How to File a Discharge Appeal With Commence Health in New Jersey

What Commence Health Does

Commence Health (formerly Livanta) is the Beneficiary and Family Centered Care Quality Improvement Organization — the BFCC-QIO — assigned to Region 2, which includes New Jersey. When a hospital tries to discharge your parent and you believe the discharge is premature or unsafe, Commence Health is the federal body that can halt it.

Their number is 1-866-815-5440. That is the most important piece of information in this article.

When You Can File

You can file an expedited discharge appeal when:

• The hospital has issued a discharge order and you believe your parent still needs inpatient care
• Your parent has received the "Important Message from Medicare" (Form CMS-R-193) and disagrees with the planned discharge
• The hospital has reclassified your parent from inpatient to observation status and issued a Medicare Change of Status Notice (MCSN)

The deadline is midnight on the proposed discharge day. If the hospital says your parent is leaving tomorrow, you file today. Do not wait for the morning.

The Step-by-Step Process

1. Call Commence Health at 1-866-815-5440. Tell them you are requesting an expedited review of a hospital discharge. They will assign a case number. Write it down.

2. The hospital freezes. Once the appeal is initiated, the hospital cannot discharge your parent and cannot bill for continued services until Commence Health issues a decision. This legal protection is automatic.

3. The hospital sends records. Commence Health requests the medical chart from the hospital. The clinical team must submit records documenting the patient's condition, treatment, and the rationale for discharge.

4. An independent physician reviews. A board-certified physician who is not affiliated with the hospital reviews the records. They determine whether inpatient care remains medically necessary based on objective clinical evidence.

5. Commence Health issues a decision. This typically takes 24 to 72 hours. If the decision favors your parent, the hospital must continue providing care. If the decision upholds the discharge, the hospital may proceed with it after the QIO decision.

Strengthening Your Appeal

A bare phone call works. But you can make the appeal stronger.

Write a "Beneficiary Perspective" letter before you call. This is a formal, written statement from the caregiver's point of view documenting why the discharge is unsafe. Include specifics: the home lacks necessary equipment, prescriptions have not been reconciled, home health has not been arranged, the caregiver has not been trained on required medical tasks.

Submit this letter to the hospital case management department and reference it during your Commence Health call. Under federal regulations, the patient has the right to supplement the medical record with this statement. It becomes a permanent part of the clinical file.

If your parent is a Medicare beneficiary and someone else will be handling the appeal on their behalf, complete a CMS-1696 Appointment of Representative form. This formally designates you as the authorized representative for the appeal.

Beyond Hospital Discharge: Quality of Care Complaints

Commence Health also handles quality-of-care complaints while your parent is still in the hospital. If clinical staff are not responding to call lights, hygiene is inadequate, or medication errors are occurring, you can request "Immediate Advocacy" through Commence Health. This is a separate process from the discharge appeal and can run in parallel.

What Commence Health Does Not Cover

Once your parent leaves the hospital and enters a nursing home or assisted living facility, Commence Health's jurisdiction ends. Care complaints in long-term settings go to the New Jersey Office of the Long-Term Care Ombudsman at 1-877-582-6995. Eviction threats while Medicaid is pending, understaffing issues, and abuse or neglect reports all go through the Ombudsman.

The Hospital-to-Home in New Jersey guide includes fill-in-the-blank appeal scripts, a Beneficiary Perspective letter template, and the complete post-appeal decision tree.

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