Claims Disputes and Appeals - Capitation and/or Delegation Supplement, 2018 UnitedHealthcare Administrative Guide

Contracted care providers who have a claim dispute with a delegated medical group/IPA must make sure they have followed all the guidelines set forth by the medical group/IPA prior to rendering services to a UnitedHealthcare member.

You may request a reconsideration of a claim determination. These requests are typically resolved with the appropriate documents to support claim payment or adjustments (e.g., sending a copy of the authorization for a claim denied for no authorization or proof of timely filing for a claim denied for untimely filing).

You must submit requests within 365 calendar days following the date of the last action or inaction, unless your participation agreement contains other filing guidelines.

The most efficient way to submit your requests is through UHCprovider.com/claimslink, which also allows attachments.

A request for reimbursement for any overpayment of a claim completed in compliance with state and federal regulations must be handled as follows:

  • Request must provide a clear, accurate, written explanation
  • Request must be issued within 365 calendar days from the last date of payment for the claim
  • The care providers given 30 working days to send written notice contesting the request for reimbursement for overpayment

Non-Contracted Care Provider Disputes — CMS Non-Contracted Care Provider Payment Dispute Resolution Process (Applicable to Non-Contracted MA Paid Claims)
A non-contracted care provider can use the Payment Dispute Resolution (PDR) process for any decision where they contend that the amount paid by the organization, (in this instance the delegated entity), for a covered service is less than the amount which would have been paid under Original Medicare.

This process also includes disagreements between a non-contracted care provider and the delegate about the delegate’s decision to pay for a different service than that billed (i.e., bundling issues, rate of payment, DRG payment dispute). You must submit a payment dispute within 120 calendar days from the date of the original claim determination.

At a minimum, the delegate must have the following requirements and processes in place when handling claim payment disputes with a Medicare non-contracted care provider:

  • Well-defined internal payment dispute process that includes:
    • A system for receiving PDRs;
    • Proper identification of payment disputes. (Care providers must clearly state what they are disputing and why, supply relevant information that will help support their position, including description of the issue, copy of submitted claim, supporting evidence to demonstrate what Original Medicare would have allowed for the same service, etc.);
    • A system for tracking disputes; and
    • Monitoring their PDR claims inventory.
  • Establish and communicate the Timely Filing Limit of 180 calendar days from the original claim determination to the non-contracted care provider at time of claim payment;
  • Information on how to submit an internal claim payment dispute to the organization communicated to the noncontracted care provider at time of claim payment, including their mailing address for submitting disputes and other dispute information (e.g., email addresses, phone numbers);
  • Requirements to process and respond (i.e., to finalize the PDR claim) to the non-contracted care provider within 30 days from the date the PDR claim is received;
  • Help ensure correct calculation of interest payments on overturned PDRs . Interest payment is required on a reprocessed non-contracted care provider clean claim if the group made an error on the original determination. Interest is only applied on the additional amount paid, and calculated from the ‘oldest receive date of the original claim’ until the ‘check mail date’ of the additional amount paid;
  • Provide a complete and clear rationale to the noncontracted care provider for upheld PDRs;
  • Ensure that the care provider Remittance Advice (PRA) or Explanation of Payment (EOP), and Uphold PDR Determination Letter contains appropriate information and meets requirements;
  • Include information on how to contract the organization in notices of upheld or overturned payment disputes if the non-contracted care provider has additional questions;
  • Include information in the notices of upheld or overturned payment disputes on how to contract the organization if the non-contracted care provider has additional questions;
  • If the root-cause of overturned PDRs is system-related, a process in place to update their claims system, if needed, so that future claims will reimburse appropriately;
  • Process in place to identify trends that contract year for any non-contracted care provider who submitted a payment dispute to help ensure that they may be paid correctly;
  • Ongoing training program in place for any piece of the internal claim PDR process to include educating all areas of the organization, such as customer service, claims, appeals, etc.;
  • Consistent monitoring of internal compliance to help ensure CMS requirements are met; and
  • End-to-end quality review process, from the time a dispute is received from the non-contracted care provider to the time when the dispute decision is sent to the noncontracted care provider.

Forward second level disputes to UnitedHealthcare. Any materials that we request related to the dispute must be submitted by the delegated entities in a timely manner. This will help ensure all relevant documentation is considered.

We have 60 calendar days to review and respond to second level disputes.

