Section 10 Appeals and Grievances

Section 10 Appeals and Grievances Provider Complaints and Administrative Appeals 10-1 Requesting an Administrative Appeal 10-1 Level I Administrative Appeal Process 10-1 Level II Administrative Appeal Process 10-2 Appealing a Behavioral Health Service Denial 10-2 Provider Audit Appeals 10-2 General Claims Audit Appeal Requests 10-2 Member Inquiries, Complaints, and Grievances 10-2 Inquiries 10-2 Member Clinical Appeals 10-5 Expedited Clinical Appeals 10-5 Standard Clinical Appeals 10-8 Access to Appeal File by Member or Member Representative 10-14 Consumer Protection from Collections and Credit Reporting During Appeals 10-15 Behavioral Health Appeals 10-15 Dental Services Appeals 10-15 Complaints and Grievances 10-3 Behavioral Health Inquiries and Grievances 10-4 Dental Services Inquiries and Grievances for Commercial/QHP Members 10-4

Section 10 Appeals and Grievances Provider Complaints and Administrative Appeals Complaints regarding reimbursement, a specific claim rejection, or any other provider issue should be reported to NHP Provider Service. A complaint is a statement by a provider of dissatisfaction with NHP s actions or services. An appeal is a request by a provider to NHP to review an adverse action or denied claim with documentation supporting the request for reconsideration. NHP has established a comprehensive process to resolve provider complaints and appeals. Requesting an Administrative Appeal As described in Section 8, Billing Guidelines, providers can request a review and possible adjustment of a previously processed claim within 90 days of the Explanation of Payment (EOP) date on which the original claim was processed. If the provider is not satisfied with the decision, an appeal can be submitted to NHP s Provider Appeals department. Appeal requests must be submitted in writing within one of the following timeframes: 90 days from receipt of the NHP EOP 90 days from receipt of EOP from other insurance 90 days from the date of the claims adjustment letter. The appeal must include relevant information and documentation to support the request. Requests received beyond the 90-day appeal request filing limit will not be considered. Appeals may be sent to: Mail Neighborhood Health Plan Provider Appeals Dept 399 Revolution Drive Suite 940 Somerville, MA 02145 Fax 617-526-1902 Level I Administrative Appeal Process Level I appeals request reconsideration of a claim denial made by NHP. Level I appeals are reviewed by NHP s Provider Appeals department. Appeal reviews will be completed within 30 calendar days from the date NHP receives the appeal request with all supporting documentation. If approved, NHP will adjust the claim internally and notify the provider with NHP s EOP. (Please allow an additional two weeks for the appealed claims to appear as reprocessed on a future NHP EOP.) If denied, the provider will be notified in writing of the reason the appeal could not be approved and, when applicable, provided with instructions for filing a Level II appeal. If more information is needed to review the appeal the provider will be notified in writing and have an additional 60 days from the date of NHP s Level I response letter to submit the required information. If a provider has received an Administrative Denial letter from NHP s clinical department, with the denial reason indicating NHP did not receive the supporting documentation requested to make a medical necessity decision, and the service has not already taken place, providers can submit a new request through NHPNet with the supporting documentation. Providers do not need to submit an appeal. If the service has already taken place and a claim has been submitted, providers must submit an appeal, with supporting documentation. When submitting a provider appeal, please use the Request for Claim Review Form. www.nhp.org 10-1 2017-02 01

