Commence Health: Medicare Discharge Appeals in Pennsylvania (Formerly Livanta)

Livanta Is Now Commence Health

If you're searching for "Livanta" to file a Medicare discharge appeal in Pennsylvania, you need to know the name changed. Effective August 18, 2025, Livanta LLC was formally rebranded as Commence Health. Same organization, same function, same Region 3 coverage area — new name.

Commence Health is the designated Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO) for Region 3, which covers Pennsylvania, Maryland, Delaware, Virginia, West Virginia, and Washington D.C. They're the independent body that reviews Medicare discharge and coverage disputes between patients and hospitals, skilled nursing facilities, and home health agencies.

This matters because outdated hospital paperwork, state websites, and online guides still reference "Livanta." If a discharge planner hands you a form with the Livanta name, the contact numbers should still work — but know that you're dealing with Commence Health.

Contact: 1-888-396-4646 (toll-free)

What Commence Health Does

Commence Health handles two categories of Medicare disputes in Pennsylvania:

Discharge appeals (expedited review). When a hospital says your parent is ready for discharge and you believe they're not medically stable, you file an expedited appeal with Commence Health. They assign an independent physician reviewer who examines the medical records, consults with the treating team, and issues a binding decision. The hospital cannot discharge your parent while this review is pending.

Quality of care complaints. If you believe your parent received substandard care during their hospital stay, SNF rehabilitation, or home health episode — medication errors, inadequate monitoring, premature discharge that led to readmission — you can file a quality complaint with Commence Health for review. This is separate from an expedited discharge appeal.

How to File a Discharge Appeal

The process is time-sensitive, so here's the step-by-step:

1. Receive the Important Message from Medicare (IM). The hospital must give your parent this form (CMS-10065) within two days of admission and again before discharge. It explains the right to appeal and includes Commence Health's contact information. If you haven't received it, ask for it immediately — the hospital is required to provide it.

2. Call Commence Health before the deadline printed on the IM. The appeal must be filed by the discharge deadline listed on the IM. Call 1-888-396-4646. You can file by phone — you don't need written paperwork to initiate the appeal.

3. The hospital provides records. Once Commence Health receives your appeal, they notify the hospital, which must submit the patient's complete medical record and a Detailed Notice of Discharge (Form CMS-10066) by noon the following day. This notice explains the clinical reasons the hospital believes discharge is appropriate.

4. Independent physician review. A Commence Health physician reviewer — who has no relationship with the hospital — evaluates the medical records, contacts the patient or representative to hear their concerns, and makes a coverage determination.

5. Decision. Commence Health issues a decision within 24 to 72 hours of receiving the complete medical record:

• Appeal upheld (in your favor): The hospital cannot discharge your parent, and Medicare continues covering the stay. No charges for the appeal period.
• Appeal denied: The hospital can proceed with discharge. If your parent chooses to stay beyond the discharge date, the hospital can issue an Advance Beneficiary Notice (ABN) and bill your parent directly for custodial care.

Observation Status Appeals

Commence Health also handles appeals when a hospital changes your parent's billing status from inpatient to outpatient observation — a reclassification that can eliminate Medicare Part A coverage for subsequent skilled nursing facility care.

When this status change occurs, the hospital must issue a Medicare Change of Status Notice (MCSN, Form CMS-10868). Your parent has the right to an expedited prospective appeal through Commence Health while still in the hospital. If the appeal is successful, the inpatient admission order is reinstated, preserving eligibility for the three-day inpatient stay requirement needed for SNF coverage.

SNF and Home Health Appeals

The appeal process extends beyond hospital stays:

• Skilled nursing facility: If the SNF issues a Notice of Medicare Non-Coverage (NOMNC) saying Medicare-covered services will end, your parent can appeal to Commence Health by the date specified on the NOMNC.
• Home health agency: Same process — if the agency issues a NOMNC terminating services, appeal to Commence Health by the date specified on the NOMNC.

In both cases, filing the appeal before the coverage end date preserves financial protections — the provider cannot bill the patient for continued services during the review period.

Don't Confuse Commence Health With Acentra Health

A common mistake: searching for "Medicare appeal" brings up Acentra Health, which is the BFCC-QIO for other regions of the country. If your parent is in Pennsylvania, your BFCC-QIO is Commence Health, not Acentra. Filing with the wrong organization wastes time you may not have.

For the complete discharge appeal process — including the exact scripts to use when calling Commence Health, a timeline showing when each form should arrive, and what to do if the appeal is denied — the Pennsylvania Hospital Discharge Guide lays out every step with Pennsylvania-specific contact numbers and deadlines.

See more Pennsylvania guides →