Quality Improvement Organization Manual 
Chapter 5 - Quality of Care Review 
 
Table Of Contents 
(Rev. 28, 10-21-16) 
 
Transmittals for Chapter 5 
 
5000  Introduction to Quality of Care Reviews 
5010 - Authority for Conducting Quality of Care Reviews 
5015  Organization of Chapter 
5020  Definitions Related to Quality of Care Reviews  
5025  Beneficiary Complaint Review Overview  
5025.1  Eligibility for Beneficiary Complaint Review  
5030  Beneficiary Complaint: Intake  Stage One 
5030.1  Scope of Complaint  
5030.2  Initial Information Collection  
5030.3  Initial Offer of Review  
5030.4  Use of CMS-Designated Case Review System  
5035  Immediate Advocacy 
5035.1  Objectives of Immediate Advocacy  
5035.2  Eligibility for Immediate Advocacy  
5035.3  Practitioner/Provider Consent to Participate in Immediate Advocacy  
5035.4  Immediate Advocacy Procedures  
5035.5  Discontinuation of Immediate Advocacy  
5040  Beneficiary Complaint Review Protocols 
5040.1  Beneficiary Complaint: Preparing and Forwarding the Medicare Quality of 
Care Complaint Form  
5040.2  Beneficiary Complaint: Follow-up - Return of Signed Medicare Quality of Care 
Complaint Form 
5040.3  Beneficiary Complaint: Receipt of a Signed Beneficiary Complaint Form  
5040.4  Beneficiary Complaint: Complaints Not Submitted in Writing (i.e. Oral 
Complaints) 
5040.5  Beneficiary Complaint: Abandoned Complaints and Reopening Rights  
5045  Beneficiary Complaint: Preparing the Beneficiary Complaint Folder 
5045.1  Beneficiary Complaint: Forwarding of Complaint to the QIO 
5045.2  Beneficiary Complaint: Requesting Medical Information 
5045.3  Beneficiary Complaint: Issuing a Claim Denial 
5045.4  Beneficiary Complaint: Reviewing and Preparing Medical Information  
5050  Beneficiary Complaint: Quality of Care Review  Stage Two 
5050.1  Beneficiary Complaint: New Concerns Raised by the Beneficiary  5050.2  Beneficiary Complaint: Preparing the Quality Review Decision (QRD) Form  
5050.3  Beneficiary Complaint: Receipt and Review by the Initial Determination Peer 
Reviewer 
5050.4  Beneficiary Complaint: QIO Review of the Interim Initial Determination 
5055  Beneficiary Complaint: Opportunity for Discussion  Stage Three 
5055.1  Beneficiary Complaint: Notification of Opportunity for Discussion  
5055.2  Beneficiary Complaint: Oral or Written Response by Practitioner/Provider  
Opportunity for Discussion  
5055.3  Beneficiary Complaint: Prohibition on Submission of New/Additional Medical 
Information 
5055.4  Beneficiary Complaint: Reviewing Response Submitted during Opportunity for 
Discussion  
5055.5  Beneficiary Complaint: No Response to Opportunity for Discussion 
5055.6  Beneficiary Complaint: Preparing the Final Determination Letter to 
Practitioners/Providers and Beneficiaries 
5055.7  Beneficiary Complaint: Failure to Respond to the Final Initial Determination 
and Right to Reconsideration 
5055.8  Beneficiary Complaint: Responsibility to Protect Information and Destruction 
of Materials 
5060  Beneficiary Complaint: Reconsideration  Stage Four 
5060.1  Beneficiary Complaint: Reconsideration Peer Reviewer  
5060.2  Beneficiary Complaint: Preparing the Reconsideration Disclosure Package 
5060.3  Beneficiary Complaint: QIOs Final Decision, Preparing and Mailing Letter to 
Providers and/or Practitioners and the Beneficiary 
5060.4  Beneficiary Complaint: Procedures for Closing a Complaint Review  
5060.5  Beneficiary Complaint: Responsibility to Protect Information and Destruction 
of Materials 
5065  Post-Review Advocacy 
5065.1  Objectives of Post-Review Advocacy  
5065.2  Eligibility for Post-Review Advocacy 
5065.3  Practitioner/Provider Consent to Participate in Post-Review Advocacy 
5065.4  Post-Review Advocacy Procedures  
5065.5  Discontinuation of Post-Review Advocacy  
5070  General Quality of Care Reviews 
5075  Concerns Identified During Other Review Activities 
5080  General Quality of Care Review: Source - Anonymous Beneficiary  
5085  General Quality of Care Review: Referrals 
5085.1  Referrals from Other Federal Government Organizations  
5090  Overlap of Review Authority 
5095  Tracking and Trending of Data 
5100  General Quality of Care Review   5110  General Quality of Care Review: Preparing the General Quality of Care Review Folder: 
Intake - Stage One 
5110.1  General Quality of Care Review: Review of Folder by the QIO 
5110.2  General Quality of Care Review: Requesting Medical Information 
5110.3  General Quality of Care Review: Issuing a Claim Denial 
5110.4  General Quality of Care Review: Reviewing and Preparing Medical 
Information  
5115  General Quality of Care Review: Quality of Care Review  Stage Two 
5115.1  General Quality of Care Review: Preparing the Quality Review Decision 
(QRD) Form  
5115.2  General Quality of Care Review: Receipt and Review by the Initial 
Determination Peer Reviewer 
5115.3  General Quality of Care Review: Return of Initial Determination 
5115.4  Preparation of Initial Determination Letter 
5115.5  General Quality of Care Review: Responsibility to Protect Information and 
Destruction of Materials 
5120  General Quality of Care of Care Review: Reconsideration  Stage Three 
5120.1  General Quality of Care Review: Reconsideration Peer Reviewer  
5120.2  General Quality of Care Review: Preparing the Reconsideration/Final 
Determination Package 
5120.3  General Quality of Care Review: Preparing and Mailing the Final 
Reconsideration Determination Letter 
5120.4  General Quality of Care Review: Procedures for Closing Review  
5125  Beneficiary and Family-Centered Care-QIO - Recommendations and Referrals for 
Quality Improvement Initiatives and Technical Assistance 
5125.1  Quality Improvement Initiatives  Beneficiary and Family-Centered Care QIO 
Responsibilities 
5125.2  Quality Improvement Initiatives  Quality Innovation Network (QIN)-QIO 
Responsibilities 
5125.2.1  Unwillingness to Cooperate  
5125.2.2  Developing a Quality Improvement Initiative 
5125.2.3  Time Frames for Developing a Quality Improvement Initiative 
5125.2.4  Quality Improvement Initiative Not Needed 
5125.2.5  Quality Improvement Initiative Root Cause Analysis 
5125.2.6  Stand-alone or Isolated Concerns  
5125.2.7  Intervention and Improvement Plan 
5125.2.8  Monitoring Quality Improvement Initiatives 
5125.2.9  Reporting Results of System-wide Change Quality Improvement 
Initiatives 
Appendix 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16)  Appendix 5-1.1 Medicare Quality of Care Complaint Form 
Appendix 5-1.2  Appointment of Representative Form 
Appendix 5-1.3  Quality Review Decision (QRD) Form 
Appendix 5-2  Beneficiary Quality of Care Complaint: Initial Acknowledgement Letter to 
Beneficiary/Beneficiary Representative  
Appendix 5-3 Beneficiary Quality of Care Complaint: Interim Determination Letter for 
Practitioners and Providers 
Appendix 5-4  Final Initial Determination Letter to Practitioners/Providers with Request to 
Disclose (For Beneficiary Complaints) 
Appendix 5-4 .1 Beneficiary Quality of Care Complaint: Final Determination Letter to 
Practitioners/Providers 
Appendix 5-4.2  Beneficiary Quality of Care Complaint: Final Determination Letter to 
Beneficiary/Beneficiary Representative  
Appendix 5-5.1 Beneficiary Quality of Care Complaint: Reconsideration Determination Letter 
to Practitioners and Providers 
Appendix 5-5.2 Beneficiary Quality of Care Complaint: Reconsideration Determination Letter 
to Beneficiary/Beneficiary Representative 
Appendix 5-5  Re-Review Determination Letter to Providers/Practitioners with Request to 
Disclose (For Beneficiary Complaints) 
Appendix 5-6  General Quality of Care Reviews: Initial Determination Letter with Right to 
Request Reconsideration to Practitioners and Providers 
Appendix 5-7  General Quality of Care Reviews: Final Reconsideration Determination Letter 
to Practitioners and Providers 
Appendix 5-8  Request for QIO Review Form 
Appendix 5-9  Beneficiary Complaint Review- Best Practices 
Appendix 5-10  General Quality of Care Review - Best Practices 
 
Note: This chapter is not a substitute for the underlying law. The QIO is responsible for 
complying with applicable statutes and regulations, as well as the supporting instruction in the 
manual chapter. 
  5000  Introduction to Quality of Care Reviews 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
This Chapter provides instructions and guidance for the Beneficiary and Family Centered Care 
Quality Improvement Organizations (QIOs) to follow in conducting Quality of Care Reviews 
and for the Quality Innovation Network (QINs) in assisting providers and practitioners in 
improving the quality of health care through Quality Improvement Initiatives (QIIs). The phrase 
quality health care refers to the degree to which health care services for individuals and 
populations increase the likelihood of desired health outcomes and are consistent with current 
professional knowledge.  
 
A Quality of Care Review focuses on whether the quality of services provided to beneficiaries is 
consistent with professionally recognized standards of health care. In conducting a Quality of 
Care Review, the QIO is responsible for reviewing actual care and services to determine where 
the provided care and services fall within the range of professionally recognized standards of 
health care. 
 
NOTE:  In the course of conducting a Quality of Care review, if a QIO identifies an issue 
requiring a different type of review, the QIO must follow the relevant regulations and 
supporting QIO Manual Chapter instructions specific to that review activity. 
 
5010  Authority for Conducting Quality of Care Reviews 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The statutory and regulatory authority to conduct Quality of Care Reviews is as follows:  
 
1862(g) of the Social Security Act (the Act) requires that the Secretary enter into contracts with 
QIOs for the purpose of promoting the effective, efficient, and economical delivery of health care 
services and of promoting the quality of services of the type for which payment may be made 
under title XVIII. 
 
1154(a) (1) (B) of the Act requires that a QIO conduct review to determine whether the quality 
of services meets professionally recognized standards of health care.  
 
1154(a)(14) of the Act requires that QIOs conduct appropriate reviews of all written 
complaints, submitted by beneficiaries or beneficiaries representatives, about the quality of 
services not meeting professionally recognized standards of health care.  
 
1154(a)(4)(A) of the Act requires that each QIO provide that a reasonable proportion of its 
activities involve reviewing the quality of services under paragraph (a)(1)(B) and that a QIO 
reasonably allocates such activities among the different cases and settings (including post-acute 
care settings, ambulatory settings, and health maintenance organizations).  
 
42 CFR 476.71(a) (2) requires a QIO to determine whether the quality of services meets 
professionally recognized standards of health care. This is accomplished through the resolution 
of oral beneficiary complaints, written beneficiary complaints, or the completion of general 
quality of care reviews. 
  42 CFR 476.71(a) (5) requires the QIO to determine the completeness, adequacy, and quality 
of hospital care.  
 
42 CFR 476.71(d) requires the QIO to carry out the responsibilities specified in Subpart C of 
part 1004 related to investigations and referral for sanctions of providers and practitioners who 
violate statutory obligations under  1156 of the Act. 
 
42 CFR 476.110 allows the QIO to use immediate advocacy, when the complaint meets certain 
criteria, to resolve oral beneficiary complaints obtained within 6 months of the date from which 
the care giving rise to the complaint occurred. 
 
42 CFR 476.120 requires the QIO to conduct a review based on written beneficiary complaints 
when the care concerning the complaint occurred no more than 3 years from the date when the 
care giving rise to the complaint occurred, and explains when the QIO can complete a General 
Quality of Care Review for certain oral beneficiary complaints. 
 
42 CFR 476.130 explains the QIOs role in reviewing beneficiary complaints, including the 
scope of the QIO review, medical record requests, types of QIO decisions, and applicable time 
frames.  
 
42 CFR 476.140 provides the beneficiary and the providers/practitioners with the right to 
request a reconsideration by the QIO of the initial decision with regard to a complaint , 
including applicable time frames and issuance of the QIOs final decision, for complaints filed 
after July 31, 2014.  
 
42 CFR 476.150 explains the procedures applicable to abandoned beneficiary complaints and 
for reopening reviews.  
 
42 CFR 476.160 explains the General Quality of Care Review procedures, including applicable 
time frames, scope of the QIO review, medical record requests, and issuance of the QIOs 
written initial determination.  
 
42 CFR 476.170 explains requirements for the General Quality of Care reconsideration 
process and issuance of the QIOs final decision. 
 
5015  Organization of Chapter 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The chapter is organized based on the two types of Quality of Care Reviews that QIOs conduct; 
Beneficiary Complaint Reviews are addressed first (See 5025-5065), followed by General 
Quality of Care Reviews. (See 5100-5125.)  
 
NOTE: All references to a beneficiary in this chapter also include the beneficiary representative, 
unless otherwise indicated. 
 
Review Type and Description 
 
1.  Beneficiary Quality of Care Complaints  Reviews initiated because a beneficiary or the  beneficiarys representative has complained (referred to as Beneficiary Complaint 
Review) about the quality of care rendered to a Medicare beneficiary 
 
2.  General Quality of Care Reviews  Reviews conducted because the QIO has 
independently identified a potential quality issue or has been referred a quality issue 
from another entity (referred to as General Quality of Care Review)  
 
Sources for Reviews 
 
A. Beneficiary Complaint Review Sources 
 
1.  A written complaint filed by a beneficiary  
 
2.  A oral complaint by a beneficiary where the beneficiary agrees to participate in 
Immediate Advocacy  
 
B. General Quality of Care Reviews Sources 
 
1.  Concerns Identified during Other Review Activities: A Quality of Care review conducted 
when a potential quality of care concern(s) is identified during the course of any other 
review activity, such as medical necessity reviews, expedited discharge appeals, 
Emergency Medical Treatment and Labor Act (EMTALA) reviews. 
 
2.  When a beneficiary raises a concern, but the beneficiary declines to submit a formal 
written complaint, and the QIO makes a preliminary determination that the complaint 
involves a potential gross and flagrant, substantial, or significant quality of care 
concern, such complaint may be processed as a General Quality of Care Review. For 
purposes of 42 CFR 476.120(a)(1) and this provision, an anonymous complaint, even if 
received in writing, is not a written complaint sufficient to trigger the beneficiary 
complaint procedures outlined in 42 CFR 476.130. 
 
3.  Referrals include a Quality of Care Review conducted in response to referrals from other 
entities (e.g., Medicare Administrative Contractors, State-based organizations, the Office 
of Inspector General, the Office for Civil Rights), including anonymous referrals. 
 
4.  Tracking and Trending is a Quality of Care review conducted as a result of tracking and 
trending or other analysis of data.  
 
Stages of Review by Type 
 
Beneficiary Complaint Reviews 
 
The process steps for this review are separated into four stages to facilitate identification of 
roles and steps associated with various aspects of the process:  
 
Stage 1: Intake Stage; 
Stage 2: Quality of Care Review Stage; 
Stage 3: Opportunity for Discussion Stage; and  Stage 4: Reconsideration Stage. 
 
NOTE: The Social Security Act 1154(a)(14) requires that QIOs conduct an appropriate 
review of all written complaints from Medicare beneficiaries alleging that the quality of 
services they received did not meet professionally recognized standards of care. For Beneficiary 
Complaints, the process instructions include a QIOs authority to offer Immediate Advocacy (See 
5035) during the Intake Stage if a written complaint has not yet been received. QIOs may also 
offer at their discretion a Post-Peer Review alternative dispute resolution process, called Post-
Review Advocacy (See 5065), for complaints submitted in writing that Peer Reviewers 
determine contain no significant quality of care concerns. 
 
General Quality of Care Reviews 
 
The process steps for this review are separated into these three stages to facilitate identification 
of roles and steps associated with various aspects of the process:  
 
Stage 1: Intake Stage; 
Stage 2: Quality of Care Review Stage; and 
Stage 3: Reconsideration Stage. 
 
5020  Definitions Related to Quality of Care Reviews 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Appointed Representative: An individual appointed by a beneficiary to represent the beneficiary 
in the Beneficiary Complaint Review process. See 42 CFR 476.1.  
 
Authorized Representative: An individual authorized, under State or other applicable law, to act 
on behalf of a beneficiary. The authorized representative will have all of the rights and 
responsibilities of a beneficiary throughout the processing of a Beneficiary Complaint. See 42 
CFR 476.1.  
 
Beneficiary Complaint: A complaint by a beneficiary or a beneficiarys representative alleging 
that the quality of services received by the beneficiary did not meet professionally recognized 
standards of care. A complaint may consist of one or more quality of care concerns. See 42 CFR 
476.1.  
 
Beneficiary Complaint Review: A review conducted by a QIO in response to the receipt of a 
written beneficiary complaint to determine whether the quality of Medicare-covered services 
provided to the beneficiary was consistent with professionally recognized standards of health 
care. See 42 CFR 476.1.  
 
Beneficiary Representative: An individual identified as an authorized or appointed 
representative of a beneficiary. See 42 CFR 476.1.  
 
Corrective Action Plan: A written plan for correcting poor care that is gross and flagrant or is a 
substantial violation in a substantial number of cases. See 1156 of the Act, 42 CFR 1004.60, 
and CMS Publication 100-10, Quality Improvement Organization Manual, Chapter 9, Sanction 
and Abuse Issues.   
Criteria: Predetermined elements of health care, developed by health professionals relying on 
professional expertise, prior experience, and the professional literature, with which aspects of 
the quality, medical necessity, and appropriateness of a health care service may be compared. 
See 42 CFR 476.1. 
 
General Quality of Care Review: A review conducted by a QIO to determine whether the quality 
of Medicare-covered services provided to a Medicare beneficiary was consistent with 
professionally recognized standards of health care. A general quality of care review may be 
carried out as a result of a referral to the QIO or a QIO's identification of a potential concern 
during the course of another review activity or through the analysis of data. See 42 CFR 476.1. 
 
Gross and Flagrant Violation: A violation of an obligation resulting from inappropriate or 
unnecessary services, services that do not meet recognized professional standards of care, or 
services that are not supported by evidence of medical necessity or quality as required by the 
QIO. The violation must have occurred in one or more instances that present an imminent 
danger to the health, safety, or well-being of a program patient or place the program patient 
unnecessarily in high-risk situations. See 42 CFR 476.1.  
 
Health Care Service or Services: Services or items for which payment may be made (in whole or 
in part) under the Medicare or State health care programs. (QIOs review only those services for 
which payment may be made (in whole or in part) under Medicare.) See 42 CFR 1004.1(b). 
 
Immediate Advocacy: An informal alternative dispute resolution process used to quickly resolve 
an oral complaint a Medicare beneficiary or his/her representative has regarding the quality of 
Medicare-covered health care received. This process involves a QIO representative's direct 
contact with the practitioner and/or provider. See 42 CFR 476.1. 
 
Initial Determination Peer Reviewer: A practitioner reviewer who makes the interim and final 
initial determinations in the Quality of Care Review process. 
 
Medicare Health Plan(s): For purpose of this Chapter, a collective reference to Medicare Part 
C Health Plans, Medicare Part D Drug Plans, Cost Plans under section 1876 of the Act, and 
Health Care Prepayment Plans (HCPPs) under 1833 of the Act. 
 
Norm: A pattern of performance in the delivery of health care services that is typical for a 
specified group. See 42 CFR 476.1.  
 
Pattern of Care: Care under question has been demonstrated in more than three instances each 
of which involved different admissions. See 42 CFR 1004.1(b) Definitions. 
 
Peer Review: A review by health care practitioners of services ordered or furnished by other 
practitioners in the same professional field. See 42 CFR 476.1. 
 
Peer Reviewer: A reviewer who is either a physician or other practitioner who matches, as 
closely as possible, the variables of licensure, specialty, and practice setting of the physician or 
practitioner under review. The Initial Determination Peer Reviewer and Reconsideration Peer 
Reviewer must meet the requirements of this definition. See 1154(c) of the Act and 42 CFR  476.98(a) (1) and (b) for additional criteria. In cases in which there is no peer match available, 
the QIO may use another physician reviewer without the same expertise. See 42 CFR 476.98(a) 
(2). 
 
Physician: A doctor of medicine or osteopathy, a doctor of dental surgery or dental medicine, a 
doctor of podiatry, a doctor of optometry, or a chiropractor, as described in 1861(r) of the Act; 
an intern, resident, or Federal Government employee authorized under State or Federal law to 
practice as a doctor; and an individual licensed to practice as a doctor as described in this 
definition in any territory or commonwealth of the United States of America. See 42 CFR  
476.1. 
 
Practitioner: An individual credentialed within a recognized health care discipline and involved 
in providing the services of that discipline to patients.  
 
Provider: A health care facility, institution, or organization, including but not limited to a 
hospital, involved in the delivery of health care services for which payment may be made in 
whole or in part. See 42 CFR 476.1. 
 
Health care practitioners other than physicians: Refers to health professionals who do not hold 
a doctor of medicine or doctor of osteopathy degree but who meet all applicable State or Federal 
requirements for practice of their professions and are in active practice. See 42 CFR 476.1 
and 480.101(b).  
 
Quality of Care: The degree to which health care services for individuals and populations 
increase the likelihood of desired health outcomes and are consistent with current professional 
knowledge. (Definition adopted from The Institute of Medicine). 
 
Quality of Care Concern: A concern that care provided did not meet a professionally recognized 
standard of health care. A general quality of care review or a beneficiary complaint review may 
cover a single or multiple concerns. See 42 CFR 476.1. 
 
Quality of Care Review: A review conducted by a QIO to determine whether the quality of 
Medicare-covered services provided to beneficiaries was consistent with professionally 
recognized standards of health care. A Quality of Care Review can be either a Beneficiary 
Complaint Review or a General Quality of Care Review. See 42 CFR  476. 
 
Quality Improvement Initiative: Any formal activity plan designed to serve as a catalyst and 
support for quality improvement that uses proven methodologies to achieve these improvements. 
The improvements may relate to safety, health care, health, and value, and involve providers, 
practitioners, beneficiaries, and/or communities.  
 
Reconsideration:  For written beneficiary complaints, reconsideration is the additional review 
performed by the QIO when requested by the beneficiary and/or the practitioner/provider when 
any of the parties is not pleased with the outcome of the QIOs Final Determination. See 42 CFR 
476.140(a). For General Quality of Care reviews, reconsideration is the additional review 
conducted by the QIO when requested by the provider and/or practitioner when he/she is not 
pleased with the outcome of the Initial Determination. See 42 CFR 476.170(a). 
  Reconsideration Peer Reviewer: A Peer Reviewer who conducts the reconsideration segment of 
a Quality of Care Review. 
 
Significant Quality of Care Concern:  A determination by a QIO that the quality of care 
provided to a Medicare beneficiary did not meet the standard of care and, while not a gross and 
flagrant or substantial violation of the standard, represents a noticeable departure from the 
standard that could reasonably be expected to have a negative impact on the health of a 
beneficiary. 
 
Standards: Professionally developed expressions of the range of acceptable variation from a 
norm or criterion. See 42 CFR 476.1. 
 
Substantial Violation in a Substantial Number of Cases: A pattern of providing care that is 
inappropriate, unnecessary, does not meet recognized professional standards of care, or is not 
supported by the necessary documentation of care as required by the QIO. See 42 CFR 
1004.1(b), Definitions. 
 
5025 Beneficiary Complaint Review Overview 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
This guidance and instruction addresses the processes in completing reviews of Beneficiary 
Complaints. 
 
NOTE: The intake person(s) refers to qualified staff as designated by a QIO. The job title may 
differ within each QIO and duties may be split among different QIO staff. 
 
The guidance covers: 
 
2.  Initial intake of information that a QIO Staff Member obtains from a beneficiary. (See 
5030-5030.2).  The initial intake of information includes the QIOs determination 
about the type of review to be conductedi.e., whether the complaint is appropriate for 
Immediate Advocacy, and if not, whether the complaint should be processed as a 
Beneficiary Complaint Review.  
 
3.  Immediate Advocacy process to be followed for complaints for which Immediate 
Advocacy has been offered and accepted. (See 5035-5035.5.)  
 
4.  Beneficiary Complaint process and review instructions. (See 5040-5055.7.)  
 
5025.1  Eligibility for Beneficiary Complaint Review 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
For a complaint to be eligible for a Beneficiary Complaint Review (see 5040  5055.7), ALL 
of the following requirements must be met. 
 
The complaint must:  
 
1.  Relate to the quality of care received by a beneficiary, regardless of whether the  beneficiary or Medicare paid for the care, but for which payment may otherwise be made 
under title XVIII;  
 
2.  Be written (includes email, facsimile, or hard-copy submission); and 
 
3.  Express concern about the quality of care received.  
 
NOTE: See 5040.4 (Beneficiary Complaint: Complaints Not Submitted in Writing) for oral 
complaints. 
 
5030  Beneficiary Complaint Intake  Stage One 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
QIOs may become aware of a potential beneficiary complaint through a phone call or 
correspondence, including the receipt of a complaint by regular mail, email, or facsimile. The 
QIO is responsible for ensuring that enough information is obtained from the beneficiary to 
complete the review, whether Immediate Advocacy or a Beneficiary Complaint Review. 
 
It is anticipated that, in most instances, a beneficiarys initial contact with a QIO about a 
potential complaint will be made by phone. QIOs may also be referred calls from 1-800 
Medicare. For calls to 1-800 Medicare, once the beneficiary indicates, through answering a 
series of questions, that the call is regarding a complaint related to the quality of care received, 
the beneficiary is transferred to the appropriate QIO.  
 
CMS developed the Medicare Quality of Care Complaint Form, CMS-10287 (Complaint Form), 
for beneficiaries to use in submitting a complaint (See Appendix 5-1.1) (See 5040.1-5040.3 of 
this Chapter for information about the use of the Complaint Form.)  
 
When a request for information from or on behalf of a beneficiary is received, the QIO must 
follow 42 CFR 480.132; the QIO must disclose the information to a person whom the 
beneficiary has identified as his/her representative or has been designated by State law. Under 
42 CFR 480.132(c), if the beneficiary has not and is not able to designate a representative and 
State law has not designated a representative, the QIO determines who is responsible for the 
beneficiary and makes disclosure to that person.  
 
A beneficiary representative is either appointed by the beneficiary or authorized under 
applicable law. See 42 CFR 476.1. In situations where the representative does not have any 
evidence of his/her status, the QIO should inform the representative of the availability of the 
Appointment of Representative Form. The QIO can either provide the representative with a copy 
of the form directly or instruct them that they may obtain a copy of the form directly by visiting 
the CMS forms web page. See Appendix 5-1.2 or visit 
http://www.cms.hhs.gov/cmsforms/downloads/cms1696.pdf. 
 
CMS expects QIOs to concurrently enter any information received into the CMS-designated case 
review system (See 5030.4) so that it is readily accessible to pertinent staff. 
 
5030.1  Scope of Complaint 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16)   
In obtaining information from the beneficiary about the nature or scope of the complaint, the 
QIO must focus on the episode of care to which the complaint pertains. The beneficiary is not 
required to identify all specific aspects of the medical care received during the episode in 
describing the complaint, nor is the beneficiary required to specifically state that the practitioner 
and/or provider did not meet professionally recognized standards of care.  
 
The QIO should not unnecessarily narrow the focus of the scope of a review based on a 
beneficiarys statements about why care was problematic because most beneficiaries are not 
health care practitioners or providers, and thus they do not have sufficient knowledge and/or 
experience to render such judgments about the care received.  
 
In addition, as the expert in conducting Quality of Care Reviews, a QIO should not focus solely 
on a beneficiarys assumptions and/or conclusions about the care received. The beneficiarys 
assumptions and/or conclusions may be misleading or not relate to the actual problem 
encountered. For instance, a beneficiarys statement about a single problematic aspect 
associated with an episode of care (e.g., the wait time in the emergency room was too long) or 
why the beneficiary believes the care did not meet professionally recognized standards of care 
(e.g., the physician should have ordered a specific test based on the beneficiarys health 
condition) may not be the reason the beneficiary received poor care or received appropriate 
care but experienced a negative outcome. 
 
The following examples are designed to assist QIOs in taking the appropriate approach during 
review of a Beneficiary Complaint:  
 
  EXAMPLE 1: A beneficiarys spouse contacts the QIO and complains about the care the 
beneficiary received while in the hospital. In discussing the concerns, the spouse 
specifically mentions the length of time the beneficiary waited in the emergency room 
before the beneficiary was admitted. The spouse also mentions that the beneficiary might 
have received the incorrect medication during the hospital stay.  
 
  In this scenario, the scope of the QIOs review is not limited to the wait time 
o
in the emergency room and the medication provided to the beneficiary. A 
QIOs review should include ALL care the hospital provided to the 
beneficiary, from arrival in the emergency room through the conclusion of the 
hospital stay. A QIO must convey information about any Quality of Care 
Concern for which care did not meet professionally recognized standards of 
care related to the beneficiarys hospital stay as well as the QIOs 
conclusions about the specific concerns the spouse mentioned (emergency 
room wait and medication error) in the complaint, even if the standard of care 
was met for these issues.  
 
  EXAMPLE 2: A beneficiary contacts the QIO to complain about medication, which was 
requested but never received, during a 6-hour stay in a hospital. The beneficiary 
ultimately left the hospital without receiving medication. During the QIOs review, the 
QIO confirms the beneficiarys description but in addition, the QIO determines that the 
beneficiary was in a lock-down unit of a psychiatric hospital and should not have been 
allowed to leave. In this scenario, the scope of the QIOs review is not limited to the  failure to receive the medication requested. 
 