Level II Administrative Appeal Process Level II appeals request reconsideration of NHP s determination on a Level I appeal. Providers who disagree with the Level I appeal determination, and who can provide more information not previously submitted, may request a Level II appeal. Level II appeal requests must be made within 60 days of the Level I decision. The Level II appeal follows the same process as the Level I appeal, providing a determination within 30 calendar days from the date NHP receives the completed request. All Level II administrative appeals are reviewed by NHP s Appeals Committee. If approved, NHP will adjust the claim internally and notify the provider with NHP s EOP. If denied, the provider will be notified in writing of the reason the appeal could not be approved. There are no further levels of appeal once an appeal is denied at Level II. Appealing a Behavioral Health Service Denial Provider complaints and appeals for behavioral health services are handled by Beacon Health Options, NHP s Behavioral Health Partner. All behavioral health appeals should be submitted directly to Beacon Health Strategies. For more information, please refer to the Behavioral Health Manual or contact Beacon Health Options directly at 800-414-2820. Provider Audit Appeals General Claims Audit Appeal Requests If the provider disagrees with the reason for the adjustments, a letter of appeal or a completed NHP Provider Audit Appeal Form may be submitted to NHP s Appeals department within 90 days of the EOP along with comprehensive documentation to support the dispute of relevant charges. Appeals are processed within 30 calendar days from NHP s receipt of all required documentation. NHP will review the appeal and, when appropriate, consult with NHP clinicians or subject matter experts in the areas under consideration. To the extent that the provider fails to submit evidence of why the adjustment is being disputed, the provider will be notified of NHP s inability to thoroughly review the request. The provider can resubmit the appeal within the 90 days EOP window and the appeal s receipt date will be consistent with the date NHP received the additional documentation. The appeal determination will be final. If the determination is favorable to the provider, NHP will adjust the claims in question within 10 calendar days of the final determination notification. Member Inquiries, Complaints, and Grievances NHP is committed to ensuring member satisfaction and to the timely resolution of all inquiries as well as reports of dissatisfaction by a member or member s representative about any action or inaction by NHP or a health care provider. NHP provides processes for members that allow for the adequate and timely resolution of inquiries and grievances. Inquiries An inquiry is any oral or written question made by, or on behalf of, a member to NHP or its designees that is not the subject of an adverse determination or adverse action, and that does not express dissatisfaction about NHP or its operations, processes, services, benefits, or providers. Upon receipt of an inquiry, NHP s Customer Service Representative will document the matter and, to the extent possible, attempt to resolve it at the time of the inquiry. www.nhp.org 10-2 2017-02 01

Complaints and Grievances While grievances are typically reported by members, NHP will investigate all reported incidents when there are member care concerns. Possible subjects for grievances include, but are not limited to: Quality of Care A member s perception of poor provision of clinical care and/or treatment by medical staff; Access A member reports that he or she was unable to access needed care in accordance with wait-time standards or in a manner that met their perceived needs. Access is defined as the extent to which a member can obtain services (telephone access and scheduling an appointment) at the time they are needed. It can also include wait time to be seen once the member arrives for a visit or geographic access to a network provider; Service/Administration A member asserts that there was a problem in interpersonal relationships, such as rudeness on the part of a provider or NHP staff person and/or deficiencies in what would generally be considered good customer service; Billing and Financial A member s dispute of responsibility for rendered services, cost-sharing amounts or other financial obligations; Provider s Facility A member asserts the provider s facility was inadequate, including but not limited to cleanliness of waiting room, restrooms and overall physical access to the premises; Privacy Violation A member reports that his or her protected health information (PHI) was released, misdirected or violated by NHP or a provider; Member Rights A member reports that his or her member rights were violated by NHP or a provider. This can include a member s allegation that NHP is not providing behavioral health services in the same way that physical health services are provided, as required by Mental Health Parity Laws. Members may designate a representative to act on their behalf and such representative is granted all the rights of a member with respect to the grievance process, unless limited in writing by the member, law or judicial order. The member must complete and return a signed and dated Designation of Appeal or Grievance Representative Form prior to the deadline for resolving the grievance. If the signed form is not returned, communication can only take place with the member. NHP ensures that any parties involved in the resolution of inquiries, grievances, and any subsequent corrective actions have the necessary knowledge, skills, training, credentials and authority to make and to implement sound decisions and that they have not been involved in any previous level of review or decision-making. Members or their representatives are provided with a reasonable opportunity to present evidence and allegations of fact or law, in person as well as in writing. A member may file a complaint or grievance by telephone, fax, letter or in person. NHP Customer Service Representatives provide reasonable assistance to the member, including, but not limited to, providing full interpreter services, toll-free numbers with TTY/ TTD, explaining the grievance or appeal process and assisting with the completion of any forms. Upon receipt of a grievance, a Customer Service Representative logs the grievance and refers the matter to the Appeal and Grievance Coordinator who will send the member or member s representative an acknowledgement letter within one business day of receiving the grievance. If the grievance was conveyed verbally, the notification will include a reduction of the oral grievance to writing. The letter instructs the member or member s representative to sign and return a copy of the grievance acknowledgement letter to NHP prior to the deadline for resolving the grievance. However, the investigation of a member s grievance is not postponed pending return of a signed letter from the member or member s representative. The member s signature acknowledges that NHP has stated the grievance correctly. The Appeal and Grievance Coordinator determines the appropriate channel for processing the grievance. An NHP health care professional with the appropriate clinical expertise in treating the medical condition, performing the procedure or www.nhp.org 10-3 2017-02 01

