What Low Appeal Participation Reveals About Prior Authorization Decisions
An HHS Office of Inspector General report examining June 2024 Medicare Advantage prior authorization decisions for skilled nursing facility admissions across the 19 largest MAO parent companies found that organizations overturned 95% of appealed denials while only 18% of denied requests were appealed. The report concluded that this “raises concerns about denials that were not appealed.” Considered together, those findings suggest that appeal outcomes may describe only a small portion of how prior authorization decisions function in practice.
Appeal Outcomes Are Only Part of the Picture
A 95% appeal overturn rate immediately draws attention because it shows that many denied requests receive a different outcome after additional review. The OIG findings become more informative once appeal participation is considered alongside that figure. With only 18% of denied requests entering the appeals process, most initial denials did not proceed to appeal.
Appeal outcomes reflect the requests that continued through the administrative process after a denial. Appeal participation establishes how frequently that additional review occurred and how much of the denied population is represented in the overturn rate.
The result is a broader concern than whether appeals are successful. When most denials remain outside the appeals process, attention begins to shift toward the decisions that did not proceed to appeal.
Variation Begins Before an Appeal Is Filed
Once attention moves to the initial determination, consistency becomes an operational issue. The OIG found meaningful differences among Medicare Advantage organizations, including variation in denial rates and differences associated with delegated review arrangements.
Organizations using naviHealth for skilled nursing facility prior authorization denied requests more frequently than organizations conducting reviews internally. NaviHealth processed approximately half of the requests examined by the OIG, and MAOs overturned 97% of appealed denials originally issued by naviHealth. OIG consequently recommended that CMS assess the variation and determine whether contractors are receiving appropriate training, guidance, and oversight from MAOs.
These findings show how review structure may shape prior authorization outcomes before an appeal occurs. Internal review practices, delegated vendors, staff training, and organizational oversight can each affect how consistently the same type of request is evaluated at the first stage of the process.
Why the Initial Determination Matters Most
Appeals provide an opportunity to correct a denial, but relatively few requests reach that stage. For most denied skilled nursing facility admissions examined by the OIG, the initial denial was not appealed.
That places considerable weight on the first review. Consistency depends on how criteria are applied, how documentation is evaluated, how delegated reviewers are managed, and whether quality controls identify patterns before individual patients must rely on an appeal.
Denial rates and overturn rates remain useful measures, but the administrative process begins earlier. When most denials are not appealed, the quality of the initial determination becomes one of the clearest indicators of how prior authorization is functioning in practice.
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