  The QIOs review  should include ALL care provided to the beneficiary by the 
o
psychiatric hospital, including the failure to properly lock down the facility, 
which resulted in the beneficiary being able to leave. The QIO must convey 
information about any Quality of Care Concern for which care did not meet 
professionally recognized standards of care related to the hospital stay 
(failure to properly lock down the facility) as well as the QIOs conclusions 
about the specific items the beneficiary mentioned (failure to receive 
requested medication and the length of wait time). 
 
  EXAMPLE 3: A beneficiary representative called to complain that an elderly beneficiary 
who was a relative, had told the representative that the wrong antibiotic medication was 
given during a recent hospitalization for pneumonia. Through chart review, the QIO 
discovered that the antibiotic medication was correct and administered timely, but the 
beneficiary had received an overdose of anti-seizure medication during the same episode 
of care. 
 
  The QIOs review must include a review of ALL care provided to the 
o
beneficiary during the episode. The QIO must convey information about any 
Quality of Care Concern for which care did not meet professionally 
recognized standards of care (i.e. the overdose of the anti-seizure medication) 
as well as the QIOs conclusions about the specific item the beneficiary 
representative mentioned (wrong antibiotic medication), even where the 
QIOs review demonstrates that the standard of care was met for the 
antibiotic medication. 
 
5030.2  Initial Information Collection 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
After receiving a call from a beneficiary or during the review of a complaint received via 
correspondence, the QIO should collect and record basic information about the potential 
complaint in the CMS-designated case review system on an ongoing basis during the course of a 
review, including completion of the initial contact.  
 
In addition, the QIO must determine whether the complaint is eligible for Immediate Advocacy, 
or if Peer Review as part of a Beneficiary Complaint Review (under 476.130), or a General 
Quality of Care Review (under 42 CFR 476.160)) is required during the initial call or contact 
with the beneficiary.   
 
NOTE: Written beneficiary complaints are not eligible for Immediate Advocacy. These steps 
apply only to telephonic or face-to-face encounters with a beneficiary who is making or has 
made a complaint about a quality of care concern. 
 
To meet the deadlines and timeframes imposed by 42 CFR 476 for Quality of Care Reviews, 
QIOs should respond to messages received after normal business hours by close of the next 
business day. 
  The following list contains information deemed necessary for the completion of intake process of 
a beneficiary complaint. The QIO should attempt to collect this information during the initial 
contact from the beneficiary. Much of the information might already be accessible using the 
CMS-designated case review system. (See 5030.4.) If specific information is not readily 
available, the QIO should ensure appropriate follow-up is completed to obtain the information 
from the beneficiary. 
 
The following information is the minimum necessary for the QIO to perform the initial screening 
of a beneficiary complaint and must be collected.  The QIO should obtain or note the following 
information:  
 
1.  The beneficiarys name, age, date of birth, sex, Healthcare insurance identification 
number, and race/ethnicity (if willing to provide). 
 
2.  The beneficiarys phone number, address, and email address. 
  
3.  The name of the caller if other than the beneficiary, including phone number, address, 
and email address; this person should be e.g. the beneficiary representative. 
 
NOTE: If the caller is other than the beneficiary (e.g., beneficiary representative) the 
QIO must obtain a completed Authorization of Representative Form included in 
Appendix 5-1.2), prior to continuing with specifics about health care issues and the 
detailed complaint. 
 
4.  The date and time the complaint was received.  
 
5.  General information about the health care issue(s) surrounding the complaint. The focus 
of the information collected must be on the general circumstances related to the episode 
of care. The beneficiarys assumptions and/or conclusions about the care received, 
including statements regarding a single problematic aspect associated with an episode of 
care or why the beneficiary believes the care did not meet professionally recognized 
standards of care, are not necessary to process the complaint.  
 
NOTE: QIOs should avoid narrowly focusing the scope of a review based on the 
beneficiarys statements about why care was problematic because most beneficiaries are 
not health care practitioners or providers, and thus they are not likely to have sufficient 
knowledge and/or experience to render such judgments about the care received. See 
5030.1, Scope of Complaint for additional instructions regarding the nature of the 
complaint. 
 
6.  The QIO must request the beneficiarys permission to disclose to the 
practitioner/provider the beneficiarys name and the reason for any medical information 
requested and document the beneficiarys response. A QIO is required to inform the 
practitioner and/or provider that the medical information is being requested due to a 
beneficiary complaint. See 42 CFR 476.130(b) (2).  
 
NOTE  The QIO must explain to the beneficiary that if he/she chooses not to disclose 
his/her name as part of the complaint process, the complaint may be processed as a General  Quality of Care Review, if the QIO deems appropriate. (See 5100 General Quality of Care 
Review.)  
 
Any additional information that may be helpful in processing the complaint should also be 
documented in the CMS case review system -- e.g., notes related to the conversation with the 
beneficiary, any discussions with internal staff about the complaint. 
 
In order to properly conduct screening, the QIO must be able to identify the following from the 
information the beneficiary provides in the complaint: 
 
1.  The State in which the complaint originates. 
 
NOTE: The QIO for the area that includes the State in which the care was received is the 
QIO that has authority to conduct the review. 
 
2.  The name of the practitioner(s) or provider(s) who is/are the subject of the complaint.  
 
3.  The setting in which the care that is the subject of the complaint took place/originates
e.g., during a physicians office visit, hospital admission, skilled nursing facility stay, or 
other. 
 
4.  Whether the beneficiary:  
 
  Has been discharged from the facility or is no longer receiving services;  
 
  Is still in the facility or is still receiving the services in question; and 
 
  Intends to file a written complaint. 
 
5.  The overall severity of the Quality of Care Concerns involved in the complaint to 
determine whether Immediate Advocacy can be offered and if any concern could be 
deemed gross and flagrant, substantial, or significant. (See 5035). The QIO 
staff member who identifies the potential gross and flagrant, substantial, or 
significant concern should consult with the QIO as needed in making such 
determinations. 
 
If any concerns the beneficiary raised could be designated gross and flagrant, 
substantial, or significant, the complaint is NOT eligible for Immediate Advocacy. 
See 5035 for information and process requirements for Immediate Advocacy. The QIO 
may consult with the QIO as needed in making such determinations. 
 
The QIO is responsible for coordination and implementation of the medical record review 
process through the application of established written criteria based on typical patterns of 
practice in the QIO area, or use of national criteria where appropriate. See 42 CFR 476.100 
(c)(1). The QIO assesses medical necessity, appropriate level of care and quality of services 
provided. The QIO is responsible for timely and accurate completion of all medical record 
review including data entry into the CMS-designated case review system in accordance with 
CMS contract requirements.   
Any additional information that may be helpful in processing the complaint should also be 
collected and documented (e.g., notes related to the conversation, any discussions with internal 
staff about the complaint. 
 
In situations where the beneficiary states that he/she may cause harm to self or others or where 
the beneficiary indicates other patients may be at risk of potential harm, the QIO should 
immediately contact the QIO to discuss the circumstances. 
 
The beneficiary must provide permission to disclose to the practitioner/provider the 
beneficiarys name and the reason for any medical information requested. A QIO is required to 
inform the practitioner and/or provider that the medical information is being requested due to a 
beneficiary complaint. See 42 CFR 476.130(b)(2).  
 
The QIO is expected to explain to the beneficiary that if he/she chooses not to disclose his/her 
name as part of the complaint process, the complaint may be processed as a General Quality of 
Care Review, if the QIO deems appropriate. (See 5100 General Quality of Care Review.)  
 
NOTE: Once a written complaint is received, Immediate Advocacy may not be offered. 
 
NOTE: If it is determined at any point during the intake of a complaint that the matter is not 
within the QIOs review responsibility (e.g., inappropriate referral for a billing issue, the matter 
occurred outside the QIOs service area), but is the responsibility of another CMS component or 
contractor such as the Medicare Administrative Contractor (MAC), the caller should be 
provided with sufficient information to contact the appropriate entity. The QIO may offer to refer 
the matter to the other entity after obtaining the beneficiarys oral agreement (Written consent is 
not required). 
 
  Alternatively, if it is determined that the call is not a Beneficiary Complaint but does 
relate to an issue for which the QIO is responsible (e.g., an expedited discharge appeal), 
the QIO must follow the procedures in place for those types of reviews.  
 
5030.3  Initial Offer of Review 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
After collecting the above information from the beneficiary, the QIO must: 
 
1.  Briefly review the information collected, including the concern(s) raised by the 
beneficiary, and ask the beneficiary if he/she has any additional information to provide. 
 
2.  Determine whether Immediate Advocacy could be used to resolve the complaint (See 
5035) or if the complaint should be reviewed in accordance with the Peer Review 
process (See 5040 for Beneficiary Complaint Review and 5100-5125 for General 
Quality of Care Reviews.)  
a.  In making this determination, the QIO should consider the information collected 
(See 5030.2) from the beneficiary, including the Scope of the Complaint. (See 
5030.1.)  
  3.  If the complaint is deemed ELIGIBLE for Immediate Advocacy, the QIO must discuss the 
availability of Immediate Advocacy with the beneficiary and provide the beneficiary with 
the opportunity to ask questions about Immediate Advocacy in general.  
 
4.  If the complaint is deemed INELIGIBLE for Immediate Advocacy, the QIO must explain 
the Beneficiary Complaint Review Peer Review process, including the need for a written 
complaint, and ask the beneficiary whether he/she has any questions about the process in 
general.  
 
5.  The QIO should also provide information about the Beneficiary Satisfaction Survey and 
ask the beneficiary if he/she would like to participate in the Survey.  
 
6.  The QIO should also provide information about the Beneficiary Satisfaction Survey and 
ask the beneficiary if he/she would like to participate in the Survey. 
 
7.  End the call by letting the beneficiary know the immediate next steps depending on 
whether the beneficiary elects to pursue the complaint through Immediate Advocacy or 
through the Peer Review process. For the Peer Review process, this includes informing 
the beneficiary that the QIO will call once the signed Complaint form is received. The 
QIO should contact beneficiaries within one (1) business day of receiving the signed 
Complaint form. 
 
5030.4  Use of CMS-Designated Case Review System 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
QIOs have an obligation under 1154(a)(9) of the Act to collect and maintain all information 
that is necessary to perform their functions.  In order to ensure that information is maintained 
and available to CMS (see 42 CFR 480.130), QIOs are required under their contracts to use the 
CMS-designated case review system to record all data/information collected for all written and  
oral complaints, including complaints handled through the Immediate Advocacy process. This 
applies to any information the beneficiary provides during the initial intake of the complaint, 
including a thorough description of the complaint, any notes obtained during the intake process 
or other individuals involved in processing the complaint, and the names of staff inputting 
information in the CMS-designated case review system. This data collection process is designed 
to help resolve any questions that may arise about a specific complaint and ensures that all 
pertinent information related to a complaint is uniformly recorded and centrally located in the 
CMS-designated case review system.  
 
Any oral communication between the QIO, the beneficiary, the QIO, and the practitioner and/or 
providers should be documented in the CMS-designated case review system. For Beneficiary 
Complaints, oral communication information should be documented in the CMS-designated case 
review system. In addition, CMS will use the documentation in the system to review and ensure 
that QIO work in this area is consistent with the applicable law and that beneficiaries, providers, 
and practitioners are provided the review and reconsideration rights to which they are entitled. 
 
For complaints deemed appropriate for Immediate Advocacy, the following information should 
be collected and entered in the CMS-designated case review system:  
    Date that consent is obtained from the parties to participate in the Immediate Advocacy 
process; 
 
  Pertinent parts of the conversation between the QIO and the beneficiary during the 
Immediate Advocacy process; and 
 
  Date of phone conversation that led to discontinuation of the Immediate Advocacy 
process and the outcome of the Immediate Advocacy process. 
 
For written Beneficiary Complaints, the following information should be collected and entered 
in the CMS-designated case review system:  
 
  Date(s) the QIO requests medical records or other pertinent information from the 
practitioner/provider by phone, in writing, fax, or CMS approved method for secure file 
transfer in order to conduct a Peer Review;  
 
  Pertinent parts of the phone (or in-person) conversation between the QIO and the 
practitioner and/or provider when the QIO orally communicated their Interim Initial 
Determination;  
 
  QIOs phone (or in-person) conversation with the beneficiary and the 
practitioner/provider when the QIO orally communicated the QIOs Final Initial 
Determination; 
 
  Date the beneficiary and practitioner/provider exercised his/her right to request a 
reconsideration by notifying the QIO orally;  
 
  Date of the phone call (or in-person conversation) and pertinent content of the oral 
communication when the QIO notified the beneficiary and practitioner/provider of the 
QIOs Final Decision;  
 
  Date of the oral conversation between the QIO and the beneficiary when the QIO 
informed the beneficiary of his/her right to resubmit a written complaint after the 
complaint has been abandoned; and 
 
  Date the beneficiary orally contacted the QIO about a complaint when the beneficiary 
does not submit a written Complaint Form by calendar day 31 or advises the QIO during 
the initial discussion that s/he will not submit a written complaint. (See 5210.2.)  
 
For Abandoned Complaints: 
 
If the QIO could not complete its review because the beneficiary failed to participate or 
comply with the complaint review process, then the date of the notice from the QIO to the 
beneficiary and the practitioner/provider informing the parties the complaint has been 
abandoned, including the reason why the QIO believes the complaint has been abandoned,  should be documented. Such notice may be oral or in writing. 
 
For abandoned complaints that the QIO subsequently refers for a General Quality of Care 
Review, refer to 5100 -5120 for further instructions: 
 
NOTE: Use of the CMS-designated case review system is designed to facilitate the resolution of 
any questions that may arise about a specific complaint and ensures that all pertinent 
information related to a complaint is uniformly recorded and centrally located in the CMS-
designated case review system. 
 
5035 Immediate Advocacy 
(Rev.28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
Based on the nature of the concern(s) the beneficiary raised during the Intake Stage, the QIO 
may recommend the use of Immediate Advocacy.  
 
Immediate Advocacy is an informal process the QIO uses to quickly resolve an oral complaint. 
The QIO should summarize the steps in the Immediate Advocacy process for the beneficiary and 
obtain the beneficiarys oral consent to participate in Immediate Advocacy before proceeding. In 
this process, the QIO makes immediate/direct contact with the practitioner and/or provider. 
Immediate Advocacy is a voluntary process. The QIO must also obtain oral consent to 
participate from the practitioner/provider. 
 
NOTE: A beneficiary, practitioner, provider, or the QIO may discontinue Immediate Advocacy 
at any time. (See 5035.5). 
 
NOTE: The use of Immediate Advocacy is not appropriate for situations where the beneficiary 
does not want his/her identity disclosed to the practitioner and/or provider. 
 
5035.1  Objectives of Immediate Advocacy  
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The objectives of Immediate Advocacy are to: 
 
  Provide flexibility in resolving complaints in situations when the traditional Peer Review 
process alone is likely not going to reach complete resolutionfor example, if the 
complaint includes issues that would not be documented in the medical information, or 
the specific time constraints related to the complaint render the Peer Review process and 
review of the medical information inappropriate. 
 
  Increase beneficiary, practitioner, and/or provider satisfaction throughout the process by 
resolving complaints in a more expeditious and effective fashion. 
 
  Resolve complaints in a more cost-effective manner. 
 
5035.2  Eligibility for Immediate Advocacy 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
  A QIO may offer Immediate Advocacy to the beneficiary prior to obtaining a written beneficiary 
complaint when the following criteria are met: 
 
1. After initially screening the complaint, the QIO determines the complaint was received within 
six (6) months from the date of service on which the care occurred concerning the complaints 
and: 
 
a.  The beneficiary complains about a matter that is unrelated to the clinical quality 
of health care itself but relates to items and/or services that accompany or are 
incidental to the medical care and are provided by a practitioner and/or provider 
(e.g., beneficiary in search of or needing an intervention for resources and/or 
services covered by Medicare, such as a wheelchair that was not delivered, a 
beneficiary concerned about the quality of communication with their practitioner 
and/or provider); or  
 
b.  The beneficiary complains about a matter that, while related to the clinical 
quality of health care the beneficiary received, does not rise to the level of being a 
gross and flagrant, substantial, or serious or urgent quality of care 
concern. This may include situations where the QIO determines that the medical 
information will most likely not contain evidence related to the complaint.  
 
NOTE: A complaint is not eligible for Immediate Advocacy when the beneficiary has 
multiple concerns and the QIO determines that at least one of the concerns is gross and 
flagrant, substantial, or significant. 
 
2. The beneficiary AGREES to the disclosure of his/her name. See 42 CFR 476.110 (a)(3). 
 
3.  All parties orally consent to the use of Immediate Advocacy. See 42 CFR 476.110 (a)(4). 
 
4.  All parties agree to the limitations on redisclosure; namely, all communications, written 
and oral, exchanged during the Immediate Advocacy process must not be redisclosed 
without the written consent of all parties.( See 42 CFR 476.110 (c) and 480.107)  
 
The following examples of complaints are appropriate for Immediate Advocacy:  
 
  The beneficiary complains that the practitioner spoke to him/her in a rude manner or 
otherwise did not treat him/her respectfully.  
 
  The beneficiary contacts the QIO about his/her failure to receive a motorized scooter or 
wheelchair. 
 
  The beneficiary is concerned that he/she received a different colored pill than expected 
and would like the QIO to call the facility to find out what drug was given.  
 
5035.3  Practitioner/Provider Consent to Participate in Immediate Advocacy 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The provider and/or practitioner must also consent to Immediate Advocacy and the conditions  on redisclosure.  Therefore, the QIO must: 
 
1. Contact the practitioner and/or provider to obtain oral consent to participate in Immediate 
Advocacy 
 
2. Inform the provider/practitioner of the receipt of a complaint and the beneficiarys desire to 
pursue resolution of the complaint through Immediate Advocacy; and 
 
3. Convey sufficient information regarding the nature of the complaint to enable the 
practitioner/provider to make an informed decision about agreeing to participate in Immediate 
Advocacy.  
 
Immediate Advocacy is designed to be a faster resolution process, therefore the QIO should 
contact the practitioner and/or provider immediately after the beneficiary consents to Immediate 
Advocacy. 
 
Upon  obtaining  the  practitioner/providers  oral  consent  to  participate  in  Immediate 
Advocacy, the QIO should follow the Immediate Advocacy procedures in 5035.4 to resolve the 
complaint.  
 
If the practitioner/provider opts NOT to participate in the Immediate Advocacy process, the 
QIO must immediately contact the beneficiary and give him/her the opportunity to file his/her 
complaint in writing. (See 5040 Beneficiary Complaint Review.) 
 
Practitioner/Provider is Unavailable: In some circumstances, the practitioner/provider may be 
unavailable for a period of time after the beneficiary consents to the use of Immediate Advocacy. 
In these situations, the QIO should contact the beneficiary to explain the circumstances and 
discuss the available options. Immediate Advocacy should not extend beyond 10 days from the 
initial effort to contact the practitioner/provider. 
 
5035.4  Immediate Advocacy Procedures 
(Rev.28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Once oral consent is obtained for all parties, the QIO may either use conference call/three-way 
call or make a call on behalf of the beneficiary to obtain resolution of the beneficiarys oral 
complaint. The focus of the call should be to provide a quick and amicable resolution of these 
complaints within a short time frame, such as within two (2) business days. 
 
NOTE: With the agreement to use Immediate Advocacy, a Peer Review is NOT performed. In 
addition, medical information should not be requested from the practitioner/provider. 
 
Practitioner and/or Provider is Unavailable/ Becomes Unavailable In these situations, the QIO 
should contact the beneficiary to explain the circumstances and discuss options. In no instance 
should the use of Immediate Advocacy extend beyond 10 days from the initial contact with the 
practitioner and/or provider. 
 
Within one (1) business day following the completion of Immediate Advocacy, the QIO should 
update the CMS-designated case review system in accordance with the QIO contract to reflect  resolution of the complaint through the use of Immediate Advocacy and close the case 
accordingly.  
 
While the goal of Immediate Advocacy is to informally and quickly resolve the beneficiarys 
complaint, in certain instances the beneficiary might remain dissatisfied after completion of 
Immediate Advocacy. Should this occur, the QIO must advise the beneficiary of his/her right to 
file a written complaint. The QIO should also consider whether a Quality Improvement Initiative 
should be pursued in accordance with 5125.  
 
5035.5  Discontinuation of Immediate Advocacy  
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Procedures and Requirements for Discontinuation. 
 
If, at any point, the Immediate Advocacy process is terminated or discontinued, the QIO must: 
 
  Inform the beneficiary of his/her right to file a written complaint in accordance with 
5040, Beneficiary Complaint Review; and  
  Notify all parties that the Immediate Advocacy process has been discontinued 
 
Reasons for Discontinuation include the following: 
 
  The beneficiary expresses his/her desire to stop pursuing a complaint through the 
Immediate Advocacy process; 
 
  The QIO becomes aware of additional information that would render the complaint  
ineligible for Immediate Advocacy; or 
 
  The provider and/or practitioner revokes consent to participate in Immediate Advocacy. 
 
5040  Beneficiary Complaint Review Protocols 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
These are the key decision points in determining whether to proceed with a Beneficiary 
Complaint and/or a General Quality of Care Review upon completion of the Intake Process: 
 
  Immediate Advocacy was appropriate, but the beneficiary expressed the intent to file a 
written complaint. 
 
  Immediate Advocacy was not appropriate, and the beneficiary expressed the intent to file 
a written complaint.  
 
  Immediate Advocacy is not appropriate because an oral beneficiary complaint involved 
at least one concern that is significant, substantial, or gross and flagrant, and the 
beneficiary does not wish to submit the oral complaint in writing. When a QIO receives 
an oral complaint, where it finds concern(s) that may be significant, the QIO is 
authorized to perform a General Quality of Care Review of the services related to that  concern. (See 5100 General Quality of Care Reviews). 
 
  Neither Immediate Advocacy nor the written beneficiary complaint processes are 
available options because the beneficiary wishes to remain anonymous. Oral and written 
complaints where the beneficiary wishes to remain anonymous can be processed at 
General Quality of Care Reviews if a quality of care concern is at least a significant one 
or if the QIO deems a General Quality of Care Review appropriate under 42 CFR 
476.160. (See 5100 General Quality of Care Reviews). 
 
5040.1  Beneficiary Complaint: Preparing and Forwarding the Medicare 
Quality of Care Complaint Form 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
After ending the intake call described in 5030.2, the QIO should immediately input basic 
information obtained during the phone call into the Medicare Quality of Care Complaint Form, 
except in situations where the beneficiary has requested that the form be emailed or in situations 
where the beneficiary expressed desire to complete the form himself or herself.  
 
NOTE: A QIO must protect confidential information under 42 CFR 480. Confidential 
information communicated between the QIO and the beneficiary must only be transmitted via a 
secure electronic submission to ensure appropriate protection of the information.  Confidential 
information includes Personally Identifiable Information (PII) and information that would be 
Protected Health Information (PHI) under the HIPAA Privacy and Security Rules (45 CFR Parts 
160 and 164) if the information is from a covered entity (health plan or health care provider) or 
if the QIO were a covered entity.   
 
A QIO is prohibited from using any independently developed complaint forms. A QIO may only 
use the official Medicare Quality of Care Compliant Form (CMS 10287). 
 
The QIO may direct the beneficiary to the QIOs website or the CMS forms web page to obtain a 
copy of the Medicare Quality of Care Complaint Form. To assist the beneficiary in completing 
the Medicare Quality of Care Complaint Form, the QIO should pre-fill the following sections of 
the form with the information provided by the beneficiary before mailing or faxing it to the 
beneficiary:  
 
1.  The beneficiarys name; 
 
2.  The beneficiarys Medicare # (HICN); 
 
3.  The beneficiarys sex and age (if known); 
 
4.  The beneficiarys race/ethnicity (if the respondent is willing to provide it); 
 
5.  The name of the beneficiarys authorized representative (if someone other than the 
beneficiary will be the contact);  
 
6.  The pertinent contact information, including street address and phone numbers for either 
the beneficiary or representative; and   
7.  A brief description of the complaint following the requirements of 5030.1.  
 
NOTE: The QIO can send the beneficiary complaint form by mail, fax, or email from the time 
the information is collected.   
 
NOTE: When the beneficiary requests the form to be sent via email, the QIO must not pre-fill the 
form in order to assure confidentiality.  When sending the complaint form by fax, the QIO should 
ensure that the beneficiary is aware that the fax is being sent and that it will contain confidential 
information.  The QIO must comply with requests from the beneficiary to not pre-fill the 
complaint form. 
Prohibition against Forwarding Additional Information: The Medicare Quality of Care 
Complaint Form and the Appointment of Representative Form are the only forms identified by 
CMS for use in the Beneficiary Complaint Review process. The QIO may forward a cover letter 
explaining the complaint process and any instructions for the complaint process. The QIO 
should not forward any additional information to the beneficiary. The QIO may only mail, fax, or 
email the Medicare Quality of Care Complaint Form and the Appointment of Representative 
Form (Appendix 5-1.2), if applicable (See the discussion of this Appointment Form in the note 
below).  
 
For a copy of the Medicare Quality of Care Complaint Form, see Appendix 5-1.1, Medicare 
Quality of Care Complaint Form and Instructions or visit 
http://www.cms.hhs.gov/cmsforms/downloads/cms10287.pdf. 
 
For a copy of the Appointment of Representative form, see Appendix 5-1.2, or visit 
http://www.cms.hhs.gov/cmsforms/downloads/cms1696.pdf . 
 
NOTE: When a Beneficiary Representative contacts the QIO to file a complaint on behalf of a 
beneficiary, the QIO must question the beneficiary representative about his/her status as a 
representative of the beneficiary in order to establish that the representative has the authority 
to file a complaint and to receive confidential information.  
 
Return of Completed Medicare Quality of Care Complaint Form and/or the Appointment of 
Representative Form:  
 
  In situations where the beneficiary or beneficiary representative requests to return the 
completed forms by email to the QIOs email address, the beneficiary must be advised 
that while returning the completed form by email is an option, the QIO is not responsible 
for the privacy of the beneficiarys private health information and that doing so may not 
offer adequate security for protected health information.  
 
NOTE: Emailed forms or facsimiles are deemed written for purposes of receipt of a signed 
written beneficiary complaint. (See 5040.3.)  
 
5040.2  Beneficiary Complaint: Follow-up  Return of Signed Medicare Quality of Care 
Complaint Form 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
  If the signed Complaint Form is not received within fourteen (14) calendar days of the date of 
the mailing, faxing, or emailing of the form, the QIO should follow up with the beneficiary. The 
QIO should determine if the beneficiary still intends to file a written complaint. The QIO should 
do this no later than calendar day fifteen (15) or the next business day following the 15th day 
after the date the Complaint Form was forwarded.  
 
Upon contact, if the beneficiary continues to indicate a desire to file a written complaint, the 
QIO should work with the beneficiary to determine any additional steps necessary to ensure 
return of a signed Medicare Quality of Care Complaint Form, including forwarding another 
Medicare Quality of Care Complaint Form.  
 
If the beneficiary no longer intends to file a written complaint or after additional follow-up the 
beneficiary fails to comply with the beneficiary review process and does not submit the signed 
Medicare Quality of Care Complaint Form by calendar day thirty (30), then the QIO may follow 
instructions provided in  5040.4 (Beneficiary Complaints: Complaints Not Submitted in 
Writing) and Section 5040.5 (Beneficiary Complaint: Abandoned Complaints and Reopening 
Rights). If the beneficiary is advised that the case will be considered abandoned and closed, the 
beneficiary may submit the signed Medicare Quality of Care Complaint Form at any time if 
he/she chooses to submit a written complaint to initiate the compliant review process. 
 
5040.3 Beneficiary Complaint: Receipt of a Signed Beneficiary Complaint 
Form 
(Rev.28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Upon receiving the signed Medicare Quality of Care Complaint Form, the QIO should date-
stamp the form and scan the form, original envelope, and/or facsimile or email and upload them 
to the CMS-designated case review system, so that the information is available for the 
appropriate QIO within one (1) business day.  
 
The QIO prepares the Beneficiary Quality of Care Complaint Initial Acknowledgement Letter to 
the Beneficiary (Appendix 5-2). The letter should be sent within one (1) business day from the 
date the QIO receives the signed Medicare Quality of Care Complaint Form.  
 
The original envelope, facsimile, or email from the beneficiary indicating the postmark/ date 
received  should be kept with the original signed Medicare Quality of Care Complaint Form and 
the date of receipt in QIO records. Emailed forms or facsimiles are deemed written.  
 
5040.4  Beneficiary Complaint: Complaints Not Submitted in Writing (i.e. Oral 
Complaints) 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
In instances when a beneficiary contacts the QIO about a complaint but does not submit a signed 
Complaint Form by calendar day thirty-one (31)or advises the QIO during the initial discussion 
that he/she will not submit a written complaint, the QIO should: 
 
1.  Close the case as a beneficiary complaint in the CMS-designated case review system.  
  2.  Identify if any  Significant Quality of Care concern(s) is present, and if so, determine if  a 
General Quality of Care review is appropriate under 42 CFR 476.160 in accordance 
with 1154(a)(1)(B) and the procedures in 5050, Beneficiary Complaint: Quality of 
Care Review Stage-One., A  Significant Quality of Care Concern is defined as:  
 
  A determination by a QIO that the quality of care provided to a Medicare beneficiary did 
not meet the standard of care and, while not a gross and flagrant or substantial violation 
of the standard, represents a noticeable departure from the standard that could 
reasonably be expected to have a negative impact on the health of a beneficiary.  
 
