Is It Really an Administrative Denial?
What's the Next Step?
What's the Administrative Reason?
Tell the Story
Don't Make These Mistakes
100

The Member was not eligible on the PAR receipt date.

Everything else in the request is complete.

Is this an Administrative Denial?

Yes.

Member eligibility on the PAR receipt date is an administrative requirement.

No amount of supporting documentation can overcome an unmet administrative requirement.

Next Step: Issue the appropriate Administrative Denial and clearly document the eligibility finding.

100

Member not eligible.

Administrative Denial.

100

A provider submits a Housing Transition Supports request.

You verify: Required documentation is complete, Requested service is within HSS scope, Housing Support Plan supports the request, and No active RFI.

During your review, you discover the Member's Medicaid coverage ended before the PAR was received.

What is the administrative reason this request cannot move forward?

Member was not eligible on the PAR receipt date.

Don't simply say, "The Member isn't eligible."

Identify which administrative requirement wasn't met and tie it to the evidence.

Next Step: Document the eligibility finding, complete the Administrative Denial pathway, and issue the appropriate notice.

100

Review note: Denied.

Good enough?

No.

Document what was requested, what administrative requirement wasn't met, and why.

100

Deny because one document is missing.

Not necessarily.

Consider whether an RFI is appropriate first.

200

The Housing Support Plan is missing.

Administrative Denial?

This is a missing-information issue.

The next step is an RFI if allowed under the workflow.

Don't deny when the provider still has an opportunity to provide required information.

200

Required documentation missing.

RFI.

200

The Member meets all HSS requirements.

The documentation is complete.

The Housing Support Plan supports the request.

During review you discover the provider submitting the PAR is not enrolled or approved to provide the requested HSS service.

What is the administrative reason?

The provider does not meet the administrative requirement to submit or provide the requested HSS service.

Administrative requirements apply to both the Member and the provider.

The denial is not because the Member doesn't qualify.

It is because the request cannot move forward under program requirements.

Next Step: Document the provider eligibility issue and complete the Administrative Denial process. Work on connecting Member to approved CBO.

200

Review note: Member ineligible.

What's missing?

The supporting evidence.

For example: "Member was not eligible on the PAR receipt date."

200

Deny because the documentation conflicts.

Not yet.

Clarify the conflict first.

300

A provider submits a PAR requesting payment for hotel lodging through Housing-Related Deposit.

Administrative Denial?

The requested service is outside HSS program scope.

Administrative Denials apply when the requested item or service cannot be covered under HSS.

300

Housing Support Plan and PAR conflict.

Clarify the conflict before determining the pathway.

300

The PAR requests Housing Transition Supports.

The Housing Support Plan clearly states the Member has been successfully housed for one year and only needs ongoing tenancy support.

Everything else is complete.

Is the administrative reason:

A. Wrong service requested

B. Outside HSS scope

C. Administrative Denial

None of the above.

This is not yet an Administrative Denial.

The documentation and requested service conflict.

The next step is to resolve the conflict according to the workflow before determining the correct pathway.

Next Step: Clarify the request (likely through RFI if appropriate under your SOP), then continue the review.

300

Review note: Outside scope.

What's missing?

Identify what was requested and explain why it falls outside HSS scope.

A denial should answer:

  • What was requested?
  • What requirement wasn't met?
  • What evidence supports that?
  • What notice was sent?
300

Deny because you're unsure.

Never.

Review, clarify, or escalate before making a determination.

400

The reviewer discovers another approved authorization for the same Member, same service, and same dates.

What should you consider?

Review the duplicate according to the SOP. If confirmed to be a duplicate that cannot move forward, the appropriate pathway may be an Administrative Denial.

Don't assume every second request is automatically denied. Verify the facts first.

400

The provider never responded to the RFI within the required timeframe.

Follow the SOP. If policy allows, the next step may be an Administrative Denial for failure to provide the requested information.

The denial is based on the unresolved administrative requirement, not because the reviewer assumed the answer.

400

While reviewing a Housing-Related Deposit request, you discover another authorization that:

  • Was approved last month
  • Covers the same Member
  • Covers the same deposit
  • Covers the same housing address

The provider submitted a second PAR because they forgot the first one had already been approved.

What is the administrative reason?

The request is a duplicate of an existing approved authorization.

Don't deny because "it looks like a duplicate."

Verify that it is a duplicate and document how you confirmed it.

Next Step: Follow duplicate request procedures and complete the appropriate Administrative Denial if the duplicate cannot move forward.

400

Your review note says: "Denied. Member not eligible."

What important information is missing?

The documentation should tell the complete story:

  • What service was requested?
  • What eligibility was reviewed?
  • What date was used?
  • What evidence showed the Member was not eligible?
  • Why couldn't the request move forward?
  • What notice was issued?

A denial should answer why, not just what.

400

Deny because the provider says they'll send it later.

Follow the workflow.

Do not approve or deny based on promises. Follow the RFI process and required timeframes.

500

Everything about the Member meets HSS requirements.

However, the provider is not eligible or approved to submit the request.

Can the request move forward?

No.

This is an administrative requirement.

Administrative requirements apply to providers as well as Members.

500

You're unsure whether the request meets administrative requirements.

Don't guess.

Pause, review the SOP, and escalate if required.

Good reviewers know when to stop.

500

The review is complete.

The documentation supports the requested service.

The Member is eligible.

The provider is eligible.

The reviewer notices the Member has already reached the program's allowable utilization limit for this benefit.

What is the administrative reason?

The allowable utilization or lifetime limit has already been met.

This is not a documentation issue.

It is an administrative program limitation.

Next Step: Document the utilization finding, identify the supporting evidence, and complete the Administrative Denial pathway or ask for an Exception in rare cases.

500

You processed an Administrative Denial three months ago.

Today:

  • The provider files an appeal.
  • You are on vacation.
  • Heather has to defend your determination.

She opens TruCare and reads only this: "Outside scope. Denied."

What information should Heather have been able to find in your documentation?


Your documentation should clearly explain:

  • What service or item was requested
  • Why it was outside HSS scope
  • What documents were reviewed
  • Which HSS requirement was not met
  • The evidence supporting that conclusion
  • Whether an RFI occurred, if applicable
  • What notice was issued
  • Why Administrative Denial was the correct pathway

Write every review as if someone else will have to defend it.

Because one day, they probably will.

500

A Housing Transition Supports request includes: Member eligible, Provider eligible, Correct service, Required documents, No RFI, and Service sequencing met.

However, the documentation clearly supports Housing Sustainment Services instead.

Administrative Denial?

Not yet.

The reviewer should resolve the documentation conflict before deciding the pathway.

One of the biggest reviewer mistakes is choosing a pathway before understanding the problem.

The right answer isn't always "approve" or "deny."

Sometimes the right answer is: "I don't have enough information to make a defensible decision yet."


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