providing treatment that is the subject of a grievance will make an initial assessment as to the clinical urgency of the situation and establish a resolution time frame accordingly if the grievance involves: The denial of a member or member s representative s request that an internal appeal be expedited Any clinical issue The NHP Appeal Committee will resolve a grievance if the subject of the grievance involves: The denial of payment for services received because of failure to follow authorization/referral procedures The denial of a member or member representative s request for an internal appeal because the request was not made in a timely fashion The denial of coverage for non-covered services The denial of coverage for services with benefit limitations Reduction in NHP Provider payment due to copayments, deductibles or coinsurance When the subject matter involves the act or omission on the part of an NHP employee, resolution is made by the employee s department, unless circumstances warrant as determined by the Appeals and Grievance Manager, that resolution should be made external to the employee s department. For grievances involving non-clinically related actions or omissions of a provider, the Grievance Coordinator requests assistance from the provider to investigate the grievance. Network providers adherence to the grievance process is monitored regularly to identify training and other interventions. For complaints concerning a provider, the nature of the complaint determines whether the matter is addressed directly with the clinician or with the site administrator. In either case, the provider is contacted to discuss the matter and asked for a written response stating the facts, including supporting documentation when appropriate. To allow timely completion of the review of all relevant information within the specified time frame, a response from the provider is expected within five business days unless otherwise agreed upon. The response must address all identified concerns and include corrective actions for each when applicable. Upon receipt of the provider s response and review of all relevant information, a written response is sent to the member containing the substance of the complaint, the findings and actions taken in response, taking into consideration the confidentiality rights of all parties. Minimally, the resolution will acknowledge receipt of the grievance and that it has been investigated. Grievances are researched and resolved as expeditiously as warranted, but no later than 30 calendar days from the verbal or written notice of the grievance. If the grievance resolution results in an adverse action, the response letter will advise the member of his or her right to appeal the decision. Behavioral Health Inquiries and Grievances Management for all behavioral health related inquiries and grievances is delegated to NHP s Behavioral Health Partner, Beacon Health Options. For more information, please see the Behavioral Health Provider Manual or contact Beacon directly at 800-414-2820. Dental Services Inquiries and Grievances for Commercial/QHP Members NHP delegates the grievance process for routine dental services for certain Commercial/QHP members to Delta Dental. Please verify the member s dental coverage with NHP s Customer Service Department. www.nhp.org 10-4 2017-02 01

Member Clinical Appeals Expedited Clinical Appeals MassHealth Level I Expedited Appeal (Level II = n/a) Expedited External Review Commercial/QHP Level I Expedited Appeal (Level II = n/a) Expedited External Review A member, member representative, or provider may request an expedited internal appeal when the member s life, health, or ability to attain, maintain, or regain maximum function would be seriously jeopardized by waiting 30 calendar days for a standard appeal resolution. Punitive action will not be taken against a provider who requests an expedited appeal on behalf of a member. An expedited appeal must be filed within 30 calendar days of NHP s decision to deny, terminate, modify, or suspend a requested health care service. The expedited internal appeal process is limited to one level. If the member (or representative) is dissatisfied with the decision, s/he may appeal the decision to the Office of Medicaid Board of Hearings (BOH) within 20 days of an expedited appeal. If the member (or representative) submits the appeal to the BOH within 21 to 30 days, it will be treated as a standard appeal. NHP will provide an expedited appeal process if it is believed that the member s health, life, or ability to regain maximum function may be put at risk by waiting 30 calendar days for a standard appeal decision. NHP will grant a request for an expedited appeal, unless the request is not related to the member s health condition. Members have the right to apply for an expedited external review at the same time a request for internal expedited review is requested. (See Commercial Expedited External Review section on how to submit an external review.) Members or their representatives can file an expedited external appeal at the same time that they file an internal expedited appeal or if they are dissatisfied with the expedited internal appeal decision. A request must be made to the Department of Health (DPH) Office of Patient Protection (OPP) within four months after the expedited internal appeal decision, but within two days if they wish to receive continuing services without liability. www.nhp.org 10-5 2017-02 01