The following activities should occur where there exist Significant Quality of Care Concern(s) 
arising out of an oral beneficiary complaint: 
 
1.  The QIO collects sufficient information to complete a General Quality of Care Review. 
 
2.  The QIO considers the concern(s) the beneficiary identified in an oral complaint to be at 
least significant. Violations that are gross and flagrant or a substantial violation in a 
substantial number of cases also meets this standard.  
 
Should the QIO determine that the matter involves a significant concern and the QIO has 
sufficient information to complete its review, the QIO may immediately request the medical 
information and begin the quality of care review (See 42 CFR 476.130 for guidance, and 
Manual 5050 for instruction). 
 
NOTE: Because oral complaints are not processed as written beneficiary complaints, the 
beneficiary shall not receive the results of the review. As such, the disclosure processes detailed 
in 5060.2, Beneficiary Complaint: Preparation of Reconsideration Disclosure Package, and 
5060.3, Beneficiary Complaint: QIOs Final Decision, Preparing and Mailing Letter to 
Beneficiary, are not applicable. If the beneficiary nonetheless requests information, refer to 42 
CFR 480.132. 
 
5040.5- Beneficiary Complaint: Abandoned Complaints and Reopening Rights 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The QIO may determine that a written beneficiary complaint or the Immediate Advocacy process 
has been abandoned if a Medicare beneficiary fails to participate in or comply with the 
requirements of the Beneficiary Complaint Review process or Immediate Advocacy process and 
the QIO does not have enough information to complete its review. If the beneficiary no longer 
intends to file a written complaint, or after additional follow-up, the beneficiary fails to 
participate, the QIO may determine that the case has been abandoned.  
 
When a QIO determines a written complaint has been abandoned, the QIO must: 
 
1.  Inform the parties by phone that the complaint review will be discontinued and document 
the date of the call in the case review notes.  
 
2.  Inform the beneficiary of his/her right to resubmit a written complaint in accordance with 
the procedures in 42 CFR 476.120 and 476.150(b).    
3.  A QIO may reopen a Medicare beneficiary complaint review using the same procedure 
(time period) a QIO would use for reopening initial denial determinations and changes 
as a result of diagnosis-related group (DRG) validation, as described in 42 CFR 476.96 
(See 42 CFR  476.150). A QIO may reopen a beneficiary complaint review within one 
(1) year of the date the original complaint was submitted.  
 
When a QIO determines the immediate advocacy process has been abandoned, the QIO must: 
 
1.  Inform the parties by phone that immediate advocacy has been discontinued and 
document the date of the call in the case review notes.  
 
2.  Inform the Medicare beneficiary of his/her right to submit a written complaint in 
accordance with the procedures in 42 CFR 476.120.  
 
5045  Beneficiary Complaint: Preparing the Beneficiary Complaint Folder 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The QIO is responsible for preparing the official Beneficiary Complaint File for maintenance at 
the QIO, either by hard copy or via the CMS-designated review system document storage, if and 
when available. CMS expects that the QIO will perform this function. A duplicate hard copy of 
the file or access to an approved secure electronic system, when available and approved by 
CMS, may be required for use by an off-site Peer Reviewer. (See 5050.3 for information related 
to the Peer Review process.)(See 5045.4 for more detailed information about the content and 
organization of the folder.) 
 
5045.1  Beneficiary Complaint: Forwarding the Complaint to the QIO 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The Beneficiary Complaint is identified as awaiting review in the CMS-designated case review 
system once the intake process and subsequent entry into the system is completed. Once the 
Beneficiary Complaint is identified as awaiting review, the QIO: 
 
1.  Reviews the Medicare Quality of Care Complaint Form and information in the CMS-
designated case review system to ensure that he/she understands the specific concern(s) 
involved. This includes those instances when multiple concerns have been raised, 
whether the concerns relate to a single complaint or multiple complaints.  
 
2.  Contacts the beneficiary to orally acknowledge receipt of the complaint, CMS expects 
within one (1) business day of receiving the complaint.  
 
During the discussion with the beneficiary, the QIO should obtain additional information (if 
necessary) and describe/explain the following to the beneficiary: 
 
1.  The complaint process to the beneficiary in more detail;  
  
2.  His or her role; 
  3.  The Initial Determination Peer Reviewers role; 
 
4.  The Peer Review process in general; and 
 
5.  The anticipated time frames related to the resolution of the review.  
 
If the QIO is unable to reach the beneficiary by phone, the QIO should follow up with the 
beneficiary within five (5) business days from the date of the initial call attempts. The QIO 
should initiate the review immediately, even in those instances when the beneficiary cannot be 
immediately contacted, unless information necessary for completing the review is still needed.  
 
If the QIO is unable to reach the beneficiary by phone, he/she should contact the beneficiary by 
letter, advising the beneficiary that a review cannot be conducted until the necessary information 
is received. 
 
NOTE: If the QIO is unable to collect the additional information from the beneficiary by 
calendar day thirty (30), contact the beneficiary on calendar day thirty-one (31)(or the next 
business day) and advise the beneficiary that the case will be closed.  
 
5045.2  Beneficiary Complaint: Requesting Medical Information 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The QIO determines the date(s) of the episode(s) of care concerning the beneficiary complaint to 
ensure that the complaint is eligible for Beneficiary Complaint Review. Under 476.120, a 
beneficiary complaint must be filed within 3 years of the episode of care out of which the 
complaint arises. 
 
If the complaint has been timely filed, the QIO should request medical information as soon as the 
written complaint is received with sufficient information to identify the practitioner and/or 
provider. (See 5030.2.) Timely requests should happen no later than one (1) business day after 
receipt of the complaint (See - Medical Record Request Key Process). 
 
Upon request by a QIO, a practitioner and/or provider must deliver all medical information 
requested within fourteen (14) calendar days of the request. 
 
NOTE: The QIO may request the provider submit the information sooner than fourteen (14) 
days if there is a preliminary determination that the complaint involves a potential gross and 
flagrant or substantial quality of care concern as specified in Part 1004 of the Act, and 
circumstances warrant earlier receipt of the medical information.  See 42 CFR 476.130 (b)(1). 
 
For significant complaints, the QIO should request medical information as soon as sufficient 
information has been obtained to identify the pertinent practitioners and providers. For details 
about a QIOs right to request medical information, see 42 CFR 476.78(b)(2), Review 
Responsibilities of Quality Improvement Organizations  Responsibilities of Health Care 
Facilities, and 42 CFR 480.111(a), QIO Access to Records and Information of Institutions 
and Practitioners. 
 
Practitioners/Providers must be informed that they are expected to provide information within  the fourteen (14)-calendar-day timeframe, that the request is the result of a beneficiarys 
complaint, and of the right to discuss the QIOs interim initial determination. The QIO must also 
request the name of a contact person to ensure timely completion of any discussion.  
 
Failure to Provide the Medical Record Requested:  
 
The following paragraphs describe when a Medicare Health Plan or the practitioner/provider is 
responsible for the medical record submission and the steps the QIO must take for CMS to 
investigate or take enforcement action as a result of the failure to provide information when the 
requested medical information is not received. 
 
In situations in which a practitioner/provider fails to submit medical information within the 
required fourteen (14)-calendar-day time frame, the practitioner/provider may be subject to a 
denial of payment under 42 CFR 476.90.  
 
In some situations where either a practitioner and/or provider fails to submit medical 
information within the required fourteen (14)-calendar-day time frame, the QIO should advise 
the practitioner and/or provider that, based on 1156(a)(3), sanctions may be initiated because 
of the failure to support the provision of items or services with evidence of medical necessity  
and quality as may be required. (See Manual Chapter 9, Sanction, Emergency Medical 
Treatment and Labor Act (EMTALA), and Fraud and Abuse for information on initiating a 
sanction process).  
 
NOTE: Upon receiving the beneficiarys medical information at any step, follow the instructions 
as outlined in 5045.4, Beneficiary Complaint: Review and Preparation of Medical 
Information. 
 
Medical Record Request - Key Process Steps 
 
CMS expects the QIO to complete the following steps in requesting medical records and 
\information: 
 
Step 1: Request the medical information within one (1) business day of receiving the written 
complaint. 
 
The QIO may contact the practitioner and/or provider by phone and follow up with a facsimile 
or mailed letter. CMS expects the letter clearly indicate the specific date on which the medical 
information was first requested since this date will be used to determine when a claim denial 
shall be issued for a practitioner/provider. See 5045.3 for information about issuing a claim 
denial.  
 
A QIO may contact either/both the Medical Records Department or the QIO liaison based on 
procedures established with a practitioner and/or provider. 
 
A QIO may obtain the medical information from the practitioner and/or provider via facsimile, 
hard copy, or a secure electronic method when available. The QIO should remain aware of its 
responsibility to protect confidentiality of information at all times when arranging to receive 
medical information.   
Step 2: A QIO should follow up as necessary to ensure adherence to the requested submission 
deadlinei.e., fourteen (14) calendar days from request or earlier in those circumstances where 
the QIO made a preliminary determination that the complaint involved a potential gross and 
flagrant or substantial quality of care concern. 
 
Before making contact, the QIO should verify that: 
 
1.  The QIO has not previously requested and received the medical information by 
conducting a search in the CMS-designated case review system. 
 
2.  The date the medical record is due for receipt by the QIO is correct. The timeframe can 
vary in cases where a potential gross and flagrant quality of care concern is identified.  
 
Step 3: If the medical information is NOT received from the practitioner/provider by calendar 
day fourteen (14) or other date designated by the QIO, contact the practitioners/providers 
senior leadership and notify the provider of the consequences for failure to provide documents 
under 42 CFR 476.90.   
 
If the medical information is NOT received from a practitioner/provider by calendar day 
fourteen (14) or other date designated by the QIO, contact and remind the practitioner/provider, 
under 1156(a)(3), items or services provided by or ordered by practitioners/providers must be 
supported by evidence of medical necessity and quality, in such form and fashion and at such 
time as may reasonably be required by a QIO in the exercise of its duties and responsibilities. 
The QIO should point out that any unreasonable delay in providing medical information could 
lead to sanctions under 1156(b). 
 
Step 4: CMS expects and best practices support that the QIO contact the CMS COR when a 
practitioner/provider has failed to submit a medical record within the designated timeframes.  
 
In addition to contacting the practitioner/provider, the QIO should immediately contact the COR 
and provide sufficient information so that the COR is prepared to contact the practitioner and/or 
provider. The QIO should also follow up with the COR to advise if/when the medical information 
is received.  
 
The COR will call the Medical Records Department, the QIO liaison, and/or senior leadership, 
and convey the responsibilities associated with the request for the medical information on the 
next business day after calendar day fourteen (14) (or the next business day after the date 
established by the QIO when theres been a preliminary determination by the QIO of potential 
gross and flagrant or substantial quality of care concern).  
 
The COR will assess the willingness to comply with the request for medical information and 
explain the potential repercussions of failure to provide the medical information, including: 
 
  Issuing a claim denial;  
 
  Notifying the Division of Medicare Health Plans Operations; and 
    Potential for the QIO to conduct additional reviews. 
 
NOTE: The COR will advise the contact that if the medical information is not received within 
the next calendar day, a claim denial shall be carried out for any claim associated with the care 
described in the complaint.  
 
Step 5: If the medical information is not received from a provider by the next business day 
following calendar day fourteen (14) (or the next business day after the date established by the 
QIO), proceed in accordance with 5045.3, Beneficiary Complaint: Issuing a Claim Denial. 
 
NOTE: In instances where the QIO completes a claim denial in accordance with 5045.3 the 
provider is still required to comply with its responsibility to forward the medical information to 
the QIO for them to complete the Quality of Care Review.  
 
For practitioners and providers, a COR may recommend additional action depending on the 
particular facts of the situation (e.g., recommending that the QIO conduct additional Quality of 
Care Reviews on other patients for whom similar claims have been submitted for payment by the 
practitioner and/or provider).  
 
In instances where the requested medical information is not received within thirty (30) calendar 
days from the date of request, the beneficiary is still entitled to notice of the outcome of the 
review under 476.130(d); however, the specific information should be tailored to the situation 
rather than listing the information identified in 476.130(d). The beneficiary must be advised in 
writing and provided with the following information: 
 
  The QIO is unable to complete the review as a result of the practitioners and/or 
providers failure to submit the medical information. 
 
  For complaints related to practitioners and/or providers: CMS has initiated action to 
deny Medicare payment to the provider for the services surrounding the care referenced 
in the beneficiarys complaint.  
 
  Based on 1156(a)(3), sanctions may be initiated against a practitioner and/or provider 
for failing to support the items or services they have provided with evidence of the quality 
of the items or services.  
 
In instances where the medical information is received within the next thirty (30) calendar days, 
the beneficiary should be contacted and advised that the review will be completed.  
 
5045.3  Beneficiary Complaint: Issuing a Claim Denial 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
A QIO will deny a providers claim in situations where the QIO has requested information from 
a provider and, despite sufficient notice and a reasonable amount of time to respond, the 
provider fails to forward the requested information. See 42 CFR 476.90. 
 
NOTE: Before processing a claim denial, the QIO should coordinate with the appropriate CMS 
COR.    
If the requested medical information is received before the claim denial is finalized, the QIO 
must stop the denial and complete the review. If the medical information is received after the 
claim denial has been finalized, payment must be re-instituted. The QIO must then comply with 
476.130 and complete the review.  
 
5045.4  Beneficiary Complaint: Reviewing and Preparing Medical Information  
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Receipt of Medical Record Documentation/Information: Upon receiving the medical record 
documentation, the QIO should immediately date-stamp the form and scan the form, original 
envelope, and/or facsimile or email. These documents should be uploaded to the CMS-
designated case review system (unless received electronically) within one (1) business day. 
 
The QIO must file the original envelope with the medical record documentation in a hard copy 
file or as a scan of the documents for storage in an electronic file.  
 
Medical Documentation Completeness and Organization: The QIO ensures all information in 
the medical information is complete, appropriately organized, and legible.  
 
If the medical documentation in the medical record is incomplete or illegible (poor copy), the 
QIO may contact the practitioner and/or provider by phone and allow an additional five (5) 
calendar days for submission of the documentation necessary to complete the medical 
information needed for review.   
 
NOTE: QIOs must follow the procedures for issuing claims denials in 5045.3 when complete 
medical record documentation is not received in accordance with the fourteen (14) calendar-day 
timeframe.  
 
The QIO should verify that the medical record documentation received for each medical record 
request contains the major documentation components. Examples include but are not limited to 
the following:  
 
1.  Emergency Room Record/Admission Record; 
 
2.  History and Physical; 
 
3.  Consultations; 
 
4.  Practitioner Orders; 
 
5.  Practitioner Progress Notes; 
 
6.  Nursing Notes; 
 
7.  Ancillary (e.g., laboratory reports, X-rays, medication administration record, 
treatment); 
  8.  Miscellaneous; and 
 
9.  Discharge Summary. 
 
NOTE: QIOs are authorized to upload medical record documentation received directly into the 
CMS-designated system or into a secure electronic system that CMS otherwise designates or 
approves. The documentation should be uploaded within one (1) business day of receiving the 
medical information.  
 
If the QIO staff member preparing the case for review and/or Physician Peer Reviewer(s) 
determine that handwritten information in the medical information cannot be deciphered, the 
QIO may contact the provider and/or practitioner and request a typed/transcribed portion of the 
problem sections of the medical information.  
 
A QIO should make every effort to limit the amount of typed/transcribed information requested. 
Failure to comply with a request for typed/transcribed information shall be treated as a failure 
to provide the medical information if the missing information precludes the completion of the 
review. QIOs must follow the procedures in 5045.3 for processing a claim denial when 
applicable. 
 
5050  Beneficiary Complaint: Quality of Care Review  Stage Two 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
A QIO initiates the Quality of Care Review for Beneficiary Complaint Reviews by conducting a 
preliminary review of the written complaint and each of the Quality of Care Concerns.  
 
For instances when the beneficiary raises multiple concerns that are potentially unrelated, the 
QIO shall determine whether the QIO will process the concerns as a single complaint with 
multiple concerns or as multiple complaints. In making this determination, the QIO should 
consider the following:  
 
  Number of episodes of care; 
 
  Total number of concerns; 
 
  Relationship or inter-relatedness of the concerns; 
 
  Time frames associated with the concerns; 
 
  Impact of different practitioner and/or provider involvement in each of the concerns; 
 
  Health care issues related to each of the concerns; 
 
  Beneficiarys own statements about the relationship between the concerns; and 
 
  Other factors deemed relevant as identified by the QIO. 
  The importance of a particular criterion may be different for different complaints, and the QIO 
should consider the totality of the circumstances.  
 
Consultation with other QIO personnel who have been involved or reviewed the materials is 
recommended when appropriate for making the determination to separate complaints that have 
been uploaded into the CMS-designated case review system as a single complaint.  
 
If a decision is made to process concerns as separate complaints, notice of the QIO 
determination under 476.130(d) must include the rationale for that decision. Further, the 
rationale must be included in the CMS-designated case review system files. 
 
5050.1  Beneficiary Complaint: New Concerns Raised by the Beneficiary 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
As a result of the QIOs broad focus in assessing the scope of the complaint, the QIO should 
rarely become aware of new Quality of Care Concerns after the complaint has entered the 
Quality of Care Review Stage. See Scope of Complaint, 5030.1.  
 
New issues/concerns may be added to the original complaint if the Interim Initial Determination 
step has not been completed. 
 
NOTE: In the rare event that a beneficiary raises a new issue/concern(s) after completion of the 
Interim Initial Determination (See 5050.4), the new issue/concern is processed as a 
separate/new complaint.  
 
5050.2  Beneficiary Complaint: Preparing the Quality Review Decision (QRD) 
Form 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Once a determination is made about the number of complaints and the specific Quality of Care 
Concern(s) to be addressed during the review, a Quality Review Decision (QRD) Form must be 
prepared for each complaint (See Appendix 5-1.3, Quality Review Decision (QRD) Form). 
The QRD Form is the only form authorized for documenting the concerns addressed in a 
Beneficiary Complaint Review.  
 
CMS created the QRD Form to better account for the multiple individuals involved in reviewing 
a beneficiary complaint and to ensure information related to every beneficiary complaintand 
in particular, every quality of care concernis maintained in an organized, detailed, and 
consistent fashion throughout the review process.  
 
Using the CMS-designated case review system, the QIO: 
 
1.  Prepares a QRD Form that sets out each individual concern; and 
 
2.  Forwards the package to the Initial Determination Peer Reviewer as soon as possible 
following receipt of the medical information.  
 
In addition, the QIO completes the following steps for each concern:    
1.  Evaluates the beneficiary complaint and each Quality of Care Concern in accordance 
with 5030.1, Scope of Complaint. 
 
2.  Evaluates the quality of care with regard to the admission diagnosis and treatment plan 
established for the beneficiary, if applicable. 
 
3.  Evaluates the quality of care for any blatant issues (e.g. Never Events identified as 
hospital acquired conditions that could have been reasonably prevented through the 
application of evidence-based guidelines) (See National Coverage Determination (NCD) 
made as part of CR 6405).  
 
4.  Researches evidence-based practices related to each Quality of Care Concern(s) while 
considering the definition of Quality Care, including reference to relevant norms and 
criteria. If no quality of care standard(s) exists, then the QIO will use available norms, 
best practices, and established guidelines and recommend a potential quality of care 
standard(s). In completing this step, the QIO must thoroughly research all available 
information, including the following: 
 
  Nurse screening criteria (e.g., InterQual, Milliman); and 
 
  Generally available resources, including information available via Internet 
searches. 
 
5.  Complete an assessment section for EACH Quality of Care Concern in the complaint and/or 
identified.  
 
6.  Evaluate additional information pertinent to the case, but unrelated to the standard(s) of 
care. This may include:  
 
  CMS-available information, including Web-based resources (e.g., Nursing Home 
and Hospital Compare); and 
 
  State-based resources, including Web-based literature/information as well as 
practitioner-specific information related to license revocations and referrals to 
the State medical conduct organizations. 
 
7.  Research all available data, at a minimum of three (3) years from the date of service, to 
determine whether the QIO has received similar complaints on the same practitioner 
and/or provider and/or if other potential concerns related to the same 
practitioner/provider are identifiable.  
 
8.  Prepare the package for forwarding to the Initial Determination Peer Reviewer.  
 
5050.3  Beneficiary Complaint: Receipt and Review by the Initial 
Determination Peer Reviewer 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
  The QIO mails or sends the package via a secure electronic method to the Initial Determination 
Peer Reviewer immediately after receiving the Medical Record documentation.  
 
Once the Peer Reviewer receives the medical record documentation, he/she should immediately 
initiate the review.  
 
The Peer Reviewer must review the Quality of Care Concern(s) identified by the beneficiary and 
any additional concern(s) identified by the QIO.  
 
After the Peer Reviewer receives all the medical record documentation, the QIO has ten (10) 
calendar days to ensure that the Initial Determination Peer Reviewer completes the following 
steps: 
 
1.  Completes the review; 
 
2.  Notifies the practitioner and/or provider of the Initial Determination Peer Reviewers 
Interim Initial Determination; and 
 
3.  Notifies the practitioner/provider of the opportunity to discuss the Determination. (See 42 
CFR 476.130(c).)  
 
NOTE: The QIO is responsible for ensuring that the Interim Initial Determination is completed 
within ten (10) calendar-days of receipt of the medical information.  
 
This includes the following: 
 
Peer Reviewer renders an Interim Initial Determination  
 
The practitioner/provider is notified of the Interim Initial Determination and is provided 
with the opportunity to discuss, within the required ten (10)-calendar-day time frame 
(See 5050.3.) The discussion must occur within seven (7) calendar days of the notice to 
the practitioner/provider. 
 
Initial Determination Peer Review Approach 
 
For Individual Concerns  The Peer Reviewer evaluates the standard(s) that the QIO 
identified on the QRD Form and checks off the appropriate box indicating whether he/she 
concurs or does not concur with the standard(s) of care as delineated by the QIO.  
 
  If the Peer Reviewer identifies quality of care concerns not raised by the beneficiary or 
identified by the QIO, the Peer Reviewer must indicate this and identify pertinent 
research describing the standard of care he/she used to identify and evaluate the 
concern. 
 
  If the Peer Reviewer determines that the standard(s) that the QIO identified for a specific 
concern(s) is incorrect or not appropriately thorough, the Peer Reviewer must identify 
the correct standard(s) and provide an explanation about the change.  
    For instances when the Peer Reviewer determines that the standard(s) is incorrect, the 
Peer Reviewer must include a rationale, with references to relevant literature/research 
and/or medical information supporting his/her decision on the appropriate standard(s) of 
care in the QRD Form.  
 
The Peer Reviewer then applies the standard(s) of care to the specific facts of the case and the 
Quality of Care Concern(s) at issue. The Peer Reviewer evaluates the medical information based 
on the standard(s) as identified, including each evidenced-based element of the standard(s) of 
care. For a complete and adequate peer review, CMS expects each Peer Reviewer to: 
 
1.  Evaluate whether the quality of care standard for each identified concern is met based on 
the facts of the case and directly link his/her decisions to elements contained in the 
evidence-based standard(s), or in the absence of evidence-based standards of care, will 
use available norms, best practices, and established guidelines.  
 
2.  Assess the responsibility of the individual identified by the beneficiary to determine if the 
individual identified is different from the individual who is responsible for the standard(s) 
not being met.  
 
3.  Consider any historical data pertinent to the concern as provided by the QIO, and 
highlight specific evidence from the review of the medical information demonstrating that 
specific elements within the standard(s) of care are or are not met.  
 
NOTE: The Peer Reviewer should also include any other information that the reviewer deems 
relevant to the Interim Initial Determination.  
 
If the Peer Reviewer concludes that there are extenuating circumstances to consider (e.g., 
emergent circumstances or exceptional complexity), the Peer Reviewer must thoroughly explain 
these and how they are relevant to the Interim Initial Determination.  
 
After completing the Rationale/Justification portion for each concern on the QRD Form, the 
Peer Reviewer must identify (and document), by checking off the appropriate box, whether the 
standard(s) of care was met or was not met for each concern. This decision/determination must 
be based on the analysis and justification. 
 
If the Peer Reviewer determines that the standard of care was not met for a concern, the Peer 
Reviewer must also check off the appropriate box indicating whether any of the following 
findings is also present: 
 
1.  The care grossly and flagrantly violated the practitioner/providers obligation to provide 
care, in one or more instances, that is of a quality that meets the professionally 
recognized standards.  
 
2.  The care failed in a substantial number of cases (more than three) to substantially 
comply with the obligation to provide care that is of a quality that meets the 
professionally recognized standards.  
 
3.  The care failed to substantially comply with the obligation to provide care that is of a  quality that meets the professionally recognized standards.  
 
4.  The care was not a substantial failure of a quality that meets the professionally 
recognized standards, but was a significant concern. 
 
5.  The care did not meet the standard of care, but was less than a substantial violation of 
the obligation to provide care that is of a quality that meets the professionally recognized 
standard. 
 
The Initial Determination Peer Reviewer must complete the review of the medical information, 
completely and accurately fill out the QRD Form to document the determination review 
thoroughly, and return the review package to the QIO in the agreed upon timeframes.  
 
The Peer Reviewer must sign and date the QRD Form and indicate the amount of time spent 
reviewing the complaint. Except in circumstances when the Peer Reviewer conducts the review 
on the QIO premises or electronically through a secure site, the reviewer may maintain a signed 
copy of the completed QRD Form and additional copies of notes in a secure location. These may 
be maintained by the Peer Reviewer to facilitate any additional review necessary based on the 
receipt of additional information during the Opportunity for Discussion Stage. 
 
5050.4  Beneficiary Complaint: QIO Review of Interim Initial Peer Review 
Determination 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Immediately upon receipt of the Beneficiary Complaint folder from the Initial Determination 
Peer Reviewer, the QIO must ensure all necessary information is returned and the QRD Form 
has been signed.  
 
A QIO may use its discretion in providing a specific number of calendar days for review of the 
package to ensure the Peer Reviewer: 
 
1.  Rendered a decision on all quality of care concerns; 
 
2.  Adhered to the correct format in providing comments; and 
 
3.  Provided a rationale for conclusions that is clear, cogent and based on the available 
information and applicable standard of care. 
 
However, a QIO is required to have the Initial Determination Peer Review completed and the 
practitioner and/or provider notified of the Peer Reviewers Interim Initial Determination within 
ten (10) calendar days after the Peer Reviewer receives all medical information.  
 
NOTE: Additional procedures are applicable if the Initial Determination Peer Reviewer has: 
 
1.  Identified a concern(s) as either gross and flagrant, or the care failed in a substantial 
number of cases (more than three) to substantially comply with the obligation to provide 
care that is of a quality that meets professionally recognized standards of health care as 
required by 1156(a) of the Act.   
  The QIO must initiate sanction proceedings in accordance with IOM Chapter 9.  
o
 
2.  Determined that the standard(s) of care was not met for any one or more of the concerns, 
and the concerns are not sanctionable.  
 
The QIO must provide notice and an opportunity for discussion to the practitioner and/or 
provider. See the procedures detailed in 5055, Beneficiary Complaint: Opportunity for 
Discussion - Stage Three. 
 
5055  Beneficiary Complaint: Opportunity for Discussion  Stage Three 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
In accordance with 1154(a)(14) of the Act, before a QIO concludes that the quality of services 
does not meet professionally recognized standards of health care, the QIO  must give the 
practitioner and/or provider reasonable notice and opportunity to discuss the concerns found.  
  
5055.1  Beneficiary Complaint: Notification of Opportunity for Discussion 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
If, after reviewing the Interim Initial Peer Review Determination package, the QIO determines 
that the Peer Reviewer has identified a concern(s) for which the standard(s) of care was not met, 
the practitioner and/or provider must be offered the opportunity to discuss the concern(s). The 
QIO must make the effort of an offer, by telephone to the practitioner/provider to discuss the 
interim initial determination with the QIO in those situations where the peer reviewer determines 
that the quality of services does not meet professionally recognized standards of care for any 
concern in the complaint. The QIO should document the date on which the offer was first made 
to the practitioner and/or provider, and this may include sending to the practitioner and/or 
provider a facsimile or letter describing the specific concern(s) at issue.  
 
NOTE: A QIO must allow a practitioner to use a representative to respond to the Opportunity 
for Discussion. (See Appendix 5-3, Interim Determination Letter for Practitioners or 
Providers). 
 
In offering the discussion opportunity, the QIO shall make every effort to discuss the Initial 
Determination Peer Reviewers interim determination as expeditiously as possible. The time 
frame for obtaining a response from the practitioner and/or provider shall not extend beyond 
seven (7) calendar days from the date the offer was originally made. In rare circumstances (e.g., 
the practitioner is unavailable [out of the country] for the entire seven (7)-day period), the QIO 
may provide additional time to respond to the offer of a discussion or submission of a written 
response to the interim initial determination.  The additional time should not exceed seven (7) 
calendar days. 
 
The practitioner and/or provider may submit a written response to the opportunity for discussion 
in lieu of a phone call within seven (7) calendar days of receiving the initial offer of an 
opportunity for discussion.  
 
  If a practitioner and/or provider requests to submit a written statement as their opportunity for  discussion in addition to having a phone call, the QIO may accept both the written response and 
phone call discussion with the practitioner and/or provider based on the complexity of the case. 
 
5055.2  Beneficiary Complaint: Oral or Written Response by 
Practitioner/Provider - Opportunity for Discussion 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Personnel 
 
The offer of the Opportunity for Discussion can be made by the QIO, the Initial Determination 
Peer Reviewer, or the Medical Director, depending on the QIOs established practice. However, 
the QIO should participate in discussions between the Initial Determination Peer Reviewer and 
the practitioner/provider to handle any administrative questions or issues that arise during this 
discussion. For complex cases, it is recommended that the Medical Director participate. 
 
