Quality Improvement Organization Manual (Pub. 100-10), Ch. 5 § 5055.4
Beneficiary Complaint: Reviewing Response Submitted during
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 Reviewer’s 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 Reviewer’s 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
Reviewer‘s 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).