Expedited Clinical Appeals (continued) MassHealth Commercial Level I Expedited Appeal (Level II = n/a) Expedited External Review Level I Expedited Appeal (Level II = n/a) Expedited External Review NHP will continue to authorize disputed services during the formal appeal process if those services had initially been authorized by NHP, unless the member indicates that s/ he does not want to continue receiving services, as long as the appeal request is submitted within 10 days of the adverse action. All requests by a provider for an expedited internal appeal will be granted unless NHP determines that the provider s request is unrelated to the member s health condition. In order to file an appeal on behalf of a member, the provider must obtain and provide NHP with written authorization from the member, designating the provider as the appeal representative. The Designation of Appeal Representative Form should be used for this purpose. While NHP will not postpone the appeal pending receipt of the form, it must be provided within a reasonable time period. If an expedited appeal request is not granted, the provider will receive prompt oral notice of the decision and written notification (dismissal of expedited appeal request) within two calendar days. In order to continue receiving ongoing services during a BOH expedited appeal, the Appeal must be requested within 10 calendar days of NHP s initial appeal decision to uphold the decision to deny, terminate, modify, or suspend a requested health care service. If the BOH determines that the member submitted the request for a BOH appeal in a timely manner, and the appeal involves the reduction, suspension, or terminations of a previously authorized service, NHP will authorize continuing services until one of the following occurs: - The member withdraws the BOH appeal; or - The BOH issues an adverse decision to the member s appeal request. NHP will continue to authorize disputed services during the formal appeal process if those services had initially been authorized by NHP, unless the member indicates that s/ he does not want to continue receiving services. NHP will provide an expedited appeal process under certain circumstances: When an appeal is submitted by or on behalf of a member who is inpatient in a hospital, resolution will be provided prior to the member s discharge from the hospital. When the treating provider certifies that the requested service or equipment is medically necessary and that there is a substantial and immediate risk of serious harm should the service or equipment not be provided pending the outcome of the normal appeal process, resolution will be made within 48 hours. When an expedited appeal is submitted by or on behalf of a member with a terminal illness, resolution will be provided within 72 hours and a written response within five business days from the receipt of the appeal. An application fee of $25.00, payable to the OPP, must accompany the request. The application fee may be waived if the OPP determines that payment of the fee would result in an extreme financial hardship for the member. Members or their representative should also submit a copy of NHP s final adverse determination letter along with the request. OPP will complete the expedited appeal within 72 hours of receipt. www.nhp.org 10-6 2017-02 01

Expedited Clinical Appeals (continued) MassHealth Commercial Level I Expedited Appeal (Level II = n/a) Expedited External Review Level I Expedited Appeal (Level II = n/a) Expedited External Review The appeal will be processed in accordance with the standard internal appeal time frames and the member (or representative) will be informed of their right to grieve, or complain, regarding the decision not to expedite the time frame. If approved as an expedited appeal after clinical review, a decision will be made within 72 hours of receipt. The time frame for making expedited internal appeal resolutions may be extended for up to 14 calendar days if the member (or representative) requests the extension. For any extension not requested by the member (or representative), the Appeal and Grievance Coordinator will send the member (or representative) a written Notice of Internal Appeal Extension Letter that will inform the member (or representative) of his or her right to grieve, or complain, regarding NHP s decision to extend the time frame for responding to the appeal. If the appeal for a member with a terminal illness is upheld, the member or representative may request a conference with a NHP medical director. The conference should be scheduled within 10 calendar days of the notification of the determination, or within 5 calendar days if the treating provider has consulted with NHP s Chief Medical Officer or Medical Director and it has been determined that the conference should be at an earlier date. Decisions on expedited appeals will be made within 72hours of receipt. The expedited internal appeal process is limited to one level. If the member (or representative) is dissatisfied with the decision, he or she may appeal the decision to the Office of Medicaid Board of Hearings (BOH). www.nhp.org 10-7 2017-02 01