Processing Responses 
 
Oral Responses: The QIO must prepare a summary of any oral response submitted to document 
that the discussion occurred. During the oral discussion, the practitioner and/or provider should 
be advised of the need to focus on the specific element(s) of the standard(s) of care or the care 
provided to the beneficiary that is being disputed in the Initial Determination Peer Reviewers 
Interim Determination.  
 
Written Responses: The practitioner and/or provider should be advised of the need to focus on 
the Initial Determination Peer Reviewers conclusions related to specific elements of the 
standard(s) of care. Written statements submitted for the Opportunity for Discussion must be 
sent to the QIO for processing and properly documenting the review file for the Peer Reviewer.  
 
5055.3  Beneficiary Complaint: Prohibition on Submission of New/Additional 
Medical Information 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The submission of new and/or additional medical information does not occur in response to the 
offer of the Opportunity for Discussion because the Reconsideration process (42 CFR 476.140 
(a)(3)) provides an opportunity to submit additional information.  
 
NOTE: In instances when the practitioner and/or provider requests to submit new and/or 
additional medical information, the QIO should advise the practitioner and/or provider of 
his/her right to request a reconsideration and that any new and/or additional medical 
information can be considered during the reconsideration process. CMS considers it a basic 
premise of fairness that beneficiaries, practitioners and/or providers are notified of the ability to 
file a request for reconsideration in connection with complaints filed after July 31, 2014. 
 
5055.4  Beneficiary Complaint: Reviewing Response Submitted during 
Opportunity for Discussion 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
  A Final Initial Determination must be completed within three (3) business days of the discussion 
with the practitioner/provider and/or receipt of written statement(s). The review process must 
take place and be completed in an appropriate timeframe. The QIO reviews the summary of any 
oral response that the practitioner and/or provider has submitted, or the written Opportunity for 
Discussion response, in light of the quality of care concern(s) raised during the Initial 
Determination Peer Review. For both oral and written responses, the QIO must make every 
effort to highlight/summarize the specific facts the practitioner and/or provider provided during 
the discussion in relationship to particular elements of the standard(s) of care that could alter 
the Initial Determination Peer Reviewers Interim decision. (As noted in 5055.3, facts provided 
during the discussion stage cannot include new medical information). The QIO must also 
describe any information/rationale provided by the practitioner and/or provider that appears to 
be unrelated to the standard(s) of care. 
  
The QIO shall forward the information, along with specific issues identified in the response, to 
the Initial Determination Peer Reviewer for consideration as soon as possible after completing 
an oral discussion and/or receiving the written response. This ensures that the QIO adheres to 
the three (3)-business-day (from the date of response) timeframe for notifying the beneficiary 
and the practitioner and/or provider by telephone of its Final Initial Determination.  
 
NOTE: The QIO should ensure that the same Peer Reviewer renders both the Interim and/or 
Final Initial Determinations, unless rare circumstances exist (e.g., the Interim Initial 
Determination Peer Reviewer is unavailable due to serious illness).  
 
In most instances, the QIO will not be required to mail the Initial Determination Peer Reviewer 
the entire Beneficiary Complaint file but the Peer Reviewer should be provided with information 
necessary from the file to complete the Final Initial Determination. The following are best 
practices for completing the review process: 
 
1.  The Peer Reviewer uses the copy of the QRD Form from the Interim Initial 
Determination in evaluating the information the practitioner and/or provider supplied to 
the QIO during the Opportunity for Discussion.  
  
2.  Additional materials are usually unnecessary in situations where the practitioner and/or 
provider conveyed information orally directly to the Peer Reviewer.  
 
3.  The QIO and the Peer Reviewer coordinate to ensure all pertinent information is 
considered in the Final Initial Determination. 
 
4.  After making the Final Initial Determination, the Initial Determination Peer Reviewer re-
signs the QRD Form and sends it back to the QIO. The signed form may also be faxed to 
expedite review.  
 
The QIO must ensure that the beneficiary and the practitioner and/or provider are informed by 
phone of the Peer Reviewers Final Initial Determination, regardless of the findings about 
whether the standard(s) of care were met or not met, no later than three (3) business days after 
the completion of its review. (See 5055.6.)  
 
  The QIO must also issue a Final Initial Determination letter to the parties within five (5)  calendar days after the QIO completes its review. (See 5055.6.)  
 
NOTE: The time frame for completing review includes the Initial Determination Peer 
Reviewers review as well as any additional review the QIO conducts after the peer review is 
complete (e.g., quality assurance of the Final Initial Determination letter). 
 
5055.5  Beneficiary Complaint: No Response to Opportunity for Discussion 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
If no response is received regarding the offer of the Opportunity for Discussion within seven (7) 
calendar days or the practitioner/provider agrees with findings, the Interim Initial 
Determination becomes the Final Initial Determination. 
 
The Initial Determination Peer Reviewer need not sign the QRD Form again to denote this 
result; however, the QIO will note on the QRD Form that no response was received. 
 
5055.6  Beneficiary Complaint: Preparing the Final Determination Letter to 
Practitioners/Providers and Beneficiaries 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The QIO shall follow the procedures in this Section for preparing the QIOs Final Determination 
Letters (Appendix 5-4.1 and 5-4.2). 
 
Upon receiving the QRD Form, the QIO prepares the Final Determination Letter to 
Practitioners/Providers (Appendix 5-4.1) and Beneficiaries (Appendix 5-4.2) conveying the 
decision to the practitioner and/or provider, and advising the practitioner and/or provider and 
the beneficiary of the right to request a reconsideration within three (3) calendar days.  
 
The QIO should: 
 
  No later than 3 business days after completion of the review or end of the discussion 
period notify (by telephone) the beneficiary and the practitioner/provider of the Final 
Initial Determination and of the right to request a reconsideration of the QIO's Final 
Initial Determination; and  
 
  Mail the Final Determination Letter to Practitioners/Providers (Appendix  
5-4.1) and to the beneficiary (Appendix 5-4.2) within five (5) calendar days of completion 
of the review.  
 
NOTE: If the determination is provided by telephone on the third business day and the 
fifth calendar day falls on the same day, the letter should be mailed by 12:00 noon on the 
next business day. See 42 CFR 476.130(d) (2).  
 
The written notice to providers and practitioners must include: 
 
  A statement for each concern that care did or did not meet the standard of care; 
    The standard identified by the QIO for each of the concerns; and 
 
  A summary of the specific facts that the QIO determines are pertinent to its findings, 
including references to medical information and, if held, the discussion with the involved 
practitioner and/or provider. 
 
For all complaints involving providers or practitioners, the letter to the beneficiary (Appendix 5-
4.2) shall include at least ALL of the following: 
 
1. A statement for each quality of care concern identified in the original written complaint and 
whether care did or did not meet the standard of care. 
 
NOTE: This does not include other quality of care concerns identified by the QIO during the 
course of review. 
 
2. A statement defining the standard of care that the QIO identified for each quality of care 
concern raised by the beneficiary.  
 
3. A statement of the facts describing how the practitioner/provider did or did not meet the 
standard of care. The statement of facts should relate only to the facts that were essential in 
determining whether a practitioner and/or provider met professionally recognized standards of 
care. 
 
In the Final Initial Determination Letter for complaints filed after July 31, 2014, a QIO must 
also inform the beneficiary if the QIO receives a request for reconsideration from any of the 
parties, the results of the QIOs Final Initial Determination could change. 
 
The QIO should also inform the beneficiary that if/when a reconsideration is requested and 
reviewed, the beneficiary will receive a QIO Final Decision letter (See Appendix 5-5.2 
Reconsideration Determination Letter to the Beneficiary) at a later date (See 5060.3 for 
issuance of the QIOs Final Decision). 
 
5055.7  Beneficiary Complaint: Failure to Respond to the Final Initial 
Determination and Right to Reconsideration 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
For instances when a practitioner/provider and the beneficiary fail to request a reconsideration 
following notification by phone and receipt of the QIOs Final Interim Determination (Appendix 
5-4.1) and the Final Determination Letter to Beneficiary (Appendix 5-4.2) within the three (3) 
calendar-day period, the QIO shall follow the procedures in 5060.4, Beneficiary Complaint: 
Procedures for Closing a Complaint Review for closing as a completed case in the CMS-
designated case review system. 
 
NOTE: The QIO may pursue, or recommend to the appropriate Quality Innovation Network - 
Quality Improvement Organization (QIN QIO), in accordance with 5125 if deemed 
appropriate. 
  5055.8  Beneficiary Complaint: Responsibility to Protect Information and 
Destruction of Materials 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
As specified at 42 CFR 480.115, the QIO is responsible for protecting information and must 
implement reasonable security measures to ensure the integrity of information and prevent 
unauthorized access. See Manual Chapter 10 for additional information. 
 
No later than thirty (30) calendar days after the Initial Determination Peer Reviewer renders 
his/her final decision, all hard copies of materials that pertain to the specific beneficiary 
complaint in his/her possession must be destroyed in compliance with QIO security procedures. 
The QIO will maintain the original documentation at its facility. 
 
5060  Beneficiary Complaint: Reconsideration  Stage Four 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
For complaints filed after July 31, 2014, a Medicare beneficiary or practitioner and/or provider 
may request a reconsideration, in writing or by phone, within three (3) calendar days following 
initial oral notification of the QIOs Final Initial Determination. A beneficiary, provider, or 
practitioner who is dissatisfied with the QIOs Final Initial Determination may request 
reconsideration.  
 
NOTE: The Beneficiary Complaint Reconsideration Procedures (See 42 CFR 476.140) replace 
the Retrospective Beneficiary Complaint Re-review Process (5250) and Concurrent Beneficiary 
Complaint Re-review process (5350) provided in Manual Chapter 5 Quality of Care Revision-
17, dated 04/06/12.  
 
NOTE: 5250 and 5350 of Manual Chapter 5 Revision  17 dated 04/06/12 - apply to 
Beneficiary Complaints filed before July 31, 2014, (the date after which reconsideration rights 
apply pursuant to 42 CFR 476.140). (A practitioner and/or provider may request a Re-review, 
in accordance with Manual Chapter 5 (5252 and 5350) Revision-17, dated 04/06/12.) 
 
The beneficiary and/or the practitioner and/or provider may request reconsideration within 
three (3) calendar days of receipt of the Final Initial Determination Letter to Practitioners/ 
Providers (Appendix 5-4.1 and Appendix 5-4.2).   
 
The QIO s Final Decision shall be issued to the beneficiary and practitioner and/or provider no 
later than five (5) calendar days after the request for a reconsideration, or if later, five (5) 
calendar days after receiving any medical or other records needed for the reconsideration. See 
42 CFR 476.140.  
 
NOTE: The timeframe for completion of review starts when additional information is received 
from all parties. If additional information is not received within seven (7) calendar days of the 
beneficiary or providers request for reconsideration, the QIO should proceed with the 
reconsideration with the information that is available.  
 
Upon receiving a reconsideration request, the following information must be forwarded to the 
reconsideration Peer Reviewer so that a reconsideration review can be completed:    
1.  Beneficiary Complaint folder/file 
 
2.  Quality Review Decision (QRD) Form; 
 
3.  All Medical information received;  
 
4.  Final Determination Letter to Practitioners/Providers and Beneficiaries (Appendix 5-4.1 
and 5-3.2) (See 5060.3). If the Initial Determination was orally communicated to the 
beneficiary, the QIO should include a brief summary of the conversation; 
 
5.  Interim Initial Determination Letter for Providers/Practitioners (Appendix 5-3; 
 
6.  Information received related to the offer of the Opportunity for Discussion Stage; and  
 
7.  Any new evidence submitted in requesting the reconsideration.  
 
The package with the above information should be forwarded to the Reconsideration Peer 
Reviewer within one (1) business day of receiving the request for reconsideration. (See 5060.1). 
Reconsideration reviews must be completed within five (5) calendar days after receipt of the 
request for reconsideration or receipt of any medical or additional information or other records 
needed for the reconsideration if applicable. 
 
When a practitioner/provider fails to request a reconsideration [in cases where the concern(s) 
from the original beneficiary complaint are confirmed quality of care concern(s)] within three 
(3) calendar days following the practitioner and/or providers oral or written receipt of the 
QIOs Final Initial Determination, the QIO will prepare and send the Final Determination 
Letter to the Beneficiary/Beneficiary Representative (Appendix 5-4.2). This mailing is to occur 
no later than five (5) calendar days after the expiration of the reconsideration period. 
 
The QIO may notify the beneficiary and the practitioner/ provider of its Final Decision by phone. 
However, the QIO must follow up by issuing a written notice to the parties by 12:00 noon on the 
next calendar day. See 42 CFR 476.140(b). 
 
5060.1  Beneficiary Complaint: Reconsideration Peer Reviewer  
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
To fulfill the practitioner/provider and/or beneficiarys right to reconsideration, and to provide 
all parties with an impartial and independent reconsideration of peer review, the 
Reconsideration Peer Reviewer should be different from the Peer Reviewer who conducted the 
Interim Initial and Final Initial Determinations. In making his/her determination, the 
Reconsideration Peer Reviewer shall review all information forwarded by the QIO. The Peer 
Reviewer shall use the QRD Form (Appendix 5-1.3) to render a determination(s).  
 
The Reconsideration Peer Reviewer receives the package from the QIO and initiates the 
reconsideration.  
 
In order to be an effective and fair review [See 476.130(b)(1)] provided upon request for a  reconsideration, the Reconsideration Peer Reviewer must review each Quality of Care Concern 
identified in the complaint and any additional concerns identified by the QIO or the Initial 
Determination Peer Reviewer during the review of the medical information. The Reconsideration 
Peer Reviewer should also document the reconsideration review by completing the QRD Form 
for each concern. The process is as follows: 
 
1.  The Reconsideration Peer Reviewer evaluates the standard(s) that the QIO and the Initial 
Determination Peer Reviewer identified for each Quality of Care Concern on the QRD 
Form. 
 
2.  The Reconsideration Peer Reviewer checks off the appropriate box indicating whether 
he/she concurs or does not concur with the standard(s) of care for each Quality of Care 
Concern as delineated by the QIO and the Initial Determination Peer Reviewer. 
 
3.  If the Reconsideration Peer Reviewer determines that the standard(s) identified by the 
QIO staff member who prepared the case for review and/or Initial Determination Peer 
Reviewer for a specific concern(s) is incorrect or not appropriately thorough, he/she 
must identify the correct standard(s) and provide an explanation of the change. 
 
4.  For instances when the Reconsideration Peer Reviewer determines that the standard(s) is 
incorrect, he/she should include references to relevant literature/ research supporting 
his/her decision on the appropriate standard(s) of care and consult with the Medical 
Director to obtain the Medical Directors concurrence on the standard to be used in 
evaluating the concern(s).  
 
NOTE: The QIO staff member who prepared the case for peer review should be included in 
this consultation with the Medical Director. 
 
Reconsideration Peer Reviewer Rationale/Justification 
 
Upon determining the standard(s) of care to be used, the Reconsideration Peer Reviewer then 
applies the standard(s) of care to the specific facts of the case and the quality of care concern(s) 
at issue. The Reconsideration Peer Reviewer evaluates the information contained in the medical 
information based on the standard(s) as identified, including each evidenced-based element of 
the standard(s) of care. CMS expects that each Reconsideration Peer Reviewer will: 
 
1.  Directly link his/her decisions to elements contained in the evidence-based standard(s), 
or in the absence of evidence-based standards of care, will use available norms, best 
practices, and established guidelines when deciding whether quality of care for each 
identified concern is met based on the facts of the case. 
 
2.  Assess the responsibility of the individual identified by the beneficiary if that individual is 
different from the individual who is responsible for the standard(s) that were not met.  
 
To conduct a complete and adequate reconsideration, CMS expects the Reconsideration Peer 
Reviewer to: 
 
1.  Consider any historical data pertinent to the concern(s) that the QIO provided.   
2.  Highlight specific evidence from the review of the medical information demonstrating 
that specific elements within the standard(s) of care that are or are not met.  
 
3.  Include any other information the Reconsideration Peer Reviewer deems relevant to 
his/her Reconsideration Determination.  
 
If the Reconsideration Peer Reviewer, in his/her determination, concludes that there are 
extenuating circumstances to take into consideration (e.g., emergent circumstances or 
exceptional complexity), the Rationale/Justification section of the QRD Form must contain an 
explanation of these circumstances including relevance, in order to be complete.  
 
After completing the Rationale/Justification portion for each concern on the QRD Form, the 
Reconsideration Peer Reviewer must identify (and document), by checking off the appropriate 
box, whether the standard(s) of care was met or not met for each concern. This 
decision/determination must be based on the analysis and justification. 
 
If the Reconsideration Peer Reviewer determines that the standard(s) of care was not met, he/she 
must also check off the appropriate quality of care determination box indicating whether: 
 
1.  The care grossly and flagrantly violated the practitioner/providers obligation to provide 
care that is of a quality that meets professionally recognized standard(s) of health care in 
one or more instances. 
 
2.  The care failed in a substantial number of cases (more than three) to substantially 
comply with the obligation to provide care that is of a quality that meets professionally 
recognized standard(s) of health care. 
 
3.  The care failed to substantially comply with the obligation to provide care that is of a 
quality that meets professionally recognized standard(s) of health care. 
 
4.  The care did not meet the standard of care, but was less than a substantial violation of 
the obligation to provide care that is of a quality that meets professionally recognized 
standard(s) of health care (i.e. It was either significant or non-significant). 
 
The QIO must ensure the Reconsideration Peer Reviewer completes his/her review of the 
medical information/package completely and accurately, adheres strictly to the requirements of 
the QRD Form to document the review thoroughly, and returns the review package to the QIO in 
the appropriate timeframe. The QIO may orally notify the beneficiary and practitioner/provider 
of its Final Decision within five (5) calendar days after the request for reconsideration or if 
later, five (5) days after receipt of any medical information needed to complete the 
reconsideration review.  
 
NOTE: If the QIO initially notifies the parties orally, it must follow up with a letter by 12:00 
noon of the next calendar day. (See Appendix 5-5.1 and 5-5.2)  
 
The Reconsideration Peer Reviewer must sign and date the QRD Form and indicate the amount 
of time spent reviewing the concern(s). An electronic signature is acceptable when and if the  feature is available through the CMS-designated or otherwise approved review system. 
 
NOTE: If the Reconsideration Peer Reviewer has identified one or more concern(s) as either 
gross or flagrant, or the care failed in a substantial number of cases (more than three) to 
substantially comply with the obligation to provide care that is of a quality that meets 
professionally recognized standards of health care as required by 1156(a) of the Act, the QIO 
must initiate sanction proceedings in accordance with Manual Chapter 9.  
 
5060.2  Beneficiary Complaint: Preparing the Reconsideration Package 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The QIO receives the package from the Reconsideration Peer Reviewer and examines it to 
ensure all necessary information was returned. 
 
The QIO identifies the Reconsideration Decision on the QRD Form and prepares the following:  
 
1.  Beneficiary Quality of Care Complaint  Reconsideration Determination Letter to 
Practitioners and Providers (See Appendix 5-5.1); and 
 
2.  Beneficiary Quality of Care Complaint: Reconsideration Determination Letter to 
Beneficiary (Appendix 5-5.2). 
  
NOTE: The QIO may copy the language used previously, unless substantial changes have been 
made.  
 
5060.3  Beneficiary Complaint: QIOs Final Decision, Preparing, and Mailing 
the Letter to Providers and/or Practitioners and the Beneficiary 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The QIO must provide notice to the beneficiary and the provider/practitioner of the reconsidered 
determination as soon as it is complete [i.e. within five (5) calendar days of receiving the request 
for reconsideration and the records for the review].  The initial notice may be done by telephone 
but written notice must be provided by noon the next calendar day. 
 
A QIO is NOT required to obtain consent from the practitioner and/or provider to disclose to the 
beneficiary the QIOs Reconsideration Determination, the standard(s) of care at issue, whether 
or not the standard(s) was met, and the specific facts pertinent to the QIO in making that 
decision.  
 
A QIO is required to give written notice as well to the practitioner and/or provider. CMS 
recommends that this be done by providing a copy of the Letter to Beneficiary  Beneficiary 
Quality of Care Complaint: Reconsideration Determination Letter to Beneficiary (Appendix 5-
4.2) 
 
A QIO shall follow the procedures in this section for preparing the QIOs Reconsideration 
Determination Letters (Appendix 5-4.1and 5-4.2). For all complaints involving practitioners or 
providers, the letter to the beneficiary (Appendix 5-4.2) shall include ALL of the following:  
  1.  A statement for each quality of care concern identified where care did or did not meet the 
standard of care. 
 
2.  A statement defining the standard of care that the QIO identified for each quality of care 
concern. 
 
3.  A statement of the facts describing how the practitioner and/or provider did or did not 
meet the standard of care.  
 
  The statement of facts should relate only to the facts that were essential in 
determining whether a provider and/or practitioner met professionally recognized 
standards of care. 
 
4.  A statement that this constitutes the QIOs final decision on the complaint, that no further 
rights are available, and there is no appeal right to the beneficiary for the applicable 
standard(s) of care. 
 
The QIO shall prepare and mail the Beneficiary Quality of Care Complaint: Reconsideration 
Determination Letter to the practitioner/provider (Appendix 5-5.1) and the Beneficiary Quality 
of Care Complaint: Reconsideration Determination Letter to Beneficiary (Appendix 5-5.2). 
 
A QIO shall follow the procedures in 5060.4, Beneficiary Complaint: Procedures for Closing 
a Complaint Review for closing the case in the CMS-designated case review system.  
 
A QIO may refer the practitioner/provider for, Quality Improvement Initiatives in accordance 
with 5125 if deemed appropriate.  
 
5060.4  Beneficiary Complaint: Procedures for Closing a Complaint Review 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
The QIO must denote in the CMS-designated or otherwise approved case review system that the 
beneficiary complaint is completed and closed. The QIO may determine that Post-Review 
Advocacy, a post-peer review alternative dispute resolution process, should be made available to 
the beneficiary. (See 5065).  
 
The QIO must place all final documents in the Beneficiary Complaint folder/file and maintain 
this hard copy or electronic file in accordance with Manual Chapter 13.  
The QIO may pursue Quality Improvement Initiatives in accordance with 5125 or Post-Review 
Advocacy in accordance with 5065, if deemed appropriate.    
 
5060.5  Beneficiary Complaint: Responsibility to Protect Information and 
Destruction of Materials 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
As specified at 42 CFR 480.115, a QIO is responsible for protecting information and must 
implement reasonable security measures to ensure the integrity of information and prevent 
unauthorized access (See Manual Chapter 10 for additional information).  
  The Initial Determination Peer Reviewer must follow the established QIO policy and procedures 
that apply to security measures for protecting QIO electronic data and confidential information. 
 
5065  Post-Review Advocacy 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Post-Review Advocacy is an informal process that a QIO may use to resolve a continuing 
concern of the beneficiary after the QIO has completed the formal Peer Review process. It 
entails the QIO directly contacting the Practitioner and/or Provider to discuss the beneficiaries 
continuing concerns.  
 
In situations where a Beneficiary Complaint Review was completed and no significant quality of 
care concern was found, a QIO may voluntarily offer an additional opportunity for the 
beneficiary and practitioner and/or provider to resolve their dispute through Post-Review 
Advocacy. This alternative dispute resolution process can be used after the Peer Review process 
is completed, but it is not required. 
 
A QIO should summarize what Post-Review Advocacy entails for the beneficiary and obtain both 
the beneficiarys and provider and/or practitioners oral consent to participate in Post-Review 
Advocacy before proceeding.  
 
A beneficiary may discontinue Post-Review Advocacy at any time during the process. See 
5065.5 for additional information about discontinuing Post-Review Advocacy.  
 
Before offering the use of Post-Review Advocacy, the QIO should consider other factors that 
may affect the successful use of such an advocacy approach, including, but not limited to the: 
 
  Ability of involved parties to articulate their own needs and interests; 
 
  Desire for a direct, indirect, or immediate response; 
 
  Physical or mental barriers to participation by any party; 
 
  Desire for an opportunity to ask questions face-to-face or through another person; 
 
  Level of comfort in addressing conflict directly or indirectly; 
 
  Special needs of participating parties/ability of family and friends to participate in a 
meaningful way; 
 
  Proximity of parties and ability to meet; and 
  
  Complexity of the case (i.e., multiple settings, length of list of concerns). 
 
Post-Review Advocacy should not be used in cases where Immediate Advocacy was attempted, 
followed by the beneficiary ultimately filing a written complaint because an informal process has 
already failed.    
5065.1  Objectives of Post-Review Advocacy  
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The objectives of Post-Review Advocacy are to: 
 
1.  Provide QIOs flexibility in resolving complaints in situations when the traditional peer 
review process did not result in an acceptable resolution of the beneficiarys concerns 
(e.g., the QIO completed the peer review but found no Quality of Care violation).  
 
2.  Increase beneficiary, practitioner, and/or provider satisfaction throughout the process by 
resolving complaints that would have otherwise not been resolved to the beneficiarys 
satisfaction.  
 
5065.2  Eligibility for Post-Review Advocacy 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
A QIO should consider offering Post-Review Advocacy to a beneficiary in situations when: 
 
1.  The beneficiary conveys that he/she still has concerns about aspects of the care provided, 
and the QIO determines that the concerns do not relate to the clinical quality of health 
care itself. The concern relates to items and/or services that accompany or are incidental 
to the medical care; or 
 
2.  The beneficiary conveys that he/she still has concerns about aspects of the care received, 
but while the care is related to the clinical quality of health care received, it does not rise 
to the level of being a gross and flagrant, substantial, serious or urgent, or even 
a significant Quality of Care Concern. This may include situations where the QIO 
determines that the medical information did not contain evidence related to the 
beneficiarys original complaint. 
 
The following complaints are examples of when Post-Review Advocacy is appropriate: 
 
  The beneficiary complains that the practitioner spoke to him/her in a rude manner or 
otherwise did not treat him/her respectfully.  
 
  The beneficiary contacts the QIO about his/her failure to receive a motorized scooter or 
wheelchair. 
 
  The beneficiary is concerned that he/she received a different colored pill than expected 
and would like the QIO to find out what drug was given.  
 
5065.3  Practitioner/Provider Consent to Participate in Post-Review Advocacy 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Immediately upon obtaining the beneficiarys oral consent to participate in Post-Review 
Advocacy, the practitioner/provider should be contacted to obtain oral consent to participate.    
The QIO should ensure the practitioner/provider has received notice of the resolution of the 
original complaint and the beneficiarys desire to continue pursuing resolution of the complaint 
through Post-Review Advocacy.  
 
The QIO should convey sufficient information about the nature of the continuing complaint to 
enable the practitioner/provider to make an informed decision about agreeing to participate in 
Post-Review Advocacy.  
 
Upon obtaining the practitioner/providers oral consent to participate in Post-Review Advocacy, 
the QIO should follow the Post-Review Advocacy procedures in 5065.4 to resolve the concerns.  
 
If the practitioner and/or provider decide not to participate in the Post-Review Advocacy 
process, the QIO should immediately contact the beneficiary and inform him/her of the 
practitioner and/or providers decision not to participate. The QIO should inform the beneficiary 
that the QIOs review of the matter has ended.  
 
 
5065.4  Post-Review Advocacy Procedures 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Once a QIO has obtained oral consent from all parties, the QIO may either use a conference 
call/three-way call or make a call on behalf of the beneficiary to resolve the beneficiarys 
concerns. The focus should be on providing a quick and amicable resolution of the concerns 
within a short time frameusually within eight (8) hours to two (2) business days. 
 
In some circumstances, the practitioner/provider may be unavailable for a period of time after 
the beneficiary consents to the use of Post-Review Advocacy.  In these situations, the QIO should 
contact the beneficiary to explain the circumstances.  The use of Post-Review Advocacy should 
not extend beyond ten (10) days from the beneficiarys consent. 
 
If Post-Review Advocacy is carried out for any Beneficiary Complaint, the QIO must document 
its work by updating the CMS-designated case review system to describe how Post-Review 
Advocacy occurred and resolution of the complaint. After the Post-Review Advocacy has 
completed, the QIO must close the case accordingly.  
 
5065.5  Discontinuation of Post-Review Advocacy  
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
If, at any point, a beneficiary expresses a desire to stop pursuing concerns through the Post-
Review Advocacy process, the QIO should inform the beneficiary that the QIOs role in the 
review of a complaint will end and that the case will be closed. Post-Review Advocacy can only 
be successful when all parties participate. 
 
NOTE: The QIO may refer the practitioner/provider for, Quality Improvement Initiatives in 
accordance with 5600 if deemed appropriate. 
  5070  Quality of Care Reviews  General 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The following sections provide instructions for QIOs to follow in reviewing quality of care 
concerns received and/or identified from sources other than Beneficiary Complaints. (See 42 
CFR 476.160. These sources include: 
 
1.  Concerns Identified during Other Review Activities: Quality of Care reviews conducted 
when a potential quality of care concern(s) is identified during any other review activity 
(e.g., medical necessity reviews, expedited discharge appeals, Emergency Medical 
Treatment and Labor Act (EMTALA) reviews. See  5075, Concerns Identified during 
Other Review Activities. 
 
2.  Referrals: Quality of care reviews conducted in response to referrals from other entities 
(e.g., contractors, state-based organizations, the Office of Inspector General, the Office 
for Civil Rights), and anonymous referrals. See 5080, Source  Anonymous 
Beneficiary and 5085, Referrals.  
 
