Livanta Appeal Maryland: How to Fight an Unsafe Hospital Discharge

The hospital says your parent is being discharged today. They can barely walk, can't manage their medications alone, and no one has confirmed whether the home health agency they're recommending is even set up. You believe the discharge is unsafe. Here's exactly how to stop it.

Who to Call

Maryland's designated Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO) is Commence Health (formerly operated by Livanta LLC). They handle expedited discharge appeals for Medicare beneficiaries across Region 3, which includes Maryland.

Contact Commence Health:

• Helpline: 888-396-4646
• TTY: 711
• Fax for appeals: 855-236-2423
• Mail: BFCC-QIO Program, Commence Health, PO Box 2687, Virginia Beach, VA 23454

The Expedited Appeal Process

Step 1: Get the Important Message from Medicare

The hospital must give your parent the "Important Message from Medicare" (IM) document within two days of admission and again before discharge. This form contains the QIO contact information and explains the appeal right. If you haven't received it, ask for it immediately — the hospital is legally required to provide it.

Step 2: Contact Commence Health Before Leaving

Call Commence Health no later than the planned discharge date and before your parent physically leaves the hospital. This is the critical deadline. Once your parent leaves the building, the fast-track appeal option closes.

Step 3: The Discharge Freezes

The moment you file a timely appeal, the hospital cannot discharge your parent. They also cannot charge the patient for room and board during the active appeal period. Your parent stays in their bed, receiving care, while Commence Health reviews the case.

Step 4: The Hospital Responds

By noon the day after Commence Health notifies the hospital of the appeal, the facility must deliver a Detailed Notice of Discharge to both the patient and Commence Health. This document outlines the clinical justification for why the hospital believes discharge is appropriate.

Step 5: The QIO Decision

Commence Health reviews the complete medical record, contacts the family or healthcare agent for their perspective, and makes an independent determination — typically within one business day of receiving the hospital's clinical documentation.

If Commence Health upholds the discharge (agrees with the hospital), the patient's financial responsibility for the stay begins at noon on the day after the notification. If they overturn the discharge, the patient stays with continued Medicare coverage.

Appealing a Rehab or SNF Coverage Termination

The same appeal process applies when a skilled nursing facility issues a Notice of Medicare Non-Coverage (NOMNC) signaling that therapy benefits are ending. Contact Commence Health before the coverage termination date. Coverage continues during the appeal review.

Second-Level Appeals

If Commence Health upholds the discharge or coverage termination and you disagree, you can request a second-level review by a Qualified Independent Contractor (QIC). This is a separate, independent review that examines the same medical evidence with fresh eyes.

Build Your Case

The strength of your appeal depends on documenting your parent's specific care needs. Note their mobility limitations, medication complexity, cognitive status, fall risk, and any gaps in the discharge plan (unlicensed providers, missing equipment, no caregiver training provided).

The Maryland Hospital Discharge Guide includes a Livanta Reconsideration Builder worksheet designed to organize this documentation into the format that appeals reviewers evaluate.

See more Maryland guides →