Standard Clinical Appeals MassHealth Level I Standard Appeals Level II Standard Appeals Standard External Reviews A treating provider may file a clinical appeal on behalf of a member for any decision made by NHP to deny, terminate, modify, or suspend a requested health care benefit based on failure to meet medical necessity, appropriateness of health care setting, or criteria for level of care or effectiveness of care. Punitive action will not be taken against a provider who requests an appeal on behalf of a member. A member appeal must be filed within 30 calendar days of NHP s decisions to deny, terminate, modify, or suspend a requested health care service. A member can continue receiving ongoing services during an appeal, as long as the appeal is requested within 10 calendar days of NHP s decision to deny, terminate, modify, or suspend a requested health care service. In order to file an appeal on behalf of a member, or if an individual other than the member or legal guardian requests the appeal, NHP must be provided with written authorization from the member designating the provider as the appeal representative. The Designation of Appeal Representative Form should be used for this purpose. The member must complete and return a signed and dated copy of this form prior to the deadline for resolving the appeal. Failure to return the signed form means communication can only take place with the member. The appeal process will not be held up pending receipt of the form. In the event that NHP s standard first level appeal decision upholds the initial determination, the member or a representative has the right to initiate a second level appeal with NHP or waive his or her right to a second level appeal and file an appeal with the Executive Office of Health and Human Services, Office of Medicaid s Board of Hearings (BOH). A Level II appeal must be filed within 30 calendar days of NHP s Level I decision to uphold the decision to deny, terminate, modify, or suspend a requested health care service. For Level II appeals, in order to continue receiving ongoing services during an appeal, the appeal must be requested within 10 calendar days of NHP s Level I appeal decision to deny, terminate, modify, or suspend a requested health care service. For standard Level II internal appeals, notice of the decision to the affected parties (member/member representative, provider, and primary care provider) will be made within 10 calendar days of the request for a Level II internal appeal unless the time frame has been extended. Once members have exhausted NHP s internal appeals process, they may file an appeal with the Board of Hearings (BOH). The exhaustion requirement is satisfied if either of the following conditions are met: NHP has issued a decision following the Level II appeal, or NHP has issued a decision following the Level I appeal and the member has waived a Level II appeal review. BOH appeals of a standard internal appeal must be filed within 30 calendar days after the notification of decision on the final internal appeal. Any continuing services that are subject of a BOH appeal will continue, pending resolution of the appeal, unless the member specifically indicates that s/he does not want to receive continuing services, and the BOH receives a written request from the member within 10 calendar days from the notification of decision on the final internal appeal. If the BOH upholds an adverse action to deny, limit, or delay services and the member received continuing services while the BOH Appeal was pending, the member may have to pay back MassHealth for the cost of the requested services that were received during this time period. www.nhp.org 10-8 2017-02 01