3.  Tracking and Trending: Quality of Care reviews conducted as a result of tracking and 
trending of data. See 5095, Tracking and Trending of Data.  
The process instructions are identical for reviews that originate from sources other than 
Beneficiary Complaints (i.e., Concerns Identified during Other Review Activities, 
Referrals, or Tracking and Trending). (See 5100-5100.4.) Unlike Beneficiary 
Complaint Reviews, where the instructions are divided into four stages, General Quality 
of Care Review is grouped into three stages to help identify roles and steps associated 
with various aspects of the process.  
 
The General Quality of Care Review stages are as follows:  
Stage One: Intake 
Stage Two: Quality of Care Review  
Stage Three: Reconsideration  
 
5075  Concerns Identified During Other Review Activities 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
QIOs may identify potential Quality of Care Concerns while conducting any other review (e.g., 
appeal, medical necessity/utilization, higher-weighted DRG, EMTALA). When a potential 
Quality of Care Concern is identified, the QIO must conduct a General Quality of Care Review. 
(See 5100.) 
 
5080  General Quality of Care Review: Source  Anonymous Beneficiary 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
If a beneficiary wishes to remain anonymous, the QIO must process the complaint as a General 
Quality of Care Review if the QIO believes the concerns warrant review. (See 5100, 42 CFR 
476.120(a)(2), and 476.160(a)(1)(i)). 
  For General Quality of Care Reviews conducted as a result of a beneficiary complaint or 
referral, the beneficiary should be informed that the QIO will NOT inform the 
practitioner/provider:  
 
1.  Of the source of the referral for the Review; and 
 
2.  That the QIO is requesting medical records as a result of a beneficiary 
complaint/referral.  
 
For General Quality of Care Reviews conducted as a result of a beneficiary complaint or 
referral, the QIO should inform the beneficiary that she/he will NOT be informed of the results of 
the General Quality of Care Review. 
 
If the individual making the complaint is identifiable as a beneficiary or beneficiary 
representative, the QIO is able to initiate direct contact with the beneficiary or beneficiary 
representative. If the beneficiary does NOT wish to remain anonymous, the QIO shall process 
the case in accordance with the Beneficiary Complaint Review procedures. (See 5040). 
 
A QIO should make every effort to keep the beneficiarys name confidential during the review 
process if a General Quality of Care Review is initiated. This includes taking steps that will not 
alert the practitioner/provider to this specific beneficiary. For example: 
 
  If additional medical records are needed from the practitioner/provider to complete 
other case reviews, the medical request for all records should be issued at the same 
time. This will minimize the practitioners ability to ascertain the name of the 
particular beneficiary that initiated the Quality of Care Review by the QIO.  
 
NOTE: The QIO should inform the beneficiary of the possibility the practitioner/provider could 
ascertain the name of the beneficiary during the General Quality of Care Review process based 
on the nature of and the specific facts surrounding the beneficiarys complaint. 
 
5085  General Quality of Care Review: Referrals 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Medicare Administrative Contractors (MACs), Medicare health plans (MHPs), State Medicaid 
survey and certification agencies (SSA), other CMS contractors, and CMS staff may also refer 
cases involving potential Quality of Care Concerns to QIOs.  
 
Before conducting a General Quality of Care Review for these types of referrals, the QIO should 
contact the CMS COR before proceeding with the review. 
 
Only the Request for QIO Review Form (See Appendix 5-8) is authorized for use when an agency 
or entity refers a potential Quality of Care Concern to a QIO. The QIO should send a copy of the 
request to the designated COR upon receipt. The QIO may proceed with conducting a General 
Quality of Care Review in accordance with 5100-5110.  
 
NOTE: At the CORs discretion, additional information may be requested from the referring  agency/entity when the request involves an extensive number of General Quality of Care 
Reviews. 
 
The QIO should conduct General Quality of Care Reviews on all referrals when sufficient 
information is conveyed to complete the review. When a potential quality of care concern, that is 
a potential gross and flagrant violation or a substantial violation in a substantial number of 
cases (more than three) is referred, the QIO must conduct a General Quality of Care Review. 
(See 5100-5115.3)  
 
5085.1  Referrals from Other Federal Government Organizations  
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
When a QIO receives a referral or request for review for potential Quality of Care Concerns 
from Federal Government organizations outside of the Centers for Medicare & Medicaid 
Services (e.g., the Office of Inspector General, the Department of Justice [DOJ], or the Office 
for Civil Rights), the QIO should provide a copy to the appropriate CMS COR. When a potential 
Quality of Care concern is referred to the QIO, the requestor will use the authorized QIO Case 
Review Referral Request Form. (See Appendix 5-8.) Upon receiving any referred potential 
Quality of Care Concerns, the QIO must follow the process requirements set forth in 5100, 
Quality of Care Reviews  General. When a potential Quality of Care Concern is referred, the 
QIO must conduct a General Quality of Care Review. (See 5100-5115.3.) 
 
5090  Overlap of Review Authority 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
QIOs may receive referrals of potential Quality of Care Concern(s) from other sources, 
agencies, or entities (e.g. other QIOs, public or private review organizations, Medicare 
contractors such as MACs), when the referring source or entity identifies what may be a quality 
concern related to Medicare services while conducting a review based on its jurisdictional 
requirements [See 476.160(a)].  
 
Pursuant to 42 CFR 476.104, QIOs must work with these organizations to ensure any necessary 
coordination. QIOs are responsible for ensuring that organizations, including contractors, have 
clearly defined direction about the types of cases that warrant referral to the QIO.  
 
5095  Tracking and Trending of Data 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
QIOs must conduct analyses of data from all review types to identify potential Quality of Care 
Concerns in accordance with the contract requirements.  
 
Data analyses may be conducted within and/or across provider settings in accordance with 
contract requirements. In addition, QIOs must make every attempt to identify Quality of Care 
Concerns related to health disparities issues, including racial, ethnic, or socioeconomic 
indicators.  
  NOTE: When a potential Quality of Care Concern is identified through data analysis, a QIO 
should conduct a General Quality of Care Review. (See 42 CFR 476.160(a)(1)(iii) and 5100-
5115.3 of Manual Chapter 5.) 
 
5100  General Quality of Care Review 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The following instructions describe the steps when the QIO reviews quality of care concerns 
received and/or identified from sources other than Beneficiary Complaints (i.e., Concerns 
identified during other review activities, referrals, or tracking and trending). 
 
5110  General Quality of Care Review: Preparing the General Quality of Care 
Review Folder: Intake  Stage One  
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
NOTE: The QIO referenced in this section refers to a qualified staff member as a QIO 
designates. The job title may differ within each QIO. 
 
A QIO is responsible for preparing the General Quality of Care Review folder/file. Should a 
copy of the folder/file be needed (e.g., for use by an off-site Peer Reviewer), a duplicate copy of 
the folder/file may be prepared. CMS expects that the folder/file will be forwarded to the QIO 
within one (1) business day of receiving a referral or identifying a potential Quality of Care 
Concern as a result of tracking and/or trending of data.  
 
In instances where a Quality of Care Concern is identified during other review activities, the 
QIO will prepare/organize the information necessary to enable the Quality of Care Review to be 
completed in addition to the original review activity. For example: 
 
In completing an expedited discharge appeal review, the Peer Reviewer identifies a Quality of 
Care Concern. A QIO should establish procedures to enable the Reviewer who identified the 
Quality of Care Concern to complete the Quality of Care Review. 
 
5110.1  General Quality of Care Review: Review of Folder by the QIO 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The QIO should review the General Quality of Care Review information in the folder/file as well 
as the information in the CMS-designated case review system to ensure that he/she understands 
the specific concern(s) involved and identifies the necessary medical records to be requested. 
 
5110.2  General Quality of Care Review: Requesting Medical Information 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The following steps do not apply to instances where the QIO already possesses medical 
information (e.g. records in connection with another review activity). The instructions and 
guidance here are written to apply to requests for medical information in response to General 
Quality of Care Reviews conducted as a result of referrals and/or tracking and trending of data. 
  TIMELINE: 
 
Practitioners and/or providers are obligated to forward all required information within fourteen 
(14) calendar days of the request from a QIO.  See 42 CFR 476.160(b).  A QIO may request the 
medical information from the practitioner and/or provider sooner than the fourteen (14)-
calendar day time frame, if the QIO determines the review involves a potential gross and 
flagrant or substantial violation of the quality of care and circumstances warrant earlier receipt 
of the information. If the QIO makes a preliminary determination that the review involves a 
potential gross and flagrant violation or a substantial quality of care concern as specified in 
Part 1004 of the Act, and circumstances warrant earlier receipt of the medical information, the 
QIO should document the determination and the reason for it. 
 
Medicare health plans (MHPs) are responsible for submitting medical information absent a 
specific delegation to the provider. Should a MHP fail to submit medical information as 
requested within the prescribed fourteen (14)-calendar-day timeframe (or at an earlier date as 
applicable, the matter should also be referred to the pertinent CMS COR for CMS to take action 
to secure compliance by the Medicare health plan. When a provider has been specifically 
delegated the responsibility to submit medical information, the COR will collaborate with the 
Division of Medicare Health Plan Operations (DMHPO) about any options that may be pursued 
in light of the providers Medicare Provider Agreement.  
 
In situations where a practitioner and/or provider fails to submit medical information within the 
required time frame, the practitioner and/or provider may be subject to a denial of payment 
under 42 CFR 476.90. In some situations, where either a practitioner or provider fails to 
submit medical information within the required timeframe, the QIO should advise the 
practitioner or provider that, based on 1156(a)(3), sanctions may be initiated because of the 
failure to support the provision of items or services with evidence of the medical necessity for 
and quality of the items or services.  
 
NOTE: Upon receiving medical information at any step, follow the instructions as outlined in 
5110.4, General Quality Review: Review and Preparation of Medical Information. 
 
CMS expects the QIO to complete the following steps in requesting medical information 
consistent with 42 CFR 476.160(b):  
 
Step 1: Request the medical information within one (1) business day after receiving the referral 
or identifying a potential quality of care concern as a result of tracking and/or trending of data.  
 
The QIO may contact the practitioner and/or provider by phone and follow up with a facsimile 
or mailed letter. If a letter is sent, the letter must clearly indicate the specific date on which the 
medical information was first requested, because this date will be used to determine when a 
claim denial shall be issued. See 5110.3 for information about a claim denial. Even if a letter is 
not sent, the QIO must document the date and time of the request. 
 
NOTE: The date of the letter may be used if it corresponds to the date of the first request.  
The QIO must advise a practitioner and/or provider of the requirement to submit the requested 
medical information within fourteen applicable time frame. 
  A QIO may contact either/both the Medical Records Department or the QIO liaison based on 
procedures that have been established with the practitioner and/or provider. 
 
Step 2: The QIO should follow up as necessary to ensure adherence to the fourteen (14) 
calendar-day submission deadline - i.e. fourteen (14) calendar days from request or the earlier 
in those circumstances where the QIO made a preliminary determination that the review 
involved a potential gross and flagrant or substantial quality of care concern.  
Before making contact to follow up on the request for information and documents, the QIO 
should verify the following information: 
 
1.  The QIO has not previously requested and received the medical information by 
conducting a search in the CMS-designated case review system. 
 
2.  The date the medical record is due for receipt by the QIO is correct. The timeframe can 
vary in cases where a potential gross and flagrant quality of care concern is identified.  
 
If the medical information is not received from the practitioner and/or provider by calendar day 
fourteen (14) or other date the QIO designates, the QIO will notify the practitioner and/or 
provider of potential for denial of the applicable claim(s) under 42 CFR 476.90; and 
 
Remind the practitioner/provider that , under 1156(a)(3), items or services provided by or 
ordered by practitioners must be supported by evidence of medical necessity and quality, in such 
form and fashion and at such time as may reasonably be required by a QIO in the exercise of its 
duties and responsibilities. The QIO should point out that any unreasonable delay in providing 
medical information could lead to sanctions under 1156(b). 
 
This step is meant to furnish a practitioner and/or provider with adequate notice to correct any 
problems associated with submitting medical information, and to help the practitioner and/or 
provider avoid potential penalties or claims denials.  
 
Step 3: In addition to contacting the provider /practitioner, the QIO should immediately contact 
the COR and provide sufficient information so that the COR is prepared to contact the 
practitioner and/or provider. The QIO should also follow up with the COR to advise him/her 
if/when the medical information is received.  
 
Step 4: On the next business day after the deadline for the delivery of the medical information 
requested by the QIO, the COR may call the Medical Records Department, the QIO liaison, 
and/or senior leadership, and convey the responsibilities associated with the request for the 
medical information.  
  
The COR may assess the willingness of the practitioner/provider to comply with the request for 
medical information and explain the potential repercussions of failure to provide the medical 
information, including: 
 
  A claim denial;  
 
  For Medicare health and drug plans, notifying the Division of Medicare Health Plan 
Operations; and   
  Referral to the OIG. 
 
NOTE: The COR advises that if the medical information is not received within the next calendar 
day, a claim denial shall be carried out for any claim associated with the quality of care concern 
identified.  
 
Step 5: If the medical information is not received from a practitioner and/or provider within 
thirty (30) calendar day of the QIO request, the QIO must proceed in accordance with 5110.3, 
General Quality Review: Issuing a Claim Denial.  
 
NOTE: In instances when the QIO completes a claim denial, the practitioner and/or provider is 
still required to comply with its responsibility to forward the medical information to the QIO to 
complete the quality of care review.  
 
For providers and practitioners, a COR may recommend additional action depending on the 
particular facts of the situation (e.g., recommending that the QIO conduct additional Quality of 
Care Reviews on other patients for whom the practitioner and/or provider has submitted similar 
claims for payment). 
 
5110.3  General Quality of Care Review: Issuing a Claim Denial 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
A QIO is authorized to deny a practitioner and/or providers claim in situations where the QIO 
has requested information from a practitioner and/or provider and, despite sufficient notice and 
a reasonable amount of time to respond, the practitioner and/or provider fails to forward the 
requested information. (See 42 CFR 476.103(2)(b) and 476.90(b)). 
 
NOTE: Before processing a claim denial, the QIO should coordinate with the appropriate CMS 
COR.  
 
If the requested medical information is received before the claim denial is finalized, the QIO 
must stop the denial and complete the review. If the medical information is received after the 
claim denial has been finalized, payment must be re-instituted. The QIO should complete the 
review. 
 
5110.4  General Quality of Care Review: Reviewing and Preparing Medical 
Information 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Upon receiving the medical record documentation, the QIO should immediately date-stamp the 
form and scan the form, original envelope, and/or facsimile, or email and upload them to the 
CMS-designated case review system (unless received electronically).  
 
The QIO should file the original envelope with the medical record documentation. The QIO 
should also ensure that all information in the medical information is complete, appropriately 
organized, and legible.    
If the medical documentation in the medical record is incomplete or illegible (poor copy), the 
QIO may contact the practitioner and/or provider by phone and allow an additional five (5) 
calendar days for submission of the documentation necessary to complete the medical review 
process. 
 
NOTE: QIOs should follow the procedures for issuing a claim denial in 5110.3 when complete 
medical information is not received in accordance with the timeline identified in 5110.2 (See 
Appendix 5-10, General Quality of Care Review - Best Practices) 
 
The QIO should verify that the medical information record documentation received for each 
medical request contains the major documentation components, particularly those relevant to the 
quality of care concern. Examples include but are not limited to the following:  
 
1.  Emergency Room Record/Admission Record; 
 
2.  History and Physical; 
 
3.  Consultations; 
 
4.  Practitioner Orders; 
 
5.  Practitioner Progress Notes; 
 
6.  Nursing Notes; 
  
7.  Ancillary (e.g., laboratory Reports, X-rays, medication administration record, treatment 
administration record) 
 
8. Discharge Summary. 
 
NOTE: QIOs are authorized to upload medical record documentation received directly into the 
CMS-designated system or other secure electronic system(s) CMS approves. The documentation 
should be uploaded within one (1) business day of receiving the medical information.  
 
For General Quality of Care Reviews, the following communication information should be 
documented in the CMS-designated case review system: 
 
  Date on which a QIO requests medical records from a practitioner and/or provider by 
phone, in writing, fax, or CMS approved method for secure file transfer. 
 
  Date on which a practitioner and/or provider contacts the QIO (in writing, by phone or 
in person) to request a reconsideration. 
 
  Date and pertinent parts of the conversation when the QIO notifies the practitioner 
and/or provider of the QIOs Final Decision, which must occur within five (5) calendar 
days after the request for reconsideration or receipt of the medical or other records 
needed for the reconsideration. (NOTE: If the QIO orally contacts the  practitioner/provider about this decision, the QIO must send the practitioner/provider a 
written notice by 12:00 noon of the next calendar day.) 
 
Use of the CMS-designated case review system is designed to facilitate the resolution of any 
questions that may arise about a specific complaint and ensures that all pertinent information 
related to a complaint is uniformly recorded and centrally located in the CMS-designated case 
review system.  
 
If the QIO or Peer Reviewer determines that handwritten information in the medical information 
cannot be deciphered, the QIO may contact the facility and request a typed/transcribed portion 
of the problem sections of the medical information.  
 
The QIO should make every effort to limit the amount of typed/transcribed information 
requested. Failure to comply with a request for typed/transcribed information shall be treated as 
a failure to provide the medical information if the missing information precludes the completion 
of the review.  
 
The Initial Determination Peer Reviewer may be consulted before determining to pursue a claim 
denial. QIOs must follow the procedures in 5110.3 for processing these denials. 
 
5115  General Quality of Care Review: Quality of Care Review  Stage Two 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The QIO may also identify potential Quality of Care concerns or cases for Quality of Care 
Reviews while carrying out the QIOs work responsibilities related to other review activities. 
Additional case(s) appropriate for Quality of Care Reviews may also be identified as a result of 
tracking and trending of data.  
 
Regardless of the referral source for a Quality of Care Review, the QIO initiates the review by 
conducting a preliminary review of each quality of care concern(s) identified.  
 
5115.1  General Quality of Care Review: Preparing the Quality Review 
Decision (QRD) Form  
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Once a determination is made about the specific concern(s) to be addressed, the QIO should 
prepare a QRD Form containing all potential concerns that have been identified (See Appendix 
5-1.3Quality Review Decision (QRD) Form.). The QRD Form is the only form authorized for 
identifying, documenting, and summarizing the quality of care concerns addressed in the review. 
 
The QRD Form is designed to account for the multiple individuals involved in a Quality of Care 
review and to ensure that information related to every Quality of Care Concern is maintained in 
an organized, detailed, and consistent fashion throughout the review process.  
 
Pursuant to the QIO contract, the QIO uses the CMS-designated case review system to prepare a 
QRD Form that sets out each individual concern and forwards the review materials and 
associated medical information to the Initial Determination Peer Reviewer within three (3)  business days of receiving the medical information. In completing the QRD Form, the QIO 
should do each of the following: 
 
1.  Identify each Quality of Care Concern; 
 
2.  Identify the quality of care with regard to the admission diagnosis and treatment plan 
established for the beneficiary, if applicable; 
 
3.  Research evidence-based practices related to each Quality of Care Concern(s), while 
considering the definition of Quality Care, including reference to relevant norms and 
criteria. If no quality of care standard(s) exists, then the QIO will use available norms, 
best practices, and established guidelines, to recommend a potential quality of care 
standard(s). In order to identify all applicable criteria and norms to be applied pursuant 
to 476.100, the QIO must thoroughly research all available information, including: 
 
  Nurse screening criteria (e.g., InterQual, Milliman, etc.); 
 
  Generally available resources, including information available via Internet 
searches; 
 
4.  Complete an Assessment section for each Quality of Care Concern; 
 
5.  Evaluate additional information pertinent to the case, but unrelated to the standard(s) of 
care. This evaluation may include:  
 
  CMS-available information, including web-based resources (e.g., Nursing Home 
and Hospital Compare); 
 
  State-based resources, including web-based literature and information as well as 
practitioner-specific information related to license revocations and referrals to 
the State medical conduct organizations; 
  
6.  Research all available data, a minimum of three (3) years from the date of service, to 
determine whether similar complaints have been received on the same practitioner 
and/or provider and/or if other potential concerns related to the same practitioner and/or 
provider are identifiable; and 
 
7.  Utilize the medical information received to prepare the information needed to complete 
the review and forward it to the Initial Determination Peer Reviewer.  
 
5115.2  General Quality of Care Review: Receipt and Review by the Initial 
Determination Peer Reviewer 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The QIO mails or sends the materials to be reviewed and the QRD Form via a secure electronic 
method to the Initial Determination Peer Reviewer immediately after receiving the Medical 
Record documentation.    
Once the Peer Reviewer receives the medical record documentation, the review should be 
initiated immediately.  
 
The Peer Reviewer evaluates the standard(s) that the QIO identified for each concern on the 
QRD Form and checks off the appropriate box indicating whether he/she concurs or does not 
concur with the identified standard(s) of care. If the Peer Reviewer identifies new Quality of 
Care Concerns, the Peer Reviewer must identify and document the concern(s), as well as the 
specific standard(s) of care for each concern, and include pertinent research supporting the 
standard of care he/she used to evaluate each concern on the QRD form. 
 
If the Initial Determination Peer Reviewer determines that the standard(s) identified by the QIO 
for a specific concern(s) is incorrect or not thorough, he/she identifies the correct standard(s) 
and provides an explanation of the change, including references to relevant literature/research 
supporting his/her decision on the appropriate standard(s) of care.  
 
The Initial Determination Peer Reviewer then applies the standard(s) of care to the specific facts 
of the case and the Quality of Care Concern(s) at issue. The Peer Reviewer evaluates the 
medical information based on the standard(s) as identified, including each evidenced-based 
element of the standard(s) of care.  
 
The Peer Reviewer must evaluate whether the quality of care standard for each identified 
concern is met based on the facts of the case and directly link his/her decisions to elements 
contained in the evidence-based standard(s), or in the absence of evidence-based standards of 
care, using available norms, best practices, and established guidelines consistent with 476.100.  
 
The Peer Reviewer also assesses the individual who is responsible for any standard(s) not met. 
The Peer Reviewer addresses the following in the documentation of the Review: 
 
  Any historical data pertinent to the concern(s) provided by the QIO, highlighting specific 
evidence from the review of the medical information and demonstrating specific elements 
within the standard(s) of care that are met or not met; 
 
  Any other information relevant to the Initial Determination; and 
  
  Extenuating circumstances taken (or not) into consideration (e.g., emergent 
circumstances or exceptional complexity). 
 
NOTE: The Peer Reviewer must be accurate and thorough in conducting and 
documenting the review, including a full explanation of the analysis, in order to fulfill the 
Review responsibility.   
 
Upon completing the Rationale/Justification portion for each concern on the QRD Form, the 
Initial Determination Peer Reviewer must check off the appropriate box indicating his/her 
decision that the standard(s) of care was met or not met for each concern. If the Peer Reviewer 
determines that the standard(s) of care was not met for a concern, the Initial Determination Peer 
Reviewer must also check off the appropriate box indicating whether: 
    The care grossly and flagrantly, in one or more instances, violated the providers or 
practitioners obligation to provide care that is of a quality that meets professionally 
recognized standards of health care.  
 
  The care failed in a substantial number of cases (more than three) to substantially 
comply with the obligation to provide care that is of a quality that meets the 
professionally recognized standard(s) of health care.  
 
  The care failed to substantially comply with the obligation to provide care that is of a 
quality that meets the professionally recognized standard(s) of health care. 
 
  The care did not meet the standard of care, but was less than a substantial violation of 
the obligation to provide care that is of a quality that meets the professionally recognized 
standard(s) of health care (i.e., it was either significant or non-significant). 
 
The Initial Determination Peer Reviewer must complete the review of the medical information 
provided and complete the QRD Form (See Appendix 5-1.3). The peer reviewer must, adhere 
strictly to the format in the QRD Form, and return the completed QRD Form to the QIO in 
sufficient time that the practitioner/provider can be notified of the initial determination within 
ten (10) calendar days of the QIO receiving the necessary medical records.  
 
The Peer Reviewer must sign and date the QRD Form and indicate the amount of time spent 
reviewing the materials. 
 
Except in circumstances when the Peer Reviewer conducts the review on the QIO premises, the 
Peer Reviewer may maintain a signed copy of his/her completed QRD Form and additional 
notes.  
 
5115.3  General Quality of Care Review: Return of Initial Determination 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Immediately upon receiving the General Quality of Care Review folder from the Initial 
Determination Peer Reviewer, the QIO must ensure all necessary information has been returned 
and the QRD Form has been signed.  
 
The QIO should review the QIO Form to ensure that the Peer Reviewer rendered a decision on 
all quality of care concerns, that the content adheres to the correct format, and that the rationale 
for conclusions is clear. This review should occur promptly to ensure that the mandatory 
timeframe for notifying the practitioner/provider is met.  
 
The QIO must ensure that the practitioner and/or provider is notified of the Peer Reviewers 
Initial Determination, in writing, within 10 calendar days from receipt of a complete medical 
record.  
 
In the same letter in which the QIO informs the practitioner/provider of the Initial Determination 
results, the QIO must also notify the practitioner/provider of his/her right to request 
reconsideration for reviews initiated after July 31, 2014.  
  NOTE: If the Initial Determination Peer Reviewer has identified a concern(s) as either gross or 
flagrant, or the care failed in a substantial number of cases (more than three) to substantially 
comply with the obligation to provide care that is of a quality that meets the professionally 
recognized standard(s) of health care (see 1156(a) of the Act), then the QIO must initiate 
sanction proceedings in accordance with Manual Chapter 9.  
 
Once confirming that the documentation is complete for the Initial Determination Peer 
Reviewers determination as to whether the standard of care was met or was not met for all 
concerns, the QIO should follow the procedures detailed in 5115.4, General Quality of Care 
Review: Preparation of the Initial Determination Letter  
 
5115.4  General Quality of Care Review: Preparation of the Initial 
Determination Letter 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Upon receiving the QRD Form, the QIO prepares the General Quality of Care Reviews  
Initial Determination Letter (Appendix 5-6) conveying the decision to the practitioner and/or 
provider. The letter must be sent to the practitioner/provider such that the practitioner/provider 
is notified of the initial determination within ten (10) calendar days of the receipt of medical 
records by the QIO (See 476.160).  
 
The letter must:  
  Advise the practitioner and/or provider of the right to request a reconsideration of any 
review initiated after July 31, 2014, if the standard(s) of care was not met for any 
concern(s) 
 
  Inform the practitioner and/or provider of the deadline for requesting a reconsideration 
(See 476.140); and  
 
  Inform the practitioner and/or provider that this will be the last communication about 
the QIOs decision if no request for reconsideration is received.  
Note: See 5120, General Quality of Review Reconsideration Stage Three, for 
information related to a practitioners and/or providers failure to respond to the 
reconsideration request.  
 
If the practitioner and/or provider does not request reconsideration (by phone or in writing) 
within three (3) calendar days, then the practitioner and/or provider may not be granted a 
request for reconsideration. See 5120. 
 
5115.5  General Quality of Care Review: Responsibility to Protect Information 
and Destruction of Materials 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
As specified at 42 CFR 480.115, a QIO is responsible for protecting information and must 
implement reasonable security measures to ensure the integrity of information and prevent 
unauthorized access. See Manual Chapter 10 for additional information.  
  The Initial Determination Peer Reviewer must follow the established QIO policy and procedures 
that apply to security measures for protecting QIO electronic data and confidential information. 
 
A QIO must maintain all medical record documentation in hard copy form or electronic files in 
accordance with Manual Chapter 13. 
 
5120  General Quality of Care of Care Review: Reconsideration  Stage Three 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The General Quality of Care Reconsideration procedures (see 42 CFR 476.170) replaces the 
Retrospective General Quality Re-review Process (5580) and Concurrent General Quality Re-
review Process (5640) described in Manual Chapter 5 Quality of Care Revision-17, dated 
04/06/12. 
 
NOTE: For General Quality of Care Re-Reviews filed before July 31, 2014, (see 42 CFR 
476.170), a practitioner and/or provider may request a Re-review, in accordance with Manual 
Chapter 5, (s 5640 and 5580) Revision-17, dated 04/06/12. 
 
For Re-reviews filed after July 31, 2014, a practitioner and/or provider may request 
reconsideration in accordance with 476.170.   
 
For General Quality of Care Reviews filed after July 31, 2014, the practitioner and/or provider 
may request reconsideration within three (3) calendar days of receiving the QIOs Final Initial 
Determination (i.e. General Quality of Care Reviews: Initial Determination Letter with Right to 
Request Reconsideration to Practitioner and Providers - Appendix 5-6). Additional evidence may 
also be submitted as part of the reconsideration process.  
 
Upon receiving a reconsideration request, the QIO must forward the General Quality of Care 
Review folder including the following items to the Reconsideration Peer Reviewer so that a 
reconsideration review can be completed:  
 
  QRD form; 
 
  All medical information received by the QIO; 
  
  General Quality of Care Reviews: Initial Determination Letter with Right to Request 
Reconsideration to Practitioners and Providers, which conveys the decision to the 
practitioner and/or provider (Appendix 5-6); and 
 
  Any new evidence submitted in requesting the reconsideration.  
 
The folder with the above information should be forwarded to the Reconsideration Peer 
Reviewer as soon as possible as the reconsideration decision must be provided within 5 calendar 
days (See 5120.1). 
 
5120.1  General Quality of Care Review: Reconsideration Peer Reviewer 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16)   
For CMS to treat the reconsideration as valid and fulfilling the right to reconsideration, the 
Reconsideration Peer Reviewer must be different then the Peer Reviewer who conducted the 
Initial Determination. In making his/her determination, the Reconsideration Peer Reviewer shall 
review all information forwarded by the QIO.  
 
The Reconsideration Peer Reviewer documents his/her review and determination using the QRD 
Form, for each Quality of Care Concern.  
 
