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August 6, 2020

Clarification of Right to Escalate Reconsideration Request to OMHA for Suppliers Participating in QIC Telephone Discussions

The Qualified Independent Contractor (QIC) revised the Notice of the Telephone Discussion letter to clarify language regarding the opportunity to escalate an appeal to the Office of Medicare Hearings and Appeals (OMHA). Please note that "escalation" is the regulatory term used when an appellant chooses to proceed to the next level of appeal when the QIC cannot make a timely appeal decision. Escalation is a different action than filing a separate appeal with OMHA.

In comparison to a standard reconsideration which has 60 days to render a decision, participation in a telephone discussion extends the QICs time frame to render a decision by an additional 60 days for a total time frame of 120 days from the appeal receipt. By participating in a telephone discussion, you will not have the opportunity to "escalate" your reconsideration request to OMHA if the QIC has not rendered a reconsideration decision within the 60-day processing standard.  However, participation in a telephone discussion as part of the Demonstration does not impact future appeal rights following the reconsideration decision.

Include Multiple Dates of Service on Reconsideration Appeal Request

Suppliers may include multiple dates of service for the same beneficiary on one reconsideration request form instead of submitting separate reconsideration requests for each date of service. Additionally, two or more redeterminations can be submitted in one appeal request to the QIC as long as the items are for the same beneficiary.

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