Standard Clinical Appeals (continued) MassHealth Level I Standard Appeals Level II Standard Appeals Standard External Reviews When filing an appeal on behalf of a member, the provider must identify the specific requested benefit that NHP denied, terminated, modified, or suspended, the original date of NHP s decision and the reason(s) the decision should be overturned. The provider may request a peer-to-peer discussion with the NHP medical director involved in the Internal Appeal regarding these matters. Appeals may be filed by telephone, mail, fax, or in person. NHP will send a written acknowledgment of the appeal on behalf of a member, along with a detailed notice of the appeal process within one business day of receiving the request. An appeal will be conducted by a health care professional that has the appropriate clinical expertise in treating the medical condition, performing the procedure or providing the treatment that is the subject of the Adverse Action, and who was not involved in the original Adverse Action. For a standard Internal Appeal resolution, NHP will complete the appeal and contact the provider within 30 calendar days with the outcome of the review. The time frame for a standard appeal may be extended for up to five calendar days if the member or representative requests the extension, or if NHP requests the extension based on the member s best interest and there is reasonable likelihood that receipt of more information within five calendar days would lead to an approval. A clear description of the procedures for requesting a BOH external appeal, including enclosures of NHP s Appeals Process and Rights for MassHealth members, and a Request for a Fair Hearing Form are included with the Level II denial of appeal notice to the member. Providers, if acting in the capacity of an authorized representative, may request that NHP reconsider an appeal decision if the provider has or will soon have additional clinical information that was not available at the time the decision was made. Upon a reconsideration request, NHP will agree in writing to a new time period for review. To initiate reconsideration, contact the Appeal Coordinator Contact Information Member Appeal/Grievance Coordinator Neighborhood Health Plan 399 Revolution Drive, Suite 820 Somerville, MA 02145 Phone: 800-462-5449 Fax: 617-526-1980 MassHealth members or their representative must complete the Request for Fair Hearing form included with the appeal decision notification to the member and submit to BOH. NHP offers assistance to Members in completing this form. Contact Information Member Appeal/Grievance Coordinator Neighborhood Health Plan 399 Revolution Drive, Suite 820 Somerville, MA 02145 Phone: 800-462-5449 Fax: 617-526-1980 To initiate an external review, contact: Board of Hearing (BOH) Office of Medicaid 100 Hancock Street, 6th Floor Quincy, MA 02171 Fax: 617-847-1204. www.nhp.org 10-9 2017-02 01

Standard Clinical Appeals (continued) MassHealth Level I Standard Appeals Level II Standard Appeals Standard External Reviews The Appeal and Grievance Coordinator will make reasonable efforts to provide oral notice to the member/member representative within one business day of the decision being made with a written notice to follow within 30 days of receipt of the appeal. A clear description of the procedures for requesting a Level II internal appeal or a BOH external appeal, including enclosures of NHP s Appeals Process and Rights for MassHealth members, and a Request for a Fair Hearing Form are included with any denial of appeal notice to the member. Providers, if acting in the capacity of an authorized representative, may request that NHP reconsider an appeal decision if the provider has or will soon have additional clinical information that was not available at the time the decision was made. Upon a reconsideration request, NHP will agree in writing to a new time period for review. To initiate reconsideration, contact the Appeal Coordinator Contact Information Member Appeal/Grievance Coordinator Neighborhood Health Plan 399 Revolution Drive, Suite 820 Somerville, MA 02145 Phone: 800-462-5449 Fax: 617-526-1980 www.nhp.org 10-10 2017-02 01

