Quality Improvement Organization Manual (Pub. 100-10), Ch. 5 § 5065
Post-Review Advocacy
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 beneficiary’s and provider and/or practitioner’s 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.