How to Appeal Hospital Discharge in Indiana: Commence Health QIO Appeal Step by Step

The hospital just told you your parent is being discharged tomorrow, and you don't think they're ready. You have until midnight tonight to file an appeal — and if you do it right, the hospital legally cannot discharge your parent while the review is pending. Here's exactly how to do it in Indiana.

Who Handles Hospital Discharge Appeals in Indiana

The organization you need is Commence Health (formerly known as Livanta, and before that, Kepro). Commence Health is the federally designated Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO) for Indiana. They're independent — not affiliated with any hospital, insurance company, or government agency.

Commence Health Contact Information:

• Phone: 888-524-9900
• TTY: 711
• Fax: 855-236-2423

Note: You may see older references to "Acentra Health" — this is the same organization. The QIO contract for Indiana's region transitioned to Commence Health.

The Deadline You Cannot Miss

You must call Commence Health before midnight on the day the hospital has scheduled the discharge. If the hospital says "discharge tomorrow morning," you need to call today.

Once you file:

1. The hospital is legally prohibited from discharging the patient
2. Medicare must continue covering the hospital stay during the review
3. You cannot be billed for the additional days while the appeal is pending

Step-by-Step Appeal Process

Step 1: Confirm You Received the Important Message from Medicare

The hospital should have given the patient (or their representative) form CMS-10065 — "An Important Message from Medicare" — within two days of admission and again before discharge. This notice explains your appeal rights. If you never received it, tell Commence Health when you call — this strengthens your case.

Step 2: Call Commence Health

When you call 888-524-9900, tell the representative:

"I am calling to file an expedited appeal of a hospital discharge for [patient name] at [hospital name] in [city], Indiana. The discharge is scheduled for [date]. I believe the discharge is premature because [specific reasons]."

Be specific about why the discharge is unsafe:

• Pending test results or surgical follow-up
• No trained caregiver at home
• Home health or DME not yet arranged
• Patient cannot perform basic activities (walking, eating, toileting)
• Cognitive decline making self-care impossible
• Wound care requirements beyond family capability

Step 3: The Hospital Responds with a Detailed Notice

After Commence Health notifies the hospital of your appeal, the hospital must deliver a Detailed Notice of Discharge (DND) by noon the following day. This document explains the clinical rationale for why they believe the patient is ready for discharge.

Read the DND carefully. If you disagree with any clinical claims, call Commence Health back to provide your perspective.

Step 4: Commence Health Reviews the Case

Commence Health's medical reviewers request the patient's complete medical records from the hospital. They evaluate whether the discharge plan meets the patient's clinical needs. The decision typically comes within 24 hours of receiving the records.

Step 5: The Decision

If Commence Health agrees with you — the discharge is overturned. Your parent stays, and Medicare covers the extended stay. The hospital must develop a revised discharge plan.

If Commence Health agrees with the hospital — the discharge proceeds. You become financially responsible for hospital charges starting at noon on the day after the decision (or the date specified in the notice). However, you can escalate to a second-level appeal through an Administrative Law Judge.

Two Types of Appeals: Discharge vs. Status Change

There are actually two different appeal scenarios:

Discharge appeal (the process above): You're challenging the hospital's decision to end the stay. Used when you believe the patient isn't medically ready to leave.

Change of status appeal: The hospital reclassified your parent from inpatient to outpatient observation status. This is a different — and arguably more dangerous — situation, because observation days don't count toward the three-day inpatient stay required for Medicare SNF coverage. If the hospital delivers a Medicare Change of Status Notice (MCSN, form CMS-10868), file an immediate appeal with Commence Health to challenge the reclassification.

What to Do While Waiting

While the appeal is pending:

• Document everything — dates, times, names of staff, what was said
• Request a copy of the patient's medical record (HIPAA allows this)
• Ask the attending physician to document their clinical assessment in the chart
• If you haven't already, designate a lay caregiver under Indiana Code § 16-21-12-7 to require hands-on training before any eventual discharge
• Contact your parent's PathWays for Aging care coordinator if they're enrolled in Medicaid managed care

Immediate Advocacy (Non-Appeal)

If the situation isn't a formal discharge dispute but you're having trouble with quality of care, medication management, or communication with hospital staff, Commence Health also offers "Immediate Advocacy" — informal mediation between the patient/family and the healthcare provider. Same phone number: 888-524-9900.

For the complete Indiana hospital discharge process — including appeal scripts, Medicaid planning, and post-discharge care coordination — the Indiana Hospital-to-Home Transition Guide walks through every scenario.

See more Indiana guides →