Standard Clinical Appeals (continued) Commercial Standard Level I Appeal (Level II = n/a) A treating provider may file a clinical appeal on behalf of a member for any decision made by NHP to deny, terminate, modify, or suspend a requested health care benefit based on failure to meet medical necessity, appropriateness of health care setting, or criteria for level of care or effectiveness of care. An appeal must be filed within 180 calendar days of NHP s decision to deny, terminate, modify, or suspend a requested health care service. In order to file an appeal on behalf of a member, or if a individual other than the member or legal guardian requests the appeal, NHP must be provided with written authorization from the member designating the provider as the appeal representative. The Designation of Appeal Representative Form should be used for this purpose. The member must complete and return a signed and dated copy of this form prior to the deadline for resolving the appeal. Failure to return the signed form means communication can only take place with the member. The appeal process will not be held up pending receipt of the form. When filing an appeal on behalf of a member, the provider must identify the specific requested benefit that NHP denied, terminated, modified, or suspended, the original date of NHP s decision and the reason(s) the decision should be overturned. The Provider may request a peer-to-peer discussion with the NHP medical director involved in the Internal Appeal regarding these matters. Appeals may be filed by telephone, mail, fax or in person. NHP will send a written acknowledgment of the appeal on behalf of a member, along with a detailed notice of the appeal process within one business day of receiving the request. Standard External Reviews As part of every written appeal decision that upholds an original decision to deny, terminate, modify, or suspend a requested health care benefit, a member or authorized representative is informed in detail of additional appeal options and the procedures for accessing those options. Members (or their authorized representatives) have the option of requesting an external appeal with the Office of Patient Protection (OPP) if they are not satisfied with the final outcome of NHP s appeal process. In order to activate the external review process with the Office of Patient Protection you will be asked to: Complete and submit the Request for Independent External Review of a Health Insurance Grievance form (enclosed with the Notice of Decision from NHP) to the Office of Patient Protection within four months of receiving NHP s written decision on your appeal. Submit a $25 fee to the Office of Patient Protection along with your request. The Office of Patient Protection may waive the fee in circumstances of financial hardship. Submit a copy of NHP s final adverse determination letter to the Office of Patient Protection along with your request. OPP will complete the appeal within 45 days of receipt of the appeal. www.nhp.org 10-11 2017-02 01

Standard Clinical Appeals (continued) Commercial Standard Level I Appeal (Level II = n/a) An appeal will be conducted by a health care professional that has the appropriate clinical expertise in treating the medical condition, performing the procedure or providing the treatment that is the subject of the Adverse Action, and who was not involved in the original Adverse Action. When an appeal is submitted by or on behalf of a member with a terminal illness, resolution will be provided within five business days of the request. For a standard Internal Appeal resolution, NHP will complete the appeal and contact the provider within 30 calendar days with the outcome of the review. The time frame for a standard appeal may be extended for up to 15 additional calendar days due to circumstances beyond NHP s control and providing that the member or representative agree to the extension. The Appeal and Grievance Coordinator will make reasonable efforts to provide oral notice to the member/member representative within one business day of the decision being made with a written notice to follow within 30 days of receipt of the appeal. NHP will continue to authorize disputed services during the formal appeal process if those services had initially been authorized by NHP. Continued authorization will not, however, be granted for services that were terminated pursuant to the expiration of a defined benefit limit. Providers, if acting in the capacity of an authorized representative, may request that NHP reconsider an appeal decision if the provider has or will soon have additional clinical information that was not available at the time the decision was made. Upon a reconsideration request, NHP will agree in writing to a new time period for review. To initiate reconsideration, contact the Appeal Coordinator. Standard External Reviews Contact Information Member Appeal/Grievance Coordinator Neighborhood Health Plan 399 Revolution Drive, Suite 820 Somerville, MA 02145 Phone: 800-462-5449 Fax: 617-526-1980 To initiate an external review, contact: Office of Patient Protection (OPP) Health Policy Commission 50 Milk Street, 8th Floor Boston, MA 02109 Phone: 800-436-7757 Fax: 617-624-5046 www.nhp.org 10-12 2017-02 01

Standard Clinical Appeals (continued) Commercial Standard Level I Appeal (Level II = n/a) Standard External Reviews Appeals may be filed by telephone, mail, fax or in person. NHP will send a written acknowledgment of the appeal on behalf of a member, along with a detailed notice of the appeal process within one business day of receiving the request. An appeal will be conducted by a health care professional that has the appropriate clinical expertise in treating the medical condition, performing the procedure or providing the treatment that is the subject of the Adverse Action, and who was not involved in the original Adverse Action. When an appeal is submitted by or on behalf of a member with a terminal illness, resolution will be provided within five business days of the request. For a standard Internal Appeal resolution, NHP will complete the appeal and contact the provider within 30 calendar days with the outcome of the review. The time frame for a standard appeal may be extended for up to 15 additional calendar days due to circumstances beyond NHP s control and providing that the member or representative agree to the extension. The Appeal and Grievance Coordinator will make reasonable efforts to provide oral notice to the member/member representative within one business day of the decision being made with a written notice to follow within 30 days of receipt of the appeal. NHP will continue to authorize disputed services during