Loading chart...
Appeals by service category showing percentage of overturns by the IRE

Total volume of IRE reviews, 2023

Service Category Insights

Different service categories tend to have widely different overturn rates

Highest rates:

ER:3.98%
Labs:4.29%
Therapies:3.59%
Nursing care:3.54%

Lowest rates:

Hospice:0.66%
Benefits:2.08%

Payers also tend to a large variation in their overturn rate

Rulings in favor of provider, as a % of all independent reviews

National average 2.8%

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