The Reconsideration Peer Reviewer receives the package from the QIO and initiates the 
reconsideration.  
 
The Reconsideration Peer Reviewer must review each potential quality of care concern identified 
by the QIO and/or the Initial Determination Peer Reviewer. For each concern, the 
Reconsideration Peer Reviewer:  
 
  Evaluates the standard(s) the QIO and the Initial Determination Peer Reviewer identified 
on the QRD Form; 
 
  Checks off the appropriate box indicating whether he/she concurs or does not concur 
with the standard(s) of care as the QIO and Initial Determination Peer Reviewer 
delineated; 
 
  Determines if the standard(s) identified by the QIO and/or Initial Determination Peer 
Reviewer identified for a specific concern(s) is incorrect or not thorough, and, when 
appropriate, identifies the correct standard(s) and provides an explanation of the 
change; and 
 
  Includes references to relevant literature/research supporting the decision regarding the 
appropriate standard of care and consults with the Medical Director to obtain the 
Medical Directors concurrence on the standard to be used in evaluating the concern(s) 
in instances where the standard of care has not been met. 
  
NOTE: The QIO staff member who prepared the case for the peer reviewer shall be 
included in this consultation. 
 
In the rare instance when a Reconsideration Peer Reviewer identifies a new concern, the 
Reviewer must notify the QIO for the QIO to initiate processing of the newly identified concern 
at the Quality of Care Review Stage. The Reconsideration Peer Reviewer must not evaluate the 
concern because the matter will be eligible for review by an Initial Determination Peer 
Reviewer. 
 
Completion of the Rationale/Justification 
 
Upon determining the appropriate standard of care, the Reconsideration Peer Reviewer then 
applies the standard of care to the specific facts of the case and the quality of care concern at 
issue.  
  The Reconsideration Peer Reviewer evaluates the medical information based on the standard as 
identified, including each evidenced-based element of the standard of care.  
 
The Reconsideration Peer Reviewer must directly link his/her decisions to elements contained in 
the evidence-based standard), or in the absence of evidence-based standards of care, will use 
available norms, best practices, and established guidelines, when deciding whether quality of 
care for each identified concern is met based on the facts of the case. The Reconsideration Peer 
Reviewer also assesses the individual responsibility for the standard(s) not met.  
 
In addition, the Reconsideration Peer Reviewer must consider any historical data pertinent to 
the concern(s) as provided by the QIO, highlight specific evidence from the review of the medical 
information demonstrating that specific elements within the standard of care are met or not met, 
and include any other information the Reconsideration Peer Reviewer deems relevant to his/her 
Reconsideration Determination.  
 
If the Reconsideration Peer Reviewer, in his/her determination, concludes that there are 
extenuating circumstances to take into consideration (e.g., emergent circumstances or 
exceptional complexity), he/she must thoroughly explain these justifications in completing the 
Rationale/Justification section of the QRD Form.  
 
The Reconsideration Peer Reviewer must complete a separate analysis for each quality concern. 
Upon completing the Rationale/Justification section, the Reconsideration Peer Reviewer must 
check off the appropriate box indicating his/her decision that the standard of care was met or not 
met.  
 
If the Reconsideration Peer Reviewer determines that the standard(s) of care was not met, he/she 
must also check off the appropriate box indicating whether: 
 
  The care grossly and flagrantly, in one or more instances, violated the 
practitioner/providers obligation to provide care that is of a quality that meets 
professionally recognized standards of health care.  
 
  The care failed in a substantial number of cases (more than three) to substantially 
comply with the obligation to provide care that is of a quality that meets the 
professionally recognized standard(s) of health care.  
 
  The care failed to substantially comply with the obligation) to provide care that is of a 
quality that meets the professionally recognized standard(s) of health care.  
 
  The care did not meet the standard of care but was less than a substantial violation of the 
obligation to provide care that is of a quality that meets professionally recognized 
standard(s) of health care (i.e., it was either significant or non-significant). 
 
The Reconsideration Peer Reviewer must complete his/her review of the medical information, 
adhere strictly to the format in the QRD Form, sign and date the form, and indicate the amount 
of time spent completing the review.  
 
The Reconsideration Peer Reviewer must return the package to the QIO with sufficient time to  ensure the QIO is able to complete its review of the reconsideration. A QIO must notify the 
practitioner or the provider of the results within five (5) calendar days after the QIO received the 
request for reconsideration, or within five (5) calendar days after receiving any medical 
information or other records needed for the QIO to complete the reconsideration.  
 
NOTE: If the Reconsideration Peer Reviewer has identified a concern(s) as either gross or 
flagrant, or the care failed in a substantial number of cases (more than three) to substantially 
comply with the obligation to provide care that is of a quality that meets professionally 
recognized standards of health care as required by 1156(a), then the QIO must initiate sanction 
proceedings in accordance with Manual Chapter 9. 
 
5120.2  General Quality of Care Review: Preparing the Reconsideration/Final 
Determination Package 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The QIO receives the review materials and completed QRD from the reconsideration Peer Reviewer and 
examines it to ensure all necessary information is returned. The QIO identifies the 
reconsideration decision on the QRD Form and prepares the General Quality of Care Review 
Final Reconsideration Letter for Practitioner/Provider (See Appendix 5-7).  
 
The QIO should use the language in the General Quality of Care Reviews: Initial Determination 
Letter unless substantial changes have been made. The QIO must notify the practitioner/provider 
of the QIOs Final Determination (as summarized in the Letter) no later than five (5) calendar 
days after receiving the request for reconsideration, or if later, five (5) calendar days after 
receiving any medical or other records needed for the reconsideration. 
 
5120.3  General Quality of Care Review: Preparing and Mailing the Final 
Reconsideration Determination Letter 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
In preparing the General Quality of Care Reviews: Final Reconsideration Determination Letter 
to Providers and Practitioners (See Appendix 5-7), the QIO must ensure the letter includes the 
following:  
 
1.  A statement for each quality of care concern that care did or did not meet the standard(s) 
of care; 
 
2.  The standard(s) that the QIO identified for each quality of care concern; 
 
3.  A specific statement conveying facts describing how the practitioner and/or provider did 
or did not meet specific criteria within the standard; and 
  
4.  A statement that this constitutes the QIOs final decision and that no further appeal rights 
are available. 
 
The QIOs Final Decision shall be issued to the provider no later than five (5) calendar days 
after the request for reconsideration, or if later, five (5) calendar days after receiving any  medical or other records needed for the reconsideration. See 42 CFR 476.170. 
 
NOTE: The timeframe for completion starts when additional information is received from all 
parties. If additional information is not received within seven (7) calendar days of the offer to 
submit additional information, the QIO should proceed with the reconsideration with the 
information that is available. 
 
5120.4  General Quality of Care Review: Procedures for Closing Review 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
The QIO must document in the CMS-designated case review system that the General Quality of 
Care Review is being closed by following all applicable requirements, and must place all file 
documents in hard copy or electronic file. A QIO may pursue Quality Improvement Initiatives in 
accordance with 5125 if deemed appropriate. 
 
5125 Beneficiary and Family-Centered Care-QIO  Recommendations and 
Referrals for Quality Improvement Initiatives and Technical Assistance 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Pursuant to the QIOs contract obligations, the Beneficiary and Family-Centered Care-QIO 
must make recommendations to Quality Innovation Network (QIN) - QIO or other CMS-
designated contractor(s) for conducting quality improvement initiatives (QIIs) associated with 
quality of care issues. QIIs may be the result of any Beneficiary and Family-Centered Care 
review function and could include system-wide change QIIs and non-system-wide change QIIs. 
 
A Quality Improvement Initiative (QII) is any formal activity designed to support quality 
improvement that uses proven methodologies to achieve these improvements. The improvements 
may relate to safety, health care, health, and value, and may involve providers, practitioners, 
beneficiaries, and/or communities. See 42 CFR 476.1. 
 
A QII may consist of system-wide and/or non-system-wide changes and may be based on a 
single, confirmed concern or multiple confirmed concerns. Pursuant to the QIOs contract 
obligations to develop and implement QIIs, QIIs must be considered for all confirmed concerns 
EXCEPT the following: 
 
1.  When it is determined that a practitioner(s) and/or provider(s) grossly and flagrantly 
failed to provide care that is of a quality that meets professionally recognized standard(s) 
of health care. (See 1156(a) of the Act.) 
 
2.  When the care failed in a substantial number of cases (more than three) to substantially 
comply with the obligation to provide care that is of a quality that meets the 
professionally recognized standard(s) of health care. (See 1156 of the Act.) 
 
NOTE: In either of the above instances, the QIO must initiate sanction proceedings in 
accordance with Manual Chapter 9. These proceedings will, if appropriate, involve the 
implementation of Corrective Action Plans. 
 
To fulfill the contract obligations to develop and implement QIIs, QIN-QIOs must consider all  aspects of the referral case. QIN-QIOs must employ data analysis techniques to identify potential 
opportunities to improve care. In addition, QIOs should consider the impact of changes within, 
and across, settings. For example, if a practitioner provides care in more than one setting (e.g., 
an inpatient acute care setting and a skilled nursing facility), the QIO should use information 
available from all settings to determine improvements in one or all of the settings. QIOs may 
work with one, several, or all related practitioner(s)/provider(s) concerned to improve the level 
of the practitioner's/providers performance; related practitioners/providers could include other 
practitioners/providers in the same setting(s) or other members of the practice setting. However, 
QIOs may not share information among providers without the specific consent of the 
practitioner(s) and/or provider(s).  
 
The Beneficiary and Family-Centered Care-QIOs are not responsible for conducting technical 
assistance with QIIs. This responsibility falls on the Quality Innovation Network-QIOs. 
However, the Beneficiary and Family-Centered Care-QIOs are in a position where they can 
recognize major areas in need of improvement. This includes completing a quality of care review 
whenever a medical record is requested for utilization reviewsuch as medical necessity, level 
of care, and higher-weighted DRGs (See QIO Manual Chapter 4)in addition to quality of care 
reviews for beneficiary complaints and other General Quality of Care reviews. Therefore, the 
QIOs input is important in designing quality improvement efforts that address trends in health 
care delivery that require improvement. See  5125.1 for additional information about QIOs 
responsibilities related to QIIs. 
 
5125.1 - Quality Improvement Initiatives  Beneficiary and Family-Centered 
Care QIO Responsibilities 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
One of the contract responsibilities of the BFCC- QIO is to make recommendations to Quality 
Innovation Network QIOs or other CMS-designated contractor(s) for conducting quality 
improvement initiatives (QIIs) associated with quality of care issues. QIIs may be the result of 
any Beneficiary and Family-Centered Care-QIO function and could include system-wide change 
QIIs and non-system-wide change QIIs. 
 
CMS expects that not every confirmed non-sanctionable quality of care concern will require a 
QII. When the Beneficiary and Family-Centered Care QIO determines that concerns can be 
addressed by offering advice or an alternative approach to the practitioner and/or provider, the 
BFCC-QIO should include that recommendation as part of their Final Determination Letter to 
the provider, practitioner and/or provider (See Appendix 5-4.1, 5-5.1,5-6, and 5-7 for applicable 
letters). When the BFCC QIO determines that the practitioner and/or provider needs technical 
assistance with QII, the BFCC QIO will refer to the Quality Innovation Network-QIO. 
 
One of the BFCC-QIOs contract duties is to provide recommendations and referrals to Quality 
Innovation Network-QIOs or other CMS-designated contractors for technical assistance be 
provided to health care practitioners and providers. This obligation arises when the BFCC-QIO 
has concluded a beneficiary complaint review and when the Beneficiary and Family-Centered 
Care-QIO has done at least one of the following: 
 
1.  Identified and confirmed quality of care concern(s) exist, after completion of the final 
review and including reconsideration if requested, that require QII; or   
2.  Has been approached by a practitioner and/or provider who is requesting the QIOs 
assistance. 
 
The referral to the QIN-QIO or other CMS-designated contractor for technical assistance should 
occur after the notice to the beneficiary in connection with a complaint and notice to the 
provider that a quality of care concern has been identified; if a reconsideration is requested, the 
referral should occur after the reconsideration is performed.   
 
In performing its contract responsibilities, the Beneficiary and Family-Centered Care-QIO must 
analyze findings from the CMS-designated case review system, other information from review 
activities, and information from providers to: 
 
  Identify trends and patterns; 
 
  Identify needs for technical assistance related to CMS quality measures across provider 
settings to help providers and practitioners meet standards. (An example of a CMS 
quality measure is a measure found in the National Hospital Inpatient Quality Measures 
set.); and 
 
  Make recommendations or referrals to the Quality Innovation Network-QIO or other 
CMS-designated contractor for technical assistance that promotes evidence-based 
medical practice and patient-centered care principles to improve the quality of health 
care, improve outcomes to beneficiaries, and lower costs.  
 
NOTE: Beneficiary and Family-Centered Care-QIO identified trends and patterns are to be 
addressed in coordination with the Beneficiary and Family-Centered Care National 
Coordinating Center (NCC) (See 5095-Tracking and Trending of Data). These types of 
recommendations must be provided to the Beneficiary and Family-Centered Care-NCC before 
being communicated to the applicable Quality Innovation Network-QIO. 
 
5125.2 - Quality Improvement Initiatives  Quality Innovation Network (QIN) 
- QIO Responsibilities 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Pursuant to its contract, the QIN-QIO shall: 
 
1.  Accept recommendations and referrals from approved sources for technical assistance to 
practitioners and providers when a need is identified for QIIs based on a confirmed 
quality of care concern; and 
 
2.  Assist provider(s)/practitioner(s) when technical assistance is requested from the 
practitioner/provider or recommended by other approved sources. Approved sources for 
referrals and recommendations include: 
 
  The Beneficiary and Family-Centered Care- QIOs  
  The Quality Innovation Network National Coordinating Center (NCC)     Value Incentive and Quality Reporting Center (VIQRC) contractors  
  Practitioner and/or provider requests for assistance  
  Others identified by CMS. 
 
Upon receiving a referral: 
 
1.  The QIN-QIO shall coordinate with the requestor to analyze findings for the 
referral.  
 
2.  For Beneficiary and Family-Centered Care-QIO referrals, the QIN-QIO shall 
coordinate with the Beneficiary and Family-Centered Care-NCC to analyze 
findings from the CMS-designated case review system, other information from 
review activities, and provider performance measures to: 
 
  Identify trends and patterns; and 
 
  Identify needs for technical assistance related to CMS measures across 
settings to help providers and/or practitioners meet standards. 
  
3.  The QIN QIO shall provide technical assistance that addresses the specific needs 
the QIO has identified and promotes evidence-based medical practice and 
beneficiary-centered care principles to improve quality of care and outcomes to 
beneficiaries.  
 
  The QIO shall develop measurable interventions in collaboration with the 
applicable provider/practitioner practice, taking into account the scope of 
the provider/practitioners practice. The intervention(s) should address 
systemic confirmed concerns. 
 
  The QIO shall assist health care provider(s) and/or practitioner(s), 
regarding how best to employ successful interventions and proven 
methods to improve health care quality and lower costs for the Medicare 
Program. 
 
NOTE: If, during the course of a QIN-QIOs work under its contract (i.e. other tasks in the QIO 
Task Order), the QIN-QIO identifies problems or concerns that could affect the quality of care 
that Medicare beneficiaries are receiving, the QIO working with its designated practitioner shall 
consider the need to request that the practitioner and/or provider initiate and complete an 
improvement plan to correct the problem.  
 
  If an improvement plan is warranted at the time the Quality Innovation Network - QIO 
requests initiation of the improvement plan, the QIO shall alert its CMS COR in writing 
of the request and the reason it was warranted; this involvement of the COR is pursuant 
to the QIO contract. A request for an improvement plan must be data based and clearly 
state the issue(s) that warrants improvement. The improvement plan must include the 
goals/objectives to be achieved, the process/measurements/tools to be used to assess the 
issue(s) and to measure improvement, and the timeframe for accomplishing the 
improvement plan, including monitoring/documenting improvement. The action to  improve the quality of care described in the providers/practitioners plan must be 
sustainable. 
 
In accordance with its contract, the QIN-QIO shall post tools and resources used in successful 
interventions on its Quality Innovation Network-QIO website within 30 days of 
COR/Government Task Lead (GTL) approval. 
 
5125.2.1  Unwillingness to Cooperate 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
In some instances, the practitioner(s) and/or provider(s) may clearly express intent not to 
cooperate with the QIO for Quality Improvement Initiatives. In these situations, the Quality 
Innovation Network-QIO should advise the practitioner(s) and/or provider(s) that the matter 
may be referred to the CMS COR (or to a State survey agency through the regional office). In 
addition, a QIO may refer the matter to other CMS contractors (e.g., Medicare Administrative 
Contractors), with appropriate review authority over the practitioners and/or providers 
activities or to the State Board of Licensing. The practitioner and/or provider(s) may also be 
subject to additional reviews focusing on identified areas of concern in appropriate situations. 
 
NOTE: Failure to agree to or participate in a Quality Improvement Initiative is not justification 
for referral to the Office of Inspector General (OIG) for possible sanction action. 
 
5125.2.2  Developing a Quality Improvement Initiative 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
As provided in the Quality Innovation Network-QIO contract, these QIOs are to work with the 
practitioner(s) and/or provider(s) to develop and implement QIIs. QIOs should ensure that all 
QIIs are cost-effective. The results of QIIs should be reproducible without necessitating 
excessive time and/or monetary expenditures. A QIO should assist practitioner(s) and/or 
provider(s) in leveraging all opportunities for improvement. In addition, the QIO should work 
with both the administrative and the medical staff (e.g., a hospital quality assurance committee) 
when providing information and developing, implementing, and monitoring QIIs. The QIO 
should investigate if the practitioner/provider has been recruited into any of the QIO Learning 
and Action Networks (LAN) and, when appropriate, request the practitioner/provider participate 
in the applicable LAN. 
 
5125.2.3  Time Frames for Developing a Quality Improvement Initiative 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
In accordance with the QIO contract, the planning of a Quality Improvement Initiative must be 
finalized within thirty (30) calendar days of receiving the referral/recommendation/request with 
a QII Plan. The implementation of a QII may be delayed an additional thirty (30) calendar days 
after the QII Plan is completed to obtain sufficient baseline data from which improvements can 
be measured. The QIO shall coordinate with the referring entity to determine if periodic reviews 
should be conducted during the implementation of interventions to gauge whether potential 
improvements are being realized and sustained (See 476.104).  
  5125.2.4  Quality Improvement Initiative Not Needed 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Under the Quality Innovation Network-QIO contracts, QIOs have the authority to pursue QIIs in 
all situations where quality of care concerns are confirmed but a referral for sanction or 
Corrective Action Plan covered in Manual Chapter 9 is not appropriate. However, there are 
situations where a QII may not be appropriate. For example:  
 
  A case is referred to a Federal or State enforcement agency responsible for the 
investigation or identification of fraud or abuse of the Medicare program. 
 
  The practitioner(s) and/or provider(s) provide evidence that the concern(s) is a single, 
isolated instance and does not effectively allow for improvement.  
  
  The underlying concern has already been identified and action taken to correct the 
problem (e.g., a Medicare coder who has been making numerous errors has been 
retrained and is now performing well). 
 
  The concern(s) will be resolved by a QII that has already been initiated. 
 
  The source of the concern is a physician, and the physician has retired, expired, or 
moved his/her practice out of the State.  
 
NOTE: When a practitioner has moved his/her practice out of State while a Quality of 
Care Review, Sanction Review under Part 1004, or Corrective Action Plan is pending, 
the QIO must forward any pertinent information to the QIO in the new State of practice. 
The appropriate COR must be provided with pertinent information related to the 
forwarding of concerns between QIOs.  
 
5125.2.5  Quality Improvement Initiative Root Cause Analysis 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
When a quality of care concern is confirmed and a referral initiated for a QII, the QIN-QIO 
should consult with the practitioner(s) and/or provider(s) to determine the root cause. This 
includes requesting that the practitioner(s) and/or provider(s) allow the QIO to review any root-
cause analysis independently completed.  
 
To conduct an adequate root cause analysis, the QIO must clearly identify the following: 
 
  The specific quality of care concern(s) at issue; 
 
  The type of provider (facility) or practitioner (individual) specialty involved; 
 
  How the concern(s) has affected the patient or patient care in general; 
 
  The impact of the concern(s) on health care operations; 
    Whether any injuries or harm resulted from the concern; 
 
  The prevalence of the concern; 
 
  Whether the concern was linked to CMS-identified or other nationally identified health 
care initiatives; 
 
  Any health care disparity issues associated with the concern(s); 
 
  Whether the Quality Innovation Network-QIO and/or the Beneficiary and Family 
Centered Care-QIO has any data or information giving evidence of other instances of the 
same concern(s) within the same or a different provider setting(s) and with the same or a 
different practitioner(s); 
 
  Whether the practitioner(s) and/or provider(s) are willing to cooperate in the Quality 
Improvement Initiative (NOTE: The failure to cooperate is not justification for initiating 
sanction proceedings.); and 
 
  Current baseline data relevant to the concern(s). 
 
When the baseline needs to be established as part of conducting an adequate root-cause 
analysis, the Quality Innovation Network-QIO must employ evidence-based techniques to obtain 
a clear snapshot of the current environment. To determine the baseline, the Quality Innovation 
Network- QIO must request data from the practitioner and/or provider that demonstrates other 
occurrences of the same or related concerns (or opportunities for the same and/or similar 
occurrences), including the timeframe during which the other instances occurred. Data before 
and after the time period when the actual concern arose should be considered. In most instances, 
QIOs should not request data for periods more than three (3) years before the time period when 
the actual concern arose.  
 
Both quantitative data and anecdotal information may be considered; however, emphasis should 
be placed on obtaining quantitative data. The Quality Innovation Network-QIO should review its 
own data or collaborate with the Beneficiary Family Centered Care-NCC to identify prior 
occurrences of the same or similar concerns with the same practitioner and/or provider or other 
practitioners and/or providers. Baseline data will be used to measure improvement(s) resulting 
from specific intervention(s) implemented with the Intervention and Improvement Plan.  
 
In conducting its analysis, a QIO should also consider any relevant information related to best 
practices developed or identified by the QIO or other QIOs.  
 
5125.2.6  Stand-alone or Isolated Concerns 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
In situations when the practitioner(s) and/or provider(s) indicates that the concern is a stand-
alone or isolated occurrence, a QIO may request any evidence the Quality Innovation Network 
-QIO determines is necessary and relevant to substantiate that an issue is an isolated occurrence 
(e.g., two to three examples of similar situations when the same concern did not present itself). In  addition, the QIO shall review its own data.  
 
5125.2.7  Intervention and Improvement Plan 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Once the Root Cause Analysis has been completed, the Quality Innovation Network-QIO 
develops the Intervention and Improvement Plan in consultation with the practitioner(s) and/or 
provider(s). The QIO identifies the intended outcome of intervention(s) and whether or not the 
identified outcome(s) is mutually established with the practitioner(s) and/or provider(s) as part 
of the Plan. An adequate Intervention and Improvement Plan lists the specific action(s) the 
practitioner(s) and/or provider(s) will take to correct the underlying cause of the concern(s) and 
identify a timeframe for initiating and completing the Intervention and Improvement Plan. 
During the implementation period, the Intervention and Improvement Plan should include 
periodic review of the specific intervention(s) against baseline data so that improvements can be 
monitored and any appropriate adjustments to the initiative considered. 
 
5125.2.8  Monitoring Quality Improvement Initiatives 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
At any point during the time period when interventions are being implemented, if the Quality 
Innovation Network-QIO, practitioner(s) and/or provider(s) determine that improvement is not 
being attained, the parties should meet as soon as possible to discuss possible reasons for the 
failure to achieve improvements and explore alternatives that may achieve the desired 
improvements. The parties should share data and mutually agree to the modifications to the 
Intervention and Improvement Plan, using the format of the original plan as described in 
5125.2 (h), Intervention and Improvement Plan.   
 
5125.2.9  Reporting Results of System-wide Change Quality Improvement 
Initiatives 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Pursuant to their contracts, Quality Innovation Network QIOs must report system-wide changes 
due to Quality Improvement Initiatives (QIIs) to CMS. Attribution of the improvements to the 
specific interventions that the QIO identified and/or in consultation with the practitioner and/or 
provider is an integral part System-wide Change Quality Improvement Initiatives. Documented 
improvement is required and is defined as any amount of quantitative improvement in a process 
or outcome related to the quality of care concern that is attributable to the QIOs activity. In 
reporting the system-wide change under the contract, QIOs must document the problem, define 
interventions as implemented by the provider(s) and/or practitioner(s), identify goals of the 
change, and describe the evaluation methodology.  
 
NOTE: QIOs may include additional information if necessary to demonstrate the success of the 
QII.  
 
A Quality Innovation Network-QIO should work with its COR to determine the best method for 
ensuring continuous progress related to successful completion of system-wide changes, including 
determining when the System-wide Change Report must be uploaded into the CMS-designated  case review system. A QII is deemed completed once the pertinent period of data collection 
has been fulfilled, and the QIO is able to demonstrate that the goals of the system-wide change 
have been attained.  
 
Pursuant to its contract, a Quality Innovation Network-QIO shall submit a report, in accordance 
with agreed-upon timeframes with the COR, that describes progress on the initiation, 
development, implementation, and conclusion for each QII. The report shall identify successful 
interventions (e.g., tools and resources) used in each QII. In addition, the report shall include 
the details of any unsuccessful QIIs based on the unwillingness of practitioner(s) and/or 
provider(s) to participate or instances when the QIO decided not to initiate a QII. A 
representative from the QIO shall be prepared to discuss the progress of their QII efforts with 
the COR on an as-needed basis. 
    Appendix 
 
Appendix 5-1.1  Medicare Quality of Care Complaint Form 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
Medicare QUALITY OF CARE COMPLAINT FORM  
 
Information to Help You Fill Out the Quality of Care Complaint Form  
The Medicare Program works to ensure that beneficiaries get the best care possible. We take 
your concern(s) seriously, and we would like to get more information to help us review your 
request. Use of this form will ensure that we process your concerns in an efficient manner. 
Quality Improvement Organizations (QIOs), are under contract with Medicare and are 
required to conduct reviews of all written complaints from beneficiaries about the quality of 
services not meeting professionally recognized standards of health care. You may contact the 
QIO for assistance in completing this form or for general assistance regarding your complaint.  
Please use this step by step instruction sheet when completing your Quality of Care 
Complaint Form. Be sure to complete all sections of the form. In addition, if your personal 
information has been included in the form based on contact you have had with the QIO for 
your State, please review the information to confirm its accuracy. 
 
1.  Print the name of the Medicare beneficiary who has a complaint about the quality of 
health care he/she received.  
2.  Include the Beneficiarys Medicare (HICN) number if known.  
3.  Check the appropriate box designating the sex of the individual listed in number 1. In 
addition, please indicate the age of the beneficiary in the blank space provided, if known.  
4.  Check the appropriate box or boxes indicating the race/ethnicity of the individual listed 
in number 1. Please note that this information is strictly voluntary and has no impact on 
the processing of the complaint.  
 
5.  Print the name of the beneficiarys authorized representative if someone other than the 
beneficiary will be the contact for the processing of the complaint.  
6.  Print the contact information for the beneficiary or for the beneficiarys authorized 
representative who is authorized to be the contact for the processing of the complaint.  
 
7.  Provide a brief description of the incident or concern. The description should include any 
information you believe is relevant to the review of your complaint, including:  
 
  Dates and times,  
 
  Identification of physicians and provider staff involved,  
 
  Information from witnesses if available, and   
  A description of what happened; and  
 
  If you require more space to describe your complaint, you may attach additional 
sheets of paper and you may provide any documents you believe support your 
complaint. 
 
PLEASE NOTE: If you raise concerns that are not quality of care concerns within the scope of 
the QIOs authority, your complaint will be referred to the appropriate entity.  
1.  By signing the form, you are authorizing the QIO to review your complaint and render a 
formal determination. The processing of your complaint may require requesting and 
reviewing of pertinent medical records.  
 
2.  PLEASE keep this page for your information. Only mail the second page (Medicare Quality 
of Care Complaint Form) to the QIO. The phone number of your QIO is ______________. A 
decision on your complaint will be made within ___ days of receiving the signed complaint 
form. 
 