The following are examples of issues excluded from the PDR process:

  • Instances in which a member has filed an appeal and you have filed a dispute regarding the same issue. In these cases, the member’s appeal takes precedence. You can submit a care provider dispute after the member appeal decision is made. If you are appealing on behalf of the member, the appeal processes as a member appeal.
  • An Independent Medical Review initiated by a member through the Member Appeal Process.
  • Any dispute filed outside of the timely filing limit applicable to you, and for which you fail to supply “good cause” for the delay.
  • Any delegated claim issues that have not been reviewed through the delegated payer’s claim resolution mechanism.
  • Any request for a dispute, which involves reviews by the delegated medical group/IPA/payer or capitated facility/care provider and does not involve an issue of medical necessity or medical management.

UnitedHealthcare West Delegated Care Provider Claims Appeals

California/Oregon/Washington: Updated versions of the Medicare Claims self-timeliness report (ICE Claims Medicare MTR) and the Commercial Claims self-timeliness report (ICE Claims Comm Mo Qtr.) found on the Iceforhealth.org website. The most current version of the form needs submission at all times. This applies to both Commercial and MA products.

The California Delegated Entity must submit the timeliness form via email to providerAuditClaimsReports@uhc.com. Monthly timeliness report submissions are due within 15 days from the end of the reporting month. Commercial quarterly reports must be submitted no later than the 30th day following the end of the quarter. Medicare quarterly report submissions are due by the 15th day, following the end of a quarter.

Maintain a copy of the reports for your records.

California: In accordance with state regulatory requirements, UnitedHealthcare shall verify on a quarterly basis that our Delegated Entities have the administrative and financial capacity to meet contractual obligations through routine reviews of financial indicators and monitoring financial solvency deficiencies.

UnitedHealthcare requires Delegated Entities to provide copies of quarterly financial statements, including a balance sheet, income statement and statement of cash flow, prepared in accordance with generally accepted accounting principles within 45 calendar days of the end of each calendar quarter.

Copies of assessed annual financial statements together with copies of all auditors’ letters to management in connection with such reviewed annual financial statements submissions are due within 150 calendar days of the end of each fiscal year. If the quarterly/annual financial statement submissions include deficiencies in financial solvency grading criteria defined by state regulations, a self-initiated Improvement Action Plan (IAP) proposal shall be submitted in an electronic format (template may be found on the Iceforhealth.org website) to UnitedHealthcare within 45 calendar days of the end of the reporting period for which the deficiency was reported.

In addition, quarterly progress reports need submission to UnitedHealthcare within 45 calendar days of the end of each subsequent reporting period until compliance with all financial grading criteria achievement.

The Delegated Entity must submit financial statements and IAPs via email to UnitedHealthcare at financialstatementsubmission@uhc.com. Both UnitedHealthcare and the delegated entity are responsible to provide compliance oversight of the Delegated Entities financial reporting IAP.

Other UnitedHealthcare West Delegated States (AZ/CO/NV/OK/TX): The Delegated Entities in these states must submit the Monthly Self-Reported Timeliness Reports within 15 calendar days following the month being reported.

California Commercial NPI
The California Department of Managed Health Care (DMHC) Timely Access to Non-Emergency Health Care Services Regulation applies to California Commercial HMO membership only. The regulation establishes time elapsed standards or guidelines to make sure that members have timely and appropriate access to needed healthcare services, including a 24/7 telephonic triage or screening requirement.

Health plans are required to comply with certain provisions of the regulation and provide an annual report detailing the status of the plan’s network care provider and enrollment, which includes the care provider’s NPI.

To comply with this regulation, UnitedHealthcare requires all California Commercial HMO care providers to include their NPI with all care provider additions or when submitting a claim.

 

Claims Research & Resolution (CR&R) process applies:

  • If you do not agree with the payment decision after the initial processing of the claim; and
  • Regardless of whether the payer was UnitedHealthcare, the delegated Medical Group/IPA or other delegated payer, or the capitated facility/care provider, you are responsible for submitting your claim(s) to the appropriate entity that holds financial responsibility to process each claim.

UnitedHealthcare will research the issue to identify who holds financial risk of the services and will abide by federal and state legislation on appropriate timelines for resolution. We will work directly with the delegated payer when claims have been misdirected and financial responsibility is in question.

If appropriate, direct all care provider-driven claim payment disputes to the delegated payer care provider Dispute Resolution process.

