Medicare Program Integrity Manual (Pub. 100-08), Ch. 12 § 12.4.3.1
Disputing a CERT Decision
12.4.3.1 – Disputing a CERT Decision
(Rev.13678; Issued: 03-12-26; Effective: 04-13-26; Implementation: 04-13-26)
A dispute may be filed in situations in which the MAC does not agree with the final
CERT review contractor decision on a claim. The MAC shall indicate the disputed claim
on the C3HUB via the feedback process in accordance with this section. Using the
appropriate field in the C3HUB, the MAC shall enter a detailed statement that explains
the rationale for filing the dispute. Once a MAC files a dispute on a claim, they should
not enter any feedback information on that claim since the claim will be removed from
feedback. The CERT review contractor will conduct a re- review of the disputed claim
and issue a new comment via C3HUB. If the MAC does not agree with the re-review
decision or new reviewer comment, the MAC has the option to escalate the dispute to
CMS via the C3HUB feedback entry. The MAC must provide a detailed rationale, via
the appropriate field in the C3HUB, as to why the claim remains in dispute. The CMS
dispute panel shall use Medicare coverage, coding, and billing rules in effect for the
billed date of service, the medical record, CERT review contractor comments, and MAC
comments/rationales to review the disputed claim. The CERT review contractor shall
notify the MAC of the CMS dispute panel final decision by way of the C3HUB. The
CMS dispute panel decision will appear as a new reviewer comment, and the claim will
appear in the new feedback posting.
Each MAC is allowed to file two disputed claims per month on or before the last day of
each month. Should the MAC choose not to submit two disputes in a given month, the
unused opportunity does not carry over.
When an appeal has been entered for a disputed claim, the MAC shall notify the CERT
review contractor immediately via the C3HUB Appeal Data Entry page to halt the
dispute process.