 
Form CMS-10287 (Revised 07/14) 
 
MEDICARE QUALITY OF CARE COMPLAINT FORM 
1. Beneficiary Name: 
2. Medicare # (HICN):  
3. Sex: Male__ Female__ Age: ____ Date of Birth:_____  
4. Race/Ethnicity (Completion of this section is voluntary): How would you describe your race? 
Please mark one or more boxes. American Indian or Alaska Native___ Native Hawaiian or 
Other Pacific Islander __ White__ Asian __ Black or African American__ Hispanic or 
Latino___  
5. Beneficiarys Authorized Representatives Name (If applicable):  
6. Contact Information:  
Street/Apt.  
City:   State:   Zip:  
Phone:   Alternate Phone:  
7. Briefly Describe the incident or your concerns: Include dates and times, persons involved, 
and description of what happened. Include attachments, if appropriate.  
8. May we reveal your identity during the review of your complaint? Yes__ No __ 
If you check no we cannot review your complaint as a written beneficiary complaint. 
However, based on the circumstances of your complaint, we may choose to review your 
complaint as a general quality of care review. You will not receive any information or notice 
about a general quality of care review if the QIO chooses to perform one.  9. Check yes here if you authorize the QIO to forward your address or other contact 
information to the entity that conducts beneficiary satisfaction surveys. If you check yes, you 
will be contacted by telephone or postal mail to conduct a brief survey about your satisfaction 
with the service you received from the QIO. If you leave this question blank, a surveyor will 
contact you about your satisfaction.  
Yes___ No___  
For your information: If you have any questions about your complaint, please call 
_________________. You will be contacted within ___ days upon the QIOs receipt of the 
signed complaint form. The QIO will use a physician who practices in the same or similar 
clinical area as the physician who provided your care in completing its review. You may provide 
any information you believe is relevant to your complaint, including copies of documentation, 
names of witnesses, etc. A decision will be made on your complaint within ___ days of receiving 
the signed complaint form. If your complaint includes concerns not within the scope of the QIOs 
authority, the concerns will be referred to the appropriate entity.  
10. By signing this form, I am requesting that the QIO review my complaint. 
Signature of Beneficiary/Representative:   Date:  
 
According to the Paperwork Reduction Act of 1995, no persons are required to respond to a 
collection of information unless it displays a valid OMB control number. The valid OMB control 
number for this information collection is 0938-1102. The time required to prepare and distribute 
this collection is 10 minutes per notice, including the time to select the preprinted form, complete 
it and deliver it to the beneficiary. If you have comments concerning the accuracy of the time 
estimates or suggestions for improving this form, please write to CMS, PRA Clearance Officer, 
7500 Security Boulevard, Baltimore, Maryland 21244-1850 
 
Form CMS-10287 (Revised 07/14) 
     
Appendix 5-1.2  Appointment of Representative Form 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
DEPARTMENT OF HEALTH AND HUMAN SERVICES                           Form Approved OMB No.0938-0950  
CENTERS FOR MEDICARE &    MEDICAID SERVICES 
 
                     
 
APPOINTMENT OF  REPRESENTATIVE 
 
 
Section 1: Appointment of Representative 
To be completed by the party seeking representation (i.e., the Medicare beneficiary, the 
provider or the supplier): 
I appoint this individual,  to act as my representative in 
connection with my claim or asserted right under Title XVIII of the Social Security Act (the 
Act) and related provisions of Title XI of the Act. I authorize this individual to make any 
request; to present or to elicit evidence; to obtain appeals information; and to receive any notice 
in connection with my appeal, wholly in my stead. I understand that personal medical 
information related to my appeal may be disclosed to the representative indicated below. 
 
Signature of Party Seeking Representation  Date 
Street Address  Phone Number (with Area Code) 
City  State  Zip Code 
Section 2: Acceptance of Appointment 
To be completed by the representative: 
I,  ,hereby accept the above appointment. I certify that I have 
not been disqualified, suspended, or prohibited from practice before the Department of Health 
and Human Services (DHHS); that I am not, as a current or former employee of the United 
States, disqualified from acting as the partys representative; and that I recognize that any fee 
may be subject to review and approval by the Secretary. 
I am a / an     
(Professional status or relationship to the party, e.g. attorney, relative, etc.) 
 
Signature of Representative  Date 
Street Address  Phone Number (with Area Code) 
City  State  Zip Code  Section 3: Waiver of Fee for Representation 
Instructions: This section must be completed if the representative is required to, or 
chooses to waive their fee for representation. (Note that providers or suppliers that are 
representing a beneficiary and furnished the items or services may not charge a fee for representation 
and must complete this section.) 
I waive my right to charge and collect a fee for representing  before the 
Secretary of DHHS. 
     
 
Section 4: Waiver of Payment for Items or Services at Issue 
Instructions: Providers or suppliers serving as a representative for a beneficiary to whom 
they provided items or services must complete this section if the appeal involves a 
question of liability under section 1879(a)(2) of the Act. (Section 1879(a)(2) generally 
addresses whether a provider/supplier or beneficiary did not know, or could not reasonably be 
expected to know, that the items or services at issue would not be covered by Medicare.) 
I waive my right to collect payment from the beneficiary for the items or services at issue in this 
appeal if a determination of liability under 1879(a)(2) of the Act is at issue. 
     
  Charging of Fees for Representing Beneficiaries before the Secretary of DHHS 
An attorney, or other representative for a beneficiary, who wishes to charge a fee 
for services rendered in connection with an appeal before the Secretary of 
DHHS (i.e., an Administrative Law Judge (ALJ) hearing, Medicare Appeals 
Council review, or a proceeding before an ALJ or the Medicare Appeals 
Council as a result of a remand from federal district court) is required to obtain 
approval of the fee in accordance with 42 CFR 405.910(f). 
The form, Petition to Obtain Representative Fee elicits the information 
required for a fee petition. It should be completed by the representative and filed 
with the request for ALJ hearing or request for Medicare Appeals Council 
review. Approval of a representatives fee is not required if: (1) the appellant 
being represented is a provider or supplier; (2) the fee is for services rendered in 
an official capacity such as that of legal guardian, committee, or similar court 
appointed representative and the court has approved the fee in question; (3) the 
fee is for representation of a beneficiary in a proceeding in federal district court; 
or (4) the fee is for representation of a beneficiary in a redetermination or 
reconsideration. If the representative wishes to waive a fee, he or she may do so. 
Section III on the front of this form can be used for that purpose. In some 
instances, as indicated on the form, the fee must be waived for representation. 
 
Approval of Fee 
The requirement for the approval of fees ensures that a representative will receive 
fair value for the services performed before DHHS on behalf of a beneficiary, and 
provides the beneficiary with a measure of security that the fees are determined to 
be reasonable. In approving a requested fee, the ALJ or Medicare Appeals 
Council will consider the nature and type of services rendered, the complexity of 
the case, the level of skill and competence required in rendition of the services, 
the amount of time spent on the case, the results achieved, the level of 
administrative review to which the representative carried the appeal and the 
amount of the fee requested by the representative. 
 
Conflict of Interest 
Sections 203, 205 and 207 of Title XVIII of the United States Code make it a 
criminal offense for certain officers, employees and former officers and 
employees of the United States to render certain services in matters affecting the 
Government or to aid or assist in the prosecution of claims against the United 
States. Individuals with a conflict of interest are excluded from being 
representatives of beneficiaries before DHHS. 
 
Where to Send This Form 
Send this form to the same location where you are sending (or have already 
sent) your: appeal if you are filing an appeal, grievance if you are filing a 
grievance, initial determination or decision if you are requesting an initial 
determination or decision. If additional help is needed, contact your Medicare  plan or 1-800-MEDICARE (1-800-633-4227). TTY users please call 1-877-
486-2048. 
CMS does not discriminate in its programs and activities. To request this 
publication in an alternative format, please call: 1-800-MEDICARE or email:  
AltFormatRequest@cms.hhs.gov. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information 
unless it displays a valid OMB control number. The valid OMB control number for this information collection is 0938-
0950. The time required to prepare and distribute this collection is 15 minutes per notice, including the time to select 
the preprinted form, complete it and deliver it to the beneficiary. If you have comments concerning the accuracy of the 
time estimates or suggestions for improving this form, please write to CMS, PRA Clearance Officer, 7500 Security 
Boulevard, Baltimore, Maryland 21244-1850. 
    Appendix 5-1.3  Quality Review Decision (QRD) Form 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
Quality Review Decision (QRD) Form 
Case Summary 
 
Case ID#:    State: Choose a State     
 
Patient Details 
Patient Name:    HIC#:   
Date of Birth:  Click here to enter a Date of Birth.         Date QRD Created: Enter QRD 
Created date. 
Date of Death:Click here to enter a Date of Death. 
 
Beneficiary Point of View: 
 
 
Health Service Encounter 
Provider/Practitioner Name:   
Provider CCN:           Service Start Date: Click here to enter Service 
Start Date 
Provider/Practitioner NPI:    Service End Date: Click here to enter 
Service End Date. 
Reason for Health Service Encounter/Admitting Diagnosis: 
 
 
Case Summary Notes: 
 
  Review Details 
Review Analyst:   
Review Due Date:  
 
Review Analyst Assessment 
Please note that the information below must be prepared for each 
Quality of Care (QoC) Concern identified in the complaint 
 
Case ID#:  
QoC Concern #:  
 
Concern Summary 
Concern Category: ____________________ 
Improvement may be needed in:  _________ 
Quality of Care Concern  
 
 
Identified by: 
 
 
 
 
Source:  
 
Practitioners involved: 
Name:    NPI:    
 
Relevant Standard of Care: 
 
 
Standard of Care Category:  
Standard of Care Source:      
Standard of Care Publication Date:   
 
Additional Information: 
 
 
Initial Determination Peer Review 
 
Case ID#:   QoC Concern #:  
 
Conclusion:  
Standard of Care Met  
Standard of Care Not Met   Grossly and flagrantly violated the obligation in 1156(a)(2) of the Act, in one or more 
instances, to provide care that is of a quality that meets professionally recognized 
standards (Sanction Activity Required)  
Failed in a substantial number of cases (more than three) to substantially comply with 
the obligation in 1156(a)(2) of the Act, to provide care that is of a quality that 
meets professionally recognized standards (Sanction Activity Required)  
Substantial failure to comply with the obligation in 1156(a)(2) of the Act to provide 
care that is of a quality that meets professionally recognized standards (Quality 
Improvement Initiative recommended; consider referral for technical assistance 
with QII)  
Significant concern (Quality Improvement Initiative recommended; consider referral 
for technical assistance with QII) 
Non-significant concern (Quality Improvement Initiative recommended; QIO to 
consider offering advice or an alternative approach or education) 
 
Agree with QIO Identified Standard of Care: 
 Agree            
 Do Not Agree       
 Concern Identified by IDPR 
  Reason for Disagreement:  Relevant Standard of Care:  
 
Standard of Care Category: 
Standard of Care Source: 
 Standard of Care Date: 
 
 
Rationale/Justification:  
 
 
 
Conflict of Interest Statement:  
I do not have a material, professional, familial, or financial conflict of interest regarding 
any parties associated with this case including any referring entity, any health benefits 
plan, the patient or his/her family, the care providers, the facility, or the developer or 
manufacturer of the principal drug, device, procedure, or other therapy being 
recommended (prescribed) or provided; nor have I accepted compensation for my 
independent review activities that is dependent in any way on the specific outcome of the 
case or had involvement with the case prior to its referral to independent review. 
Initial Determination Peer Reviewer Name (print): 
__________________________________________ 
Initial Determination Peer Reviewer Signature: 
___________________________________________ 
Date:                       Minutes Spent on Case:  
 
 
Final Initial Determination Peer Review 
 
Case ID#:  
QoC Concern #:  
 
Written Response Received from practitioner and/or provider:  
 
Relationship of Information to Standard of Care:  
 
 
Conclusion:  
Standard of Care Met  
Standard of Care Not Met  
Grossly and flagrantly violated the obligation in 1156(a)(2) of the Act, in one 
or more instances, to provide care that is of a quality that meets 
professionally recognized standards (Sanction Activity Required)  
Failed in a substantial number of cases (more than three) to substantially 
comply with the obligation in 1156(a)(2) of the Act, to provide care that is  of a quality that meets professionally recognized standards (Sanction 
Activity Required)  
Substantial failure to comply with the obligation in 1156(a)(2) of the Act to 
provide care that is of a quality that meets professionally recognized 
standards (Quality Improvement Initiative recommended; consider referral 
for technical assistance with QII)  
Significant concern (Quality Improvement Initiative recommended; consider 
referral for technical assistance with QII) 
Non-significant concern (Quality Improvement Initiative recommended; QIO to 
consider offering advice or an alternative approach or education) 
 
Rationale/Justification:  
 
 
Conflict of Interest Statement:  
I do not have a material, professional, familial, or financial conflict of interest regarding 
any parties associated with this case including any referring entity, any health benefits 
plan, the patient or his/her family, the care providers, the facility, or the developer or 
manufacturer of the principal drug, device, procedure, or other therapy being 
recommended (prescribed) or provided; nor have I accepted compensation for my 
independent review activities that is dependent in any way on the specific outcome of the 
case or had involvement with the case prior to its referral to independent review. 
Initial Determination Peer Reviewer Name: 
__________________________________________ 
Initial Determination Peer Reviewer Signature: 
___________________________________________ 
Date:                                    Minutes Spent on Case:  
 
 
Reconsideration Peer Review 
 
Case ID#:  
QoC Concern #:  
Written Reconsideration Request Received from practitioner and/or provider: Click 
here to enter received date. 
 
Conclusion:  
Standard of Care Met  
Standard of Care Not Met  
Grossly and flagrantly violated the obligation in 1156(a)(2) of the Act, in one 
or more instances, to provide care that is of a quality that meets 
professionally recognized standards (Sanction Activity Required)  
Failed in a substantial number of cases (more than three) to substantially 
comply with the obligation in 1156(a)(2) of the Act, to provide care that is  of a quality that meets professionally recognized standards (Sanction 
Activity Required)  
Substantial failure to comply with the obligation in 1156(a)(2) of the Act to 
provide care that is of a quality that meets professionally recognized 
standards (Quality Improvement Initiative recommended; consider referral 
for technical assistance with QII)  
Significant concern (Quality Improvement Initiative recommended; consider 
referral for technical assistance with QII) 
Non-significant concern (Quality Improvement Initiative recommended; QIO to 
consider offering advice or an alternative approach or education) 
 
Rationale/Justification:  
 
 
Agree with QIO Identified Standard of Care: 
 Agree     
 Do Not Agree    
 Concern Identified by RPR 
Reason for Disagreement: Relevant Standard of Care:  
Standard of Care Category: 
Standard of Care Source: 
Standard of Care Date: 
 
Conflict of Interest Statement:  
I do not have a material, professional, familial, or financial conflict of interest regarding 
any parties associated with this case including any referring entity, any health benefits 
plan, the patient or his/her family, the care providers, the facility, or the developer or 
manufacturer of the principal drug, device, procedure, or other therapy being 
recommended (prescribed) or provided; nor have I accepted compensation for my 
independent review activities that is dependent in any way on the specific outcome of the 
case or had involvement with the case prior to its referral to independent review. 
Reconsideration Peer Reviewer Name: 
__________________________________________ 
Reconsideration Peer Reviewer Signature: 
___________________________________________ 
Date:    __               Minutes Spent on Case: 
_______________________________________________________________________ 
    Appendix 5-2  Beneficiary Quality of Care Complaint: Initial 
Acknowledgement Letter to Beneficiary/Beneficiary Representative 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
QIO LETTERHEAD 
INITIAL NOTIFICATION 
Date of Notice 
Name of Addressee 
Address 
City, State, and Zip Code 
 
Beneficiary Name  
Medicare # (HICN)  
Practitioner/Provider Name  
Practitioner/Provider Number (CCN/NPI/UPN)  
Date(s) of Service 
 
Dear [insert name of Beneficiary/ or Representative here]: 
 
We have received your written quality of care complaint(s). Thank you for taking the time 
to bring your health care concern(s) to our attention.  
 
[Insert QIO name here] is the Beneficiary and Family Centered Care Quality 
Improvement Organization (QIO) authorized by the Centers for Medicare & Medicaid 
Services (CMS) to review medical services provided to people with Medicare in [Insert 
QIO area/region here]. As part of our mission, we review all written complaints about 
the health care that was provided by a physician and/or facility to people with Medicare. 
The goal of our review is to determine if that care was appropriate and followed 
acceptable medical standards. Our review is based on what is written in the medical 
record but is not limited to your specific complaints. During the review, we may find 
other concerns about the care you received. You will get our result(s) in writing when the 
review is completed.  
 
These are examples of the types of factors we can review in a medical record: 
 
  Was your medical condition diagnosed correctly? 
  
  Did you get the right medication for your medical problem?  
 
  Did the doctor perform the right surgery? 
 
  Was the care given to you by the staff done correctly? 
 
Our review process does not address issues such as billing, customer service, 
communication, legal, or any other issues that are not noted in the medical record. We  understand that these issues are important, but our quality of care review is limited to the 
medical care reflected in the entries in the medical record.  
 
If a quality of care concern is identified, we offer education and feedback to providers to 
improve the quality of care for people with Medicare. The following is a summary of the 
concerns identified in your written complaint.   
 
Summary of Concern(s) 
What the Medicare Complaint Process CAN Address 
 
This first section of the summary letter contains the parts of your complaint(s) that can 
be addressed by a review of the medical record. 
 
NOTE: The following is for instructional purposes ONLY. DO NOT INCLUDE IN 
THE LETTER. 
 
PREPARATION NOTE FOR THE QIO 
The summary must include the specific concerns identified by the beneficiary and 
any concerns identified by the QIO based on the initial intake analysis. (See  
5110.1)  
 
This information should be consistent with the information contained in the QRD 
Form. (See 5230.2)] 
 
What the Medicare Complaint Process CANNOT Address 
 
This second section of the summary letter contains any part of your complaint(s) that may 
be related to customer service, billing, legal, or other issues that cannot be addressed by 
a review of the medical record. 
 
NOTE: The following is for instructional purposes ONLY. DO NOT INCLUDE IN 
THE LETTER. 
 
PREPARATION NOTE FOR THE QIO 
The summary must include the specific concerns identified by the beneficiary and 
any concerns identified by the QIO based on the initial intake analysis. (See 
5110.1)  
 
This information should be consistent with the information contained in the QRD 
Form. (See 5230.2)] 
 
We want to make sure that we clearly understand your quality of care concerns. Please 
feel free to contact us with any questions or comments you may have.  
 
[Insert QIO Name] 
[Insert QIO Contact Person]  [Insert QIO Address] 
[Insert QIO Contact Number] 
[Insert QIO Fax Number] 
 
It is important to let you know that the actual time needed to complete our review will 
depend on the time needed to obtain the necessary medical records and responses from 
the practitioner(s)/provider(s) involved. If there are any delays in the process, we will 
contact you.  
 
Once again, thank you for bringing your concerns to our attention.  
 
Sincerely, 
 
 
Medical Director (or designated physician) 
[Insert title here] 
 
    Appendix 5-3  Beneficiary Quality of Care Complaint: Interim 
Determination Letter for Practitioners and Providers 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
NOTE: This letter is optional since the Interim Determination can be given to 
Providers/Practitioners via phone and/or in writing. (See 5055.1)  
 
QIO LETTERHEAD 
 
Date of Notice 
 
QIO Liaison for Provider or Practitioners Name 
Name of Addressee  
Address 
City, State, and Zip Code 
 
Beneficiary Name  
Medicare # (HICN)  
Practitioner/Provider Name  
Practitioner/Provider Number (CCN/NPI/UPN)  
Date(s) of Service 
 
Dear: [insert name of Practitioner or Provider here] 
 
The [Insert QIO name here] is the Quality Improvement Organization (QIO) authorized 
by the Centers for Medicare & Medicaid Services (CMS) to review medical services 
provided to Medicare beneficiaries in [Insert QIO area/region here]. One of the 
functions we perform is the review of health care provided to Medicare beneficiaries to 
determine if the care provided was consistent with professionally recognized standards of 
health care, normally referred to as a Quality of Care Review. QIOs conduct these 
reviews to investigate complaints initiated by beneficiaries or the patients 
representatives about the health care they received. In addition, Quality of Care Reviews 
may be performed as a result of other tasks that CMS assigns to the QIO.  
 
Opportunity for Discussion 
As part of the review process, we are required to give you an opportunity to discuss our 
initial findings before we make our final decision. Your response can be written or oral 
and must be received within 7 calendar days from the receipt of this letter in order for us 
to consider information you provide in our Final Determination. Please be advised that 
this is not an opportunity for you to submit additional medical information. If additional 
medical information is submitted, we will not consider it in rendering the Final 
Determination. However, we welcome any policies, guidelines, rationale, and/or 
evidence-based information you would like us to consider in the review.  
 
Summary of Findings  A QIO Peer Reviewer has reviewed the care provided to [Insert name of beneficiary who 
has consented here] by [name of practitioner] or at [name of provider]. Based on an 
evaluation of the information received, the following is the summary of our review. 
Confirmed and/or identified concern(s): 
 
NOTE: The following is for instructional purposes ONLY. DO NOT INCLUDE IN 
LETTER 
PREPARATION NOTE FOR QIO 
The summary must include:  
 
  The specific concerns identified by the beneficiary and any concerns identified 
by the QIO based on the Scope of Review (See 5110.1),  
 
  The standard of care associated with each concern,  
 
  A statement of the analysis and findings for each concern, and  
 
  A statement to the practitioner informing him/her that their consent is not 
required for the QIO to disclose specific findings about the review to the 
beneficiary. 
 
This information should be consistent with the information contained in the QRD Form 
(See 5230.2)]. 
 
Please direct your response to: 
[Insert QIO Name] 
[Insert QIO Contact Person] 
[Insert QIO Address] 
[Insert QIO Contact Number] 
[Insert QIO Fax Number] 
 
If you have any questions about this letter or would like to make arrangements to discuss 
this case, contact the person listed above.  
 
If the concerns involve both a physician/practitioner and a provider, the 
physician/practitioner and the representative for the provider may respond separately to 
the opportunity for discussion. However, we strongly encourage coordination of the 
responses. 
 
If we do not receive your response within 7 calendar days from the receipt of this letter, 
the Initial Determination will become our Final Determination, and we will send you a 
letter noting this change. The information in this letter is confidential, and you may 
disclose it only in accordance with Federal regulations found in 42 CFR Part 480. 
 
If you have any questions about this letter, please contact the above-named person within 
the time frame described above.    
 
Sincerely, 
 
Medical Director (or designated physician) 
[Insert title here] Appendix 5-4  Final Initial Determination Letter to 
Practitioners/Providers with Request to Disclose (For Beneficiary 
Complaints) 
(Rev. 17, Issued: -04-06-12, Effective: 05-07-12 Implementation: 05-07-12) 
 
QIO LETTERHEAD 
 
Date of Notice 
Name of Addressee 
Address 
City, State, and Zip Code 
 
Patient Name (when the patient has consented to disclosure) 
Health Insurance Claim (HIC) Number 
Practitioner/Provider Name (If this applies) 
Practitioner/Provider Number (If this applies) 
Date of Admission/Service 
Medical Record Number (if known) 
 
Dear: 
 
Previously, you were afforded the opportunity to discuss our review of care you provided 
in our letter (dated _____).  This letter constitutes our Final Initial Determination based 
on a careful review of the information provided by the beneficiary in filing the complaint, 
information contained in the medical information, as well as any information provided 
during the opportunity for discussion. 
 
Summary of Findings 
 
The results of our review are as follows:  
PREPARATION NOTE FOR QIO 
The summary must include: 
  the specific concerns identified by the beneficiary and any concerns 
identified by the QIO based on the Scope of Review (See 5110.1), 
  the standard of care associated with each concern, and  
  a statement of the analysis and findings regarding each concern, including 
specific information detailing the evaluation of information obtained as a 
result of the opportunity for discussion and any differences and/or 
changes between the Interim and Final Initial Determinations.   
The information should be consistent with the information contained in the 
Quality Review Decision (QRD) Form. 
 
Consent to Release Findings to the Beneficiary 
We will inform beneficiaries about whether the care they were provided did or did not 
meet professionally recognized standards of care. In order for us to release to the 
beneficiary more specific facts about the actions of particular practitioners involved in the  care of the beneficiary, and how their actions did or did not meet the standard of care, we 
must obtain consent from those practitioner(s) The findings we propose releasing to the 
beneficiary are attached to (or included in) this letter.  If you are a practitioner, please 
review the language and indicate consent to our disclosing the information to the 
beneficiary within thirty calendar days from the date of this letter.  Please note that we 
will treat your failure to indicate your consent as your declining to consent and the 
beneficiary will not be informed of these specific findings.  In order to facilitate release 
of these specific findings to the beneficiary, please contact the QIO representative named 
below to discuss the attached findings: 
 
Name of QIO Contact Person 
Address 
Telephone Number 
 
PREPARATION NOTE FOR QIO:  
  If the notice is addressed to the provider and/or physician practice or some 
other practitioner, insert the name of the practitioner(s) also notified and 
include the statement:   
 The following practitioner, [insert name(s)] also has been notified of our 
o
Final Initial Determination and contacted to obtain his/her consent to 
disclose the specific findings to the beneficiary. 
  If the notice is addressed to a practitioner, insert the name of the provider if 
applicable.  Do not specify other physicians or practitioners you may be 
notifying. 
  If the notice is addressed to the provider and will also be sent to a physician 
practice or some other practitioner, insert into the providers notice the 
name(s) of the practitioner(s) also notified and include the statement:   
 The following practitioner(s), [insert name(s)] also has been notified of 
o
our Final Initial Determination and contacted to obtain his/her consent to 
disclose the specific findings to the beneficiary. 
  If the notice is addressed to a practitioner or physician practice, insert the 
name of the provider if applicable.  Do not specify other physicians or 
practitioners you may be notifying. 
 
 
Right to Request a Re-Review 
PREPARATION NOTE FOR QIO 
The QIO must select the appropriate paragraph depending on whether a 
Retrospective or Concurrent Review is being conducted (Do NOT include For 
Retrospective Review or For Concurrent Review heading in the actual letter).  
In addition, the references to the other practitioners receiving the letter should not 
be included if addressed to a practitioner. 
For Retrospective Review 
We are also notifying (name (See NOTES above)) of our Final Initial 
Determination.  If you or (name (See NOTES above)) disagree with this Final 
Initial Determination, either party may request a Re-Review.  To request a Re- Review, you must submit your request in writing within 15 calendar days from 
the date of this letter.  Your request for a Re-Review may include additional 
information and/or documentation, including medical information you believe 
supports your request for a Re-Review. 
For Concurrent Review 
We are also notifying (name (See NOTES above)) of our Final Initial 
Determination.  If you or (name (See NOTES above)) disagree with this Final 
Initial Determination, you must submit your request in writing within 5 calendar 
days from the date of this letter.  Your request for a Re-Review may include 
additional information and/or documentation, including medical information you 
believe supports your request for a Re-Review.   
 
 
Your request for a Re-Review may be submitted via mail or facsimile to the following 
address: 
 
QIO Name 
Address 
Facsimile Number 
 
Please be advised that if a Re-Review is requested, you [practitioner] will again be 
provided the opportunity to consent to our disclosing information to the beneficiary after 
the Re-Review determination.  
 
The information in this notice is confidential and may be re-disclosed only in accordance 
with federal regulations found in 42 CFR Part 480. 
 
Sincerely, 
 
 
Medical Director (or designated physician) 
(Include title) 
  Appendix 5-4.1  Beneficiary Quality of Care Complaint: Final 
Determination Letter to Practitioners and Providers 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
QIO LETTERHEAD 
 
Date of Notice 
QIO Liaison for Provider or Practitioners Name 
Name of Addressee  
Address 
City, State, and Zip Code 
 
Beneficiary Name  
Medicare # (HICN)  
Practitioner/Provider Name  
Practitioner/Provider Number (CCN/NPI/UPN)  
Date(s) of Service 
 
Dear [insert name of Practitioner or Provider here]:  
 
In our Initial Determination Letter, dated [insert date here], you were given the 
opportunity to discuss our review of the care you provided. This letter constitutes our 
Final Determination based on a review of the complaint, the medical information, and 
any correspondence provided during the opportunity for discussion. 
 
Summary of Review 
A QIO Peer Reviewer has reviewed the care provided to [Insert name of beneficiary 
relevant to the complaint] by [name of practitioner] or at [name of provider]. Based on 
an evaluation of the information received, the following is the summary of our review. 
 
Confirmed and/or identified concern(s) [should be the same as in the Interim 
Determination Letter] 
 
NOTE: The following is for instructional purposes ONLY. DO NOT INCLUDE IN 
THE LETTER 
 
PREPARATION NOTE FOR THE QIO 
The summary must include:  
 
  The specific concerns identified by the beneficiary and any concerns identified by 
the QIO based on the Scope of Review (See 5110.1), 
  
  The standard of care associated with each concern,  
 
  A statement of the analysis and facts the QIO determines are pertinent to its 
findings, including references to medical information and, if held, information  obtained as a result of the opportunity for discussion with the involved 
practitioner or provider, and  
 
  For each concern, there should be a statement about whether or not the care 
provided was consistent with standards of health care. 
 
This information should be consistent with the information contained in the QRD Form 
(See 5230.2)]  
 
If [Insert QIO name here] identifies quality of care concerns that represent a significant 
departure from the expected standard of health care and/or identifies patterns of care 
that may have significance beyond a single episode, a determination may be made that 
further intervention activities are required. If this occurs, you will be notified in writing 
and given the opportunity to discuss the concern(s) with [Insert QIO name here]. 
 
Non-confirmed concern(s): 
 
NOTE: The following is for instructional purposes ONLY. DO NOT INCLUDE IN 
THE LETTER. 
 
PREPARATION NOTE FOR QIO 
The summary must include: 
  
  The specific concerns identified by the beneficiary and any concerns identified by 
the QIO based on the initial intake (See 5110.1).  
  
  The standard of care associated with each concern and a statement of the 
analysis and facts the QIO determines are pertinent to its findings, including 
references to medical information and, if held, information obtained as a result of 
the opportunity for discussion with the involved practitioner or provider.  
 
This information should be consistent with the information contained in the QRD Form 
(See 5230.2)] 
 
This information will be entered into [the CMS database]. On an ongoing basis, we 
analyze patterns of care involving quality concerns that may have significance beyond a 
single episode. The QIO provides this information to CMS as requested. 
 
Please be advised that the Medicare Beneficiary has the right to request Reconsideration. 
If a request is received, this determination may or may not change as a result of the QIO 
reviewing this case again during the Reconsideration process. In the event that the 
Reconsideration does result in a change in the Final Determination, you will be notified 
in writing.] 
 
