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Expert Q&A

A consulting company we worked with many years ago had us have Medicare Advantage (MA) patients sign an appointment of representative (AOR) form right from the beginning of their admission. Of course, it takes more resources to get signatures from the patient after discharge. What are the pros and cons of having the patient sign the AOR form at admission?

March 27, 2025 · Anna McGraw

The whole point of having the MA patient assign you their rights of appeal is so that you can appeal on behalf of the patient. For Medicare Advantage plans, appealing on behalf of the patient allows you to go through the 5-level Medicare appeal process which is not available to the provider if the provider is contracted with the plan. When you appeal on behalf of the facility, you get the number of internal (back to the payer) appeal levels that are described in your payer-provider contract or in the payer’s provider manual.

Best practice is to have the AOR form signed by the patient on admission. Some hospitals have struggled with implementing the process because it involves changes in forms, or adding new forms to registration packets, and questions arise about why every patient needs to sign the form even though not every admission will be denied. MA plans may have their own AOR form they provide for use, however, the CMS AOR form 1696 should be accepted by MA plans. You can download the form here: CMS 1696.

Related

We are seeing an increased number of payor appeals which state “The HBV review performed is a payment integrity review, not a level of care or a medical necessity review, focused on the payment of services documented in the medical record. Facility documentation submitted and reviewed by HBV has identified outpatient services were delivered, and not acute care inpatient services. HBV is not denying the services provided, rather the review is focused on the payment of services documented in the medical record. In accordance with the application of MCG guidelines, HBV has determined that the services delivered are consistent with an outpatient or observation payment.” We have tried outlining the services performed, resources required, how IP level of care were met by the MCG / IQ criteria they outline. They are still being upheld. What else can we do to argue these denials?
Expert Q&A

We are seeing an increased number of payor appeals which state “The HBV review performed is a payment integrity review, not a level of care or a medical necessity review, focused on the payment of services documented in the medical record. Facility documentation submitted and reviewed by HBV has identified outpatient services were delivered, and not acute care inpatient services. HBV is not denying the services provided, rather the review is focused on the payment of services documented in the medical record. In accordance with the application of MCG guidelines, HBV has determined that the services delivered are consistent with an outpatient or observation payment.” We have tried outlining the services performed, resources required, how IP level of care were met by the MCG / IQ criteria they outline. They are still being upheld. What else can we do to argue these denials?

Mar 27, 2025