How to Appeal a Hospital Discharge Under Medicare: The QIO Fast-Appeal Process

The case manager just told you your parent is being discharged tomorrow. Your parent cannot walk to the bathroom without help, there is no one at home trained in wound care, and the home safety equipment has not arrived. You know this is not safe.

You may be able to challenge it through Medicare's fast-appeal process. Here is exactly how the process works, the deadlines you cannot miss, and the words to say on the phone.

Your Parent's Right to Appeal

Every Medicare beneficiary has the right to appeal a hospital discharge. The signed Important Message from Medicare (IM) is the key document for an inpatient fast appeal and lists the BFCC-QIO contact information.

"An Important Message from Medicare" (IM notice): Given at admission and again at discharge. This document lists the phone number for the Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO) that handles appeals in your state.

"Detailed Notice of Discharge" (DND): If issued during the review, this notice explains why the hospital believes continued inpatient care is no longer necessary.

If you did not receive the IM, ask the charge nurse or patient advocate immediately. The IM includes the information needed to start the appeal.

The Fast-Appeal Timeline

This is a same-day process. Timing is everything:

File before midnight on the planned discharge day. Call the BFCC-QIO listed on your IM notice. Currently, two organizations handle all Medicare discharge appeals nationally:

• Commence Health (formerly Livanta) — covers most states
• Acentra — covers remaining states

You can find which organization covers your state by calling 1-800-MEDICARE (1-800-633-4227).

What happens when you file:

1. The hospital must provide your parent's medical records to the QIO within 24 hours
2. A physician reviewer at the QIO evaluates whether the discharge is medically appropriate
3. The QIO issues a decision by noon the next day
4. After filing, inpatient care remains without patient charge until at least noon the day after the QIO decision.

This is the critical point families miss: filing by the deadline preserves the applicable cost protection while the QIO review proceeds. The fast appeal has a $0 fee.

What to Say on the Phone

Call the QIO and say:

"I am calling to file an expedited appeal of a hospital discharge under Medicare. My parent's name is [name], their Medicare Beneficiary Identifier is [MBI number], and the hospital is [hospital name]. The discharge is planned for [date]. I believe this discharge is unsafe because [specific clinical reasons]."

Specific clinical reasons that strengthen an appeal:

• No trained caregiver available at home to provide required care
• Home safety equipment (hospital bed, wheelchair ramp, grab bars) has not been delivered
• Wound care requires skilled nursing that home health has not yet been set up to provide
• Cognitive changes (delirium, confusion) make the patient unable to safely manage at home
• Fall risk is high and the home has not been modified
• Follow-up appointments have not been scheduled and critical medication changes have not been reconciled

You do not need a lawyer. You do not need medical training. Anyone acting in good faith on behalf of the patient can file.

If the Appeal Is Upheld or Denied

If the QIO upholds the appeal, your parent remains within the applicable protected period. For an inpatient appeal, patient cost remains $0 until at least noon the day after the QIO decision.

If the QIO denies the appeal, follow the QIO's instructions for further review and the applicable cost-protection dates in the notice.

More immediately, use the protected period identified by the QIO to:

• Get home health services in place (call the agency directly, do not wait for the hospital coordinator)
• Confirm durable medical equipment delivery
• Complete essential home safety modifications
• Schedule the 7-day primary care follow-up
• Set up the medication system

Skilled Nursing Facility Discharges Work Differently

If your parent is being discharged from a skilled nursing facility (SNF), home health agency, or hospice rather than a hospital, the timeline is different:

File by noon on the day before services are scheduled to end. The hospital deadline is midnight; the SNF/home health/hospice deadline is noon the day before. The document you need is the "Notice of Medicare Non-Coverage" (NOMNC), not the IM notice.

The QIO evaluates the appeal and there is no fee to file. For SNF, HHA, and hospice, patient cost remains $0 until the service termination date listed on the NOMNC; follow the QIO's instructions for any further review.

The Rehab and Recovery at Home Toolkit includes the complete discharge appeal process with word-for-word scripts, QIO contact information, and a pre-discharge safety checklist to ensure your parent's home is ready before they leave the hospital.