Right to Request Reconsideration 
  If you disagree with this Final Determination, you may also request Reconsideration by 
submitting your request within 3 calendar days from the receipt of this letter. Your 
request for Reconsideration may include additional information and/or documentation, 
including  
 
Your request for Reconsideration can be either written or oral using the contact 
information below: 
 
[Insert QIO Name] 
[Insert QIO Contact Person] 
[Insert QIO Address] 
[Insert QIO Contact Number] 
[Insert QIO Fax Number] 
 
 
Please be advised that if Reconsideration is requested, this determination may or may not 
change as a result of the QIO reviewing this case again during the Reconsideration 
process. In the event that the Reconsideration does result in a change in the Final 
Determination, you will be notified in writing. 
 
The information in this notice is confidential and may be disclosed only in accordance 
with Federal regulations found in 42 CFR Part 480. 
Sincerely, 
 
Medical Director (or designated physician) 
[Insert title here] 
 
    Appendix 5-4.2  Beneficiary Quality of Care Complaint: Final 
Determination Letter to Beneficiary/ Beneficiary Representative 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
QIO LETTERHEAD 
 
Date of Notice  
Name of Addressee  
Address  
City, State, and Zip Code  
 
Beneficiary Name  
Medicare # (HICN)  
Practitioner/Provider Name  
Practitioner/Provider Number (CCN/NPI/UPN)  
Date(s) of Service 
 
Dear [insert name of Beneficiary or Representative] 
 
Thank you for your patience while we completed a full and comprehensive review of the 
quality of care concerns you raised [(If available, include copy of the quality of care 
concern form signed by the complainant]). Our Final Determination is based on a 
physicians careful review of: 
 
  Information you provided in filing the complaint 
 
  Medical information 
 
  Any information provided during the practitioner/providers opportunity for 
discussion. 
 
Summary of Review 
The following is the summary of our review. 
 
Confirmed and/or identified concern(s): 
 
NOTE: The following is for instructional purposes ONLY. DO NOT INCLUDE IN 
THE LETTER. 
 
PREPARATION NOTE FOR THE QIO 
The summary must include: 
 
  The specific concerns identified by the beneficiary and any concerns identified by 
the QIO based on the initial review (See 5110.1), 
  
  The standard of care associated with each concern, and    
  A summary of the analysis and facts the QIO determines are pertinent to its 
findings, including references to medical information and, if held, information 
obtained as a result of the opportunity for discussion with the involved 
practitioner or provider.  
 
The information should be consistent with the information contained in the QRD Form 
(See 5230.2)] 
 
Non-confirmed concern(s): 
NOTE: The following is for instructional purposes ONLY. DO NOT INCLUDE IN 
LETTER 
 
PREPARATION NOTE FOR THE QIO 
The summary must include: 
 
  The specific concerns identified by the beneficiary and any concerns identified by 
the QIO based on the Scope of Review (See 5110.1), 
 
  The standard of care associated with each concern, and 
 
  A summary of the analysis and facts the QIO determines are pertinent to its 
findings, including references to medical information, and including any 
information obtained as a result of the opportunity for discussion with the 
involved practitioner or provider.  
 
The information should be consistent with the information contained in the QRD Form 
(See 5230.2]. 
 
Your Right to Request a Reconsideration 
 
If you disagree with this determination, you may request Reconsideration by submitting 
your request within three (3) calendar days from the receipt of this letter. You may 
provide additional information and/or documentation, including medical information that 
will help with your request.  
 
Your request for Reconsideration can be either written or oral using the contact 
information below:  
  
[Insert QIO Name] 
[Insert QIO Contact Person] 
[Insert QIO Address] 
[Insert QIO Contact Number] 
[Insert QIO Fax Number] 
  NOTE: The determination in this letter may or may not change as a result of us 
reviewing this case again during the Reconsideration process. If it does, you will be 
notified in writing. 
 
The information in this notice is confidential and may be disclosed only in accordance 
with Federal regulations found in 42 CFR Part 480. 
 
 
Sincerely, 
 
 
Medical Director (or designated physician) 
[Insert title here] 
 
Appendix 5-5  Re-Review Determination Letter to 
Providers/Practitioners with Request to Disclose (For Beneficiary 
Complaints) 
(Rev. 17, Issued: -04-06-12, Effective: 05-07-12 Implementation: 05-07-12) 
 
QIO LETTERHEAD 
 
Date of Notice 
Name of Addressee 
Address 
City, State, and Zip Code 
 
Patient Name (when the patient has consented to disclosure) 
Health Insurance Claim (HIC) Number 
Practitioner/Provider Name (if this applies) 
Practitioner/Provider Number (if this applies) 
Date of Admission/Service 
Medical Record Number (if known) 
 
Dear: 
 
Previously, you received our Final Initial Determination letter, dated _________, about 
care you provided [to the beneficiary listed above. (Only include where the beneficiary 
has consented to the disclosure of his or her name.)]  We received your request for a Re-
Review, and have completed the Re-review.  This letter conveys the final results of our 
Re-Review and constitutes our FINAL decision on this matter.  The Re-review was 
completed by a Peer Reviewer who was not involved in the original Determination. 
 
Summary of Re-Review Findings 
 
Based on a thorough review of all information, the Re-Review Peer Reviewer has 
determined   PREPARATION NOTE FOR QIO 
The summary must include: 
  the specific concerns identified by the beneficiary and any concerns 
identified by the QIO based on the Scope of Review (See 5110.1),   
  the standard of care associated with each concern, and 
  a statement of the analysis and findings regarding each concern, including 
the analysis of any additional information submitted as part of the Re-
Review request and/or changes between the Initial Determination and Re-
Review.   
This information should be consistent with the information contained in the 
Quality Review Decision (QRD) Form. 
 
Consent to Release Findings to the Beneficiary 
We will inform beneficiaries about whether the care they were provided did or did not 
meet professionally recognized standards of care. In order for us to release more specific 
findings to the beneficiary, we must obtain consent from practitioner(s) involved in the 
care of the patient.  The findings we propose releasing to the beneficiary are attached to 
(or included in) this letter.  If you are a practitioner, please review the language and 
indicate consent to our disclosing the information within thirty calendar days from the 
date of this letter.  Please note that we will treat your failure to indicate your consent as 
your declining to consent, and the beneficiary will not be informed of these specific 
findings.  In order to facilitate release of these specific findings to the beneficiary, please 
contact the QIO representative named below to discuss the attached findings:  
 
Name of QIO Contact Person 
Address 
Telephone Number 
 
PREPARATION NOTE FOR QIO:  
  If the notice is addressed to the provider or practitioner group, insert the 
name of the practitioner(s) also notified and the following language.  
  The following practitioner, [insert name(s)] also has been notified of our 
Re-Review decision and contacted to obtain his/her consent to disclose the 
specific findings to the beneficiary. 
  If the notice is addressed to the practitioner, insert the name of the provider if 
applicable.  Do not specify other practitioners you may be notifying. 
  If the notice is addressed to the provider and will also be sent to a physician 
practice or some other practitioner, insert into the providers notice the 
name(s) of the practitioner(s) also notified and include the statement:   
 The following practitioner(s), [insert name(s)] also has been notified of 
o
our Final Initial Determination and contacted to obtain his/her consent to 
disclose the specific findings to the beneficiary. 
  If the notice is addressed to a practitioner or physician practice, insert the 
name of the provider if applicable.  Do not specify other physicians or 
practitioners you may be notifying. 
  Again, this constitutes the QIOs FINAL decision on this matter, and no further appeal 
rights are available.  The information in this notice is confidential and may be re-
disclosed only in accordance with Federal regulations found in 42 CFR Part 480. 
 
Sincerely, 
 
 
 
Medical Director (or designated physician) 
(Include title) 
 
 
Appendix 5-5.1  Beneficiary Quality of Care Complaint: Reconsideration 
Determination Letter to Practitioners and Providers 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
QIO LETTERHEAD 
FINAL NOTIFICATION 
Date of Notice 
QIO Liaison for Providers or Practitioners Name 
Name of Addressee 
Address 
City, State, and Zip Code 
 
Beneficiary Name  
Medicare # (HICN)  
Practitioner/Provider Name  
Practitioner/Provider Number (CCN/NPI/UPN)  
Date(s) of Service 
 
[NOTE: The following is for instructional purposes ONLY. DO NOT INCLUDE IN 
THE LETTER. 
 
  If the notice is addressed to the provider or practitioner group, insert the name of 
the practitioner(s) also notified. 
 
  If the notice is addressed to the practitioner, insert the name of the provider if 
applicable. Do not specify other practitioners you may be notifying. 
 
  If the notice is addressed to the provider and will also be sent to a physician 
practice or some other practitioner, insert into the providers notice the name(s) 
of the practitioner(s) also notified.  
    If the notice is addressed to a practitioner or physician practice, insert the name 
of the provider if applicable. Do not specify other physicians or practitioners you 
may be notifying.] 
 
Dear [Insert name of Practitioner or Provider here]: 
 
You previously received our letter, dated [insert date here], about care you provided to 
[insert beneficiary name here]. We received your request for Reconsideration and have 
completed the Peer Review. Following CMS policy, a Peer Reviewer who was not 
involved in the prior determination of the initial review completed the Reconsideration 
review. This letter conveys the results of your Reconsideration review and constitutes our 
final decision on this matter.  
 
Summary of Reconsideration Review 
Based on a review of the information received, the following is the summary of our 
Reconsideration review. 
 
Confirmed and/or identified concern(s) [should be the same as Final Determination 
letter]:  
[NOTE: The following is for instructional purposes ONLY. DO NOT INCLUDE IN 
THE LETTER. 
 
PREPARATION NOTE FOR THE QIO 
The summary of confirmed concerns must include: 
 
  The specific concerns identified by the beneficiary and any concerns identified by 
the QIO based on the Scope of Review (See 5110.1),  
  
  The standard of care associated with each concern, and 
 
  A summary of the analysis and facts the QIO determines are pertinent to its 
findings, including references to medical information and, if held, information 
obtained as a result of the opportunity for discussion with the involved 
practitioner or provider.  
 
The information should be consistent with the information contained in the QRD Form 
(See 5230.2]. 
 
 
Non-confirmed concern(s): NOTE: The following is for instructional purposes ONLY. 
DO NOT INCLUDE IN LETTER 
 
PREPARATION NOTE FOR THE QIO 
The summary must include: 
    The specific concerns identified by the beneficiary and any concerns 
identified by the QIO based on the Scope of Review (See 5110.1),  
  
  The standard of care associated with each concern, and  
 
  A summary of the analysis and facts the QIO determines are pertinent to 
its findings, including references to medical information and, if held, 
information obtained as a result of the opportunity for discussion with the 
involved practitioner or provider.  
 
The information should be consistent with the information contained in the QRD Form 
(See 5230.2)] 
 
This information will be entered into [the CMS database]. On an ongoing basis, we 
analyze patterns of care involving quality concerns that may have significance beyond a 
single episode. The QIO provides this information to CMS upon request. 
 
Again, this constitutes the QIOs final decision on this matter, and no further appeal 
rights are available. The beneficiary or patient representative will be notified of the 
results of the QIO Quality of Care Review. The information in this notice is confidential 
and may be disclosed only in accordance with Federal regulations found in 42 CFR Part 
480. 
 
Sincerely, 
 
 
 
Medical Director (or designated physician) 
[Insert title here] 
 
 
Appendix 5-5.2  Beneficiary Quality of Care Complaint: Reconsideration 
Determination Letter to Beneficiary/Beneficiary Representative 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
NOTE: This letter template applies to beneficiary complaints received after July 31, 
2014. 
 
QIO LETTERHEAD 
 
Date of Notice 
Name of Addressee 
Address 
City, State, and Zip Code 
 
Beneficiary Name   Medicare # (HICN)  
Practitioner/Provider Name  
Practitioner/Provider Number (CCN/NPI/UPN)  
Date(s) of Service 
 
Dear [insert name of Beneficiary or Representative here] 
 
We received your request for a different reviewer to look at your quality of care concerns 
under the Reconsideration process. The Reconsideration review findings are below, and 
this is our final determination about the quality of the medical care you received.  
 
Summary of Review 
The following is the summary of our Reconsideration Peer Review.  
 
Confirmed and/or identified concern(s) [should be the same as Final Determination 
letter]: 
 
[NOTE: The following is for instructional purposes ONLY. DO NOT INCLUDE IN 
THE LETTER. 
 
PREPARATION NOTE FOR THE QIO 
The summary must include: 
 
  The specific concerns identified by the beneficiary and any concerns identified by 
the QIO based on the Scope of Review (See 5110.1),  
 
  The standard of care associated with each concern, and 
  
  A summary of the analysis and facts the QIO determines are pertinent to its 
findings, including references to medical information and, if held, information 
obtained as a result of the opportunity for discussion with the involved 
practitioner or provider.  
 
The information should be consistent with the information contained in the QRD Form 
(See 5230.2)] 
 
Non-confirmed concerns: 
NOTE: The following is for instructional purposes ONLY. DO NOT INCLUDE IN 
LETTER 
 
PREPARATION NOTE FOR THE QIO 
The summary must include: 
 
  The specific concerns identified by the beneficiary and any concerns 
identified by the QIO based on the Scope of Review (See 5110.1),    
  The standard of care associated with each concern, and  
 
  A summary of the analysis and facts the QIO determines are pertinent to 
its findings, including references to medical information and, if held, 
information obtained as a result of the opportunity for discussion with the 
involved practitioner or provider.  
 
The information should be consistent with the information contained in the QRD Form 
(See 5230.2)] 
 
This information will be entered into [the Centers for Medicare & Medicaid Services 
(CMS) database]. On an ongoing basis, we review quality of care services and concerns 
that may identify patterns of care that may have significance beyond a single episode. 
The QIO provides this information to CMS as requested to improve the overall quality of 
care for all Medicare beneficiaries.  
 
Again, this is the final decision on this matter, and no further appeal rights are available. 
In addition, the information in this notice is confidential and may be disclosed only in 
accordance with Federal regulations found in 42 CFR Part 480.  
 
Thank you for sharing your concerns with us. If you have any questions, please do not 
hesitate to contact us: 
 [Insert QIO Name] 
[Insert QIO Contact Person] 
[Insert QIO Address] 
[Insert QIO Contact Number] 
[Insert QIO Fax Number] 
 
Sincerely, 
 
 
Medical Director (or designated physician) 
[Insert title here]  Appendix 5-6  General Quality of Care Reviews - Initial Determination 
Letter with Right to Request Reconsideration to Practitioners and 
Providers 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
QIO LETTERHEAD 
INITIAL NOTIFICATION 
Date of Notice  
QIO Liaison for Provider or Practitioners Name 
 
Name of Addressee  
Address 
City, State, and Zip Code 
 
Beneficiary Name  
Medicare # (HICN)  
Practitioner/Provider Name  
Practitioner/Provider Number (CCN/NPI/UPN)  
Date(s) of Service 
 
 
Dear [Insert name of Practitioner or Provider here]: 
 
You are receiving this notification because [Insert QIO name here] identified a potential 
quality of care concern about care you provided to [Insert beneficiary name here].  
 
[Insert QIO name here] is the Quality Improvement Organization (QIO) authorized by 
the Centers for Medicare & Medicaid Services (CMS) to review Medicare cases in 
[Insert QIO area/region here] to determine if the health care services provided to 
Medicare beneficiaries meet professionally recognized standards of care, are medically 
necessary, and are delivered in the most appropriate setting. Our primary purpose is to 
identify areas where health care services can be improved and provide feedback to 
facilities and practitioners. This Peer Review is intended to be a collegial interaction 
with the goal of improving patient care. 
 
We have completed our review of the episode of care referenced above. A [Insert QIO 
name here] Peer Reviewer has carefully reviewed the medical information.  
 
Summary of Review 
 
Based on a review of the information received, the following is the summary of our 
review.  
 
Confirmed and/or identified concern(s): 
  [NOTE: The following is for instructional purposes ONLY. DO NOT INCLUDE IN 
THE LETTER 
 
PREPARATION NOTE FOR THE QIO: 
The review findings must include: 
 
  A statement for each quality of care concern that care did or did not meet the 
standard(s) of care,  
 
  The standard(s) identified by the QIO for each quality of care concerns, and 
 
  A specific statement conveying facts describing how the practitioner and/or 
provider did or did not meet specific criteria within the standard. 
 
Non-confirmed concern(s): 
 
NOTE: The following is for instructional purposes ONLY. DO NOT INCLUDE IN 
LETTER 
 
PREPARATION NOTE FOR QIO: 
The review findings must include:  
 
  A statement for each of the quality of care concerns that care did or did not meet 
the standard(s) of care,  
 
  The standard(s) identified by the QIO for each quality of care concerns, and  
 
  A statement for each quality of care concern that care did or did not meet the 
standard(s) of care. 
 
If you disagree with this quality of care concern(s) determination, you may request 
Reconsideration. Your request should include the reason for your dissatisfaction with our 
determination and any additional information you may wish to submit. Your request for 
Reconsideration can be written or oral and must be submitted within three (3) calendar 
days from receipt of this letter using the following contact information: 
[Insert QIO Name] 
[Insert QIO Contact Person] 
[Insert QIO Address] 
[Insert QIO Contact Number] 
[Insert QIO Fax Number] 
 
NOTE: If a request for Reconsideration is not submitted within the appropriate 
timeframe, this notification will be considered our Final Determination. 
 
This information will be entered into [the Centers for Medicare & Medicaid Services 
(CMS) database]. On an ongoing basis, we analyze patterns of care involving quality  concerns that may have significance beyond a single episode. The QIO provides this 
information to CMS as requested to improve the overall quality of care for all Medicare 
beneficiaries. 
 
The information in this notice is confidential and may be disclosed only in accordance 
with Federal regulations found in 42 CFR Part 480. Thank you for your participation in 
the improvement of the Medicare program.  
 
Sincerely, 
 
 
 
Medical Director (or designated physician) 
[Insert title here] 
  Appendix 5-7  General Quality of Care Reviews: Final Reconsideration 
Determination Letter to Practitioners and Providers 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
NOTE: Use this letter template if a request for reconsideration is submitted within the 
appropriate timeframe. 
QIO LETTERHEAD 
FINAL NOTIFICATION 
Date of Notice  
QIO Liaison for Provider or Practitioners Name 
 
Name of Addressee  
Address 
City, State, and Zip Code 
Beneficiary Name  
Medicare # (HICN)  
Practitioner/Provider Name  
Practitioner/Provider Number (CCN/NPI/UPN)  
Date(s) of Service 
 
Dear [insert name of Practitioner or Provider here]: 
 
You previously received our Initial Determination letter, dated [Insert date here], about 
the care you provided to [Insert beneficiary name here]. We received your request for 
Reconsideration, and have completed the Reconsideration Peer Review. A [Insert QIO 
name here] Peer Reviewer has carefully reviewed the medical information, and any 
additional information that was provided. This Peer Reviewer was not the same Peer 
Reviewer who initially reviewed this matter.  This letter conveys the results of your 
Reconsideration and constitutes our final decision on this matter.  
 
Summary of Review 
 
Based on a review of the information received, the following is the summary of our 
review.  
 
Confirmed and/or identified concern(s): 
 
NOTE: The following is for instructional purposes ONLY. DO NOT INCLUDE IN 
THE LETTER 
 
PREPARATION NOTE FOR THE QIO: 
The review findings must include: 
 
  A statement for each quality of care concern that care did or did not meet the 
standard(s) of care, 
    The standard(s) identified by the QIO for each quality of care concern, and  
  
  A specific summary conveying facts describing how the practitioner and/or 
provider did or did not meet specific criteria within the standard. 
 
Non-confirmed concern(s): 
 
NOTE: The following is for instructional purposes ONLY. DO NOT INCLUDE IN 
LETTER 
 
PREPARATION NOTE FOR QIO: 
The review findings must include:  
 
  A statement for each quality of care concern that care did or did not meet the 
standard(s) of care,  
 
  The standard(s) identified by the QIO for each quality of care concern, and 
 
  A specific summary conveying facts describing how the practitioner and/or 
provider did or did not meet specific criteria within the standard.] 
 
This information will be entered into [the Centers for Medicare & Medicaid Services 
(CMS) database]. On an ongoing basis, we analyze patterns of care involving quality 
concerns that may have significance beyond a single episode. The QIO provides this 
information to CMS as requested. 
 
The information in this notice is confidential and may be disclosed only in accordance 
with Federal regulations found in 42 CFR Part 480. Thank you for your participation in 
the improvement of the Medicare program. 
 
 
Sincerely, 
 
 
 
Medical Director (or designated physician) 
[Insert title here]  Appendix 5-8  REQUEST FOR QIO REVIEW FORM 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
 
TO:   QIO Name 
Address 
City, State, Zip 
 
I.  Requesting Agency/Organization and Contact Person 
Agency/Organization:           Phone #:        
Contact Person:             Email:       
II.  Patient Information 
Patient Name:           HIC #:          
Date of Birth:          Sex: Male  __  Female   
Facility Name:           
Provider Name:           Provider Phone #:        
Admit Date:              Discharge Date:          
III.  Referral 
Type of Referral (check one): Quality of Care:         Other:      
 
 
Reason for Review Request or Quality of Care Concern Identified (be specific): (Quality 
of Care e.g., over-prescribing drugs or prescribing the wrong drug, failing to diagnose a 
medical problem that is found later, misreading x-rays to identify a medical problem, 
failing to get back to a patient with medical results in a timely manner, failing to provide 
appropriate care after a surgical procedure)          
                         
                         
                         
                         
                         
                         
                     
Reviewers Signature         Date 
 
Do you need an update on case upon completion of QIOs review? (Check one):  
Yes       No      
 
                         
THIS SECTION FOR QIO USE ONLY 
Was a review conducted?    Yes      No      Review Results:                    
                       
                       
                       
                       
                       
                       
                       
                 
 
Additional Information:                  
                       
                       
                       
                       
                       
                       
                       
                 
 
  Appendix 5-9  Best Practices  
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
Beneficiary Complaint Review 
Review Type  Timing  Reference 
  Intake Stage   
QIO during initial intake  The date of service on which the  5045.2 
of information from the  care that gave rise to the 
beneficiary will accept the  complaint occurred is less than 
complaint when received in  three (3) years from the date of 
writing   the phone call to the QIO. If 
service was more than 3 years 
before the date of the call or 
complaint to the QIO, the QIO 
cannot review the matter under 
42 CFR 476.120(a). 
QIO intakes initial  One (1) business day of initial  5030.2 
information from the  contact 
beneficiary 
QIO responds to messages  Next business day  5030.2 
received after hours  
QIO mails Complaint form   One (1) business day of Intake  5040 
Failure to return form,  Fifteen (15) calendar days from  5040.2 
QIO contacts beneficiary  mailing 
Failure to return form, the  Thirty-one (31) calendar days  5040.2 
QIO has insufficient  from mailing 
information to proceed 
with a review and closes 
complaint. Review 
processed as Quality of 
Care Review if serious or 
urgent concern present. 
QIO uploads form into  One (1) business day of receipt  5040.3 
CMS-designated case 
review system for Review 
Analyst review 
Review Analyst contacts  One (1) business day of receipt  5040.3 
beneficiary, orally 
acknowledges receipt of 
complaint 
  Immediate Advocacy    Review Type  Timing  Reference 
Look back period for  Six (6) months from the date of  5035.2 
Immediate Advocacy  service which care occurred 
involving the complaint 
Time frame for QIO to  Eight (8) hours to two (2) days is  5035.4 
make a final decision for  average, but no more than ten 
an Immediate Advocacy  calendar days from the time the 
Immediate Advocacy began 
Review Analyst updates  One (1) business day after  5035.5 
CMS-designated system  Immediate Advocacy is 
about result of Immediate  completed 
Advocacy 
  Requesting Medical Information   
Medical information  One (1) business day from  5045.2 
requested  receipt of written complaint  
Due date of all medical  Fourteen (14) calendar days  5045.2 
information  from date of request or sooner if 
complaint involves a gross and 
flagrant of substantial quality of 
care issue. 
Medical information not  Contact the COR immediately  5045.2 
received by deadline  who contacts provider by the 
calendar day 14 or earlier  next business day 
if concern was potentially 
gross and flagrant or a 
substantial quality of care 
issue and QIO determines 
that circumstances warrant 
earlier receipt of 
information. 
Medical information not  Contact COR and notify the  5045.3 
received by calendar day  Beneficiary on the next business 
30   day  
Medical information  Immediately date-stamp and  5045.4 
received  upload into CMS-designated 
case review system within one 
business day 
Information missing/  Contact provider/practitioner   5045.4 
illegible in medical  and provide five (5) calendar 
information   days to submit corrections 
  Quality of Care Review Stage      Review Type  Timing  Reference 
Review Analyst completes  Within a reasonable amount of  5050.2 
Quality Review Decision  time to ensure the ten calendar 
(QRD) Form and forwards  day timeframe is met 
package to  Initial 
Determination Peer 
Reviewer(s) (IDPR) 
IDPR completes review  Within the 10 calendar day  5050.2 
and returns package to  timeframe from receipt of the 
Review Analyst and  medical record 
reviews IDPR decision 
  Opportunity for Discussion Stage   
Review Analyst offers  One (1) business day after  5055.1 
opportunity for discussion  reviewing the IDPR 
determination  
Response to opportunity  Seven (7) calendar days from  5055.1 
for discussion  initial offer 
Extension of response time  Additional seven (7) calendar  5055.1 
for opportunity for  days in rare circumstances 
discussion 
Review Analyst forwards to  One (1) business day from  5055.4 
IDPR information received  receipt of oral/written response 
during opportunity for 
discussion 
IDPR considers  Three (3) business days  5055.4 
information received and 
makes Final Determination 
No response to offer of  Seven (7) calendar days, then  5055.6 
opportunity for discussion  Interim Initial Determination 
becomes Final Determination 
Review Analyst forwards  Three (3) business days of receipt  5055.6 
Final Initial Determination  of all of the QRD Form or one 
Letter   business day of expiration of 
opportunity for discussion if no 
response received 
Practitioner/provider  Three (3) calendar days from  5060 
requests a Reconsideration  receipt of the Final 
Determination Letter 
IDPR destroys copies of all  Thirty (30) calendar days  5055.8 
materials  
  Beneficiary Complaint Reconsideration Procedure    Review Type  Timing  Reference 
Beneficiary must inform  No later than three (3) calendar  5060 
QIO of his/her request for  days following the initial 
a Reconsideration in  notification of the QIOs 
writing or by phone  determination 
Review Analyst forwards  Within one (1) business day of  5060 
Beneficiary Complaint  receipt of request 
folder to Reconsideration 
Peer Reviewer  
RPR completes the  Within five (5) calendar days  5060.1 
Reconsideration review,  after receiving any medical or 
returns folder, and the  other records needed for 
beneficiary and provider  reconsideration  
are notified of the decision.    
Review Analyst mails Final  Within five (5) calendar days of  5060.4 
Decision to beneficiary  request or if later within 5 
calendar days of receipt of 
medical information  Appendix 5-10  General Quality of Care - Best Practices 
(Rev. 28, Issued: 10-21-16, Effective: 10-21-16, Implementation: 10-21-16) 
 
General Quality of Care Review 
Review Type  Timing  Reference 
  Intake Stage   
QIO intake person forwards folder  One (1) business day of receipt of  5110 
to Review Analyst  referral/identification of concern 
  Requesting Medical Information   
Medical information requested  One (1) business day from  5110.2 
receipt/identification of concern  
Due date of medical information  Fourteen (14) calendar days from  5110.2 
date of request or sooner if 
complaint involves a gross and 
flagrant of substantial quality of 
care issue. 
Medical information not received  Contact COR immediately  5110.2 
by deadline calendar day 14 or 
earlier if concern was potentially 
gross and flagrant or a substantial 
quality of care issue and QIO 
determines that circumstances 
warrant earlier production of 
medical records) 
Medical information not received  COR calls practitioner/provider  5110.2 
by the next business day following  the next business day 
deadline 
Medical information not received  15 calendar days from date of  5110.2 
from provider, then initiate claim  request or sooner if complaint 
denial  involves a gross and flagrant of 
substantial quality of care issue. 
QIO receives medical information   Immediately date-stamp and  5110.4 
upload into CMS-designated case 
review system within one business 
day 
Information missing/illegible in  QIO contacts  5110.4 
medical information   provider/practitioner and provides 
five (5) calendar days to submit 
corrections 
  Quality of Care Review Stage    Review Type  Timing  Reference 
Review Analyst completes QRD  Within a reasonable amount of  5115.1 
Form and forwards package to  time to ensure the 10-calendar-
Initial Determination Peer  day time frame is met 
Reviewer (IDPR) 
IDPR completes review, returns  Ten (10) calendar days from  5115.2 
package to the Review Analyst, and  receipt of package, including all 
notifies practitioner/provider of  medical information 
Initial Determination Decision 
 IDPR destroys copies of all  Thirty (30) calendar days after  5115.5 
materials   Final Initial Determination 
  Reconsideration Stage   
Practitioner/provider must file a  Three (3) calendar days following  5115.5 
written or oral request for a  the receipt of the QIO Initial 
Reconsideration  Determination  
Review Analyst forwards  Within one (1) business day of  5115.5 
Beneficiary Complaint folder to the  receipt of request 
Reconsideration Peer Reviewer 
Review Analyst  prepares and mails  Within five (5) calendar days after  5120.1 
Final Decision Letter  receipt of request for a 
reconsideration, or 5 calendar 
days after receiving all medical 
information  
  Transmittals Issued for this Chapter 
 
Rev #  Issue Date  Subject  Impl Date  CR# 
R28QIO  10/21/2016  QIO Manual Chapter 5  Quality of Care  10/21/2016 N/A 
Review 
R17QIO  04/06/2012  QIO Manual Chapter 5  Quality of Care  05/07/2012 N/A 
Review 
R09QIO  08/29/2003  Change in Terminology to CMS and QIO  N/A  N/A 
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