The commercial provider Payment Dispute Resolution (PDR) process includes any decisions where a delegated provider appeals the amount paid by the organization.

The following are the regulatory and UnitedHealthcare compliance requirements:

  •  “Written Acknowledgement” of provider disputes within two working days for electronic submission and 15 working days for paper submission.
  • Resolution and a “Written Determination” must be completed within 45 working days after the date of receipt of the provider dispute or the amended provider dispute.
Need More Information about UnitedHealthcare West Claims Disputes?

Additional information, requirements, and mailing addresses regarding claims disputes for UnitedHealthcare West members can be found in the UnitedHealthcare West Supplement, UnitedHealthcare West Bulk Claims Rework Reference Table.

  • Resolution of a provider dispute or amended provider dispute involving a claim and which is determined in whole or in part in favor of the provider, must include payment of any outstanding monies determined to be due, and all interest and penalties must be paid within five working days of the issuance of the written determination.
  • Incomplete provider disputes where additional information has been requested, the provider has 30 working days to submit additional information.
  • Late payment on a complete claim for emergent/urgent services shall include the greater of $15 or 15% per annum for the period of time that the payment is late.
  • Late payment on all other complete claims shall include interest at the rate of 15% (0.000411) per annum for the period of time that the payment is late. Penalty for failure to include interest due on a late claim payment shall pay $10 for that late claim in addition to the required interest payment.
  • Quarterly Dispute Resolution Mechanism Reports must be submitted and signed by the Principal Office within 30 days of the close of each calendar quarter.
  • Timeliness is measured from the earliest date stamp within your facilities if you are the financially responsible payer through the date the payment check or notice contesting that claim has been mailed.
  • Written procedures for Provider Dispute & Resolution must be established which must include; address, directions for submission, timeframe guidelines and phone numbers for inquiries.
  • Improvement Action Plans must be submitted when specified.
  • Review process requirements are complied with, including:
    • Keeping the scheduled assessment appointment
    • Having all claims and supporting documentation ready at the time of the inspection
    • Canceled checks or bank statements
    • Operational Review Questionnaire(s) and Attestations signed and are all available for review

A delegated entity that is contractually delegated to process and adjudicate claims or approve or deny referrals for service shall establish and maintain a fair, fast and cost-effective dispute resolution mechanism to process and resolve contracted and non-contracted care provider disputes in accordance with state and federal regulations.

If the dispute request is for services payable by the delegated entity, we determine if the appropriate payer has reviewed the request for dispute. If the appropriate payer has not reviewed the dispute request, we forward the dispute request to the appropriate payer. We notify the care provider of service of the forwarding dispute request to the delegated entity for processing.

The delegated entity is accountable for submitting all required information to us and the appropriate state agency in accordance with the guidelines established by state and federal regulations. All delegated claims processing entities are required to report PDR processing compliance results quarterly in accordance with state and federal regulations. Submission of quarterly reports, are due no later than the 30th day following the end of the quarter.

We regularly conduct a compliance assessment of the PDR Process of each delegated entity. We review care providers at least annually.

As part of the compliance assessment, we request copies of Delegated Entity Provider Dispute report. The auditor reviews the reports and randomly selects finalized disputes for reviewing. The auditor also requires a copy of the delegated entity’s PDR Policy and Procedures, and evidence of the availability of the PDR mechanism. If the capitated medical group/IPA or capitated facility is found to be non-compliant with UnitedHealthcare state or federal requirements, we expect the delegated entities to develop an improvement action plan designed to bring them back into compliance.

We sanction care providers who do not achieve compliance within the established timeframes until they reach compliance. PDR processing is a delegated function that is subject to revocation. Sanctions may consist of additional/enhanced reviewing, onsite claims/PDR management, and/or revocation. There may be costs to the delegated entity depending on the sanction put in place.

If a care provider continues to have a Commercial claims dispute with the delegated entity related to medical necessity and utilization management, the care provider must forward all claim information and correspondence
between the delegated entity and the care provider to UnitedHealthcare for review. We do not begin the review until we receive the supporting documentation.

Commercial care provider claims must be processed in accordance with the agreed upon contract rates or member benefit plan and within state and federal requirements.

Note: Date stamps from other health plans or insurance companies are not valid received dates for timely filing determination.

Commercial interest rates and timeframes for processing may vary, depending on the applicable state requirements. In some states, an additional penalty for late claims payments may also apply and be paid by the delegated medical group/IPA/facility.