How to File a QIO Appeal for Hospital Discharge in Arizona

You have decided your parent is not ready to leave the hospital. The discharge planner disagrees. The clock is running — you need to file a fast appeal with Arizona's Quality Improvement Organization before midnight on the scheduled discharge day, or you lose the right to an immediate review.

Arizona's designated Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO) is Commence Health (formerly Livanta). They are the independent federal contractor responsible for reviewing discharge disputes in Region 9, which covers Arizona.

Contact Information

• Helpline: 1-877-588-1123
• TTY: 711
• Toll-free fax: 855-694-2929
• Online appeal portal: commencehealthqio.cms.gov

You can file by phone or through the online portal. The phone is faster in a crisis — call and tell them you want to file a fast appeal of a hospital discharge.

What You Need Before Filing

Gather this information before you call or start the online form:

• Medicare Beneficiary Identifier (MBI): The patient's Medicare card number (11 characters, letters and numbers)
• Patient's date of birth
• Hospital name and full address
• Planned discharge date
• Specific clinical reasons you believe the discharge is unsafe — be concrete: "Patient cannot walk to the bathroom without assistance," "No home health agency has been arranged," "Caregiver has not been trained on wound care"

You do not need a power of attorney or formal legal authority to file. Any family member acting as the patient's representative can initiate the appeal.

The Online Portal: What to Expect

The Commence Health online portal has a strict 15-minute inactivity timeout. If you stop entering information for 15 minutes, the session expires and you must start over. Have all your information ready before you begin.

The form must be completed in a single session — there is no save-and-resume option. Required fields include the MBI, patient demographics, facility information, and a free-text field where you describe why the discharge is premature.

After submitting, you receive a confirmation. You can track the status of your case using Commence Health's Arrow Case Lookup system.

What Happens After You File

The process moves fast — by design:

1. The discharge is frozen. The hospital cannot discharge your parent once the appeal is filed. Medicare continues covering the inpatient stay during the review. The hospital cannot bill the patient for this continued care.

2. The hospital delivers a Detailed Notice of Discharge (DND). The hospital must send this document to both the patient and Commence Health by noon the day after the appeal is filed. The DND explains the clinical reasons the hospital believes the patient no longer needs inpatient care.

3. Commence Health reviews the medical records. They issue a decision within 24 to 48 hours of receiving the records.

4. If the appeal is upheld: Medicare coverage continues and the patient stays until medically ready for discharge.

5. If the appeal is denied: You have 3 calendar days to request a reconsideration from an independent reviewer. The patient remains covered during this second review.

Building a Strong Appeal

The QIO reviewer is looking at whether the patient still meets "inpatient level of care" criteria. Generic complaints like "I don't think they're ready" are not enough. Focus on specific, documented clinical concerns:

• Functional deficits: "Patient scored 2 out of 3 on transfers during PT evaluation yesterday — cannot safely get out of bed without two-person assist"
• Unresolved medical issues: "IV antibiotics were discontinued 12 hours ago and no oral transition has been confirmed effective"
• Missing discharge prerequisites: "No medication reconciliation has been completed," "DME has not been delivered," "Receiving facility has not completed pre-discharge screening as required by A.R.S. Section 36-420.04"
• Caregiver unreadiness: "Designated caregiver has not been trained on wound care or catheter management as required under the CARE Act"

Ask the attending physician to document any concerns they have about discharge readiness. A physician note supporting delayed discharge significantly strengthens the appeal.

Medicare Advantage Plans: Different Process

If your parent has a Medicare Advantage plan (Part C) rather than Original Medicare, the appeal process is different. You file directly with the Medicare Advantage plan, not with the QIO.

Medicare Advantage plans must process expedited appeals within 3 calendar days. If the appeal involves an immediate threat to health, the plan may grant an extension of coverage while the review is pending. Check the plan's Evidence of Coverage document for the specific appeal phone number and process.

You can still contact Commence Health for guidance, but they do not have direct review authority over Medicare Advantage plan decisions.

The Hospital-to-Home in Arizona toolkit includes the complete appeal framework, including pre-written appeal scripts, the QIO filing checklist, and the clinical documentation templates you need to build a strong case against a premature discharge.

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