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Appeal guide · Skilled nursing

Skilled nursing facility denials

Skilled nursing facility (SNF) coverage is denied at admission or, more often, ended mid-stay with a Notice of Medicare Non-Coverage. The clock on these denials is measured in hours, and the appeal runs through the Quality Improvement Organization, not the plan.

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What gets denied

  • SNF admission after a hospital stay for surgery, stroke, fracture, or infection
  • Continued coverage after the first one to two weeks of a stay
  • Stays where the plan says the patient has 'plateaued' or 'reached maximum benefit'
  • Admissions denied because the hospital stay was classed as observation rather than inpatient

Common denial reasons

  • Plan says the patient no longer needs daily skilled care
  • Plan says care is 'custodial' or 'maintenance' only
  • No qualifying 3-day inpatient stay (traditional Medicare, or plans that keep the rule)
  • Medicare Advantage plan applied an internal algorithm or criteria beyond the Medicare rule
  • Documentation from the facility does not describe the skilled tasks being performed

How we approach the appeal

For a mid-stay cutoff, call the QIO before the deadline on the notice; coverage continues while the QIO decides. Ask the facility for the Detailed Explanation of Non-Coverage and the therapy and nursing notes. Show the specific skilled services being delivered (wound care, IV therapy, therapy that requires a licensed clinician) and, where the plan cites lack of progress, cite the maintenance-coverage standard. For Medicare Advantage denials, cite 42 CFR 422.101(b)(2): the plan may not use criteria more restrictive than Medicare's.

Filing window

Notice of Medicare Non-Coverage: contact the QIO no later than noon of the day before the effective date on the notice for fast-track review (42 CFR 405.1200 to 405.1204 for traditional Medicare; 42 CFR 422.626 for Medicare Advantage). If that window is missed, a standard appeal remains available (65 days for Medicare Advantage reconsideration, 42 CFR 422.582). Commercial plans: at least 180 days to file an internal appeal.

Typical recovery

SNF care is billed per day; a denied stay of a few weeks is commonly a five-figure sum in billed charges. The amount at stake depends on the days denied and the plan's rates.

Documents we'll ask for
  • · Notice of Medicare Non-Coverage (or the plan's denial) with the effective date
  • · Detailed Explanation of Non-Coverage from the facility
  • · Nursing notes and therapy notes for the disputed days
  • · Hospital discharge summary and the inpatient admission order
  • · Physician's certification of the need for skilled care

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This page provides general information about appeal strategy. It is not legal advice. Outcomes depend on documentation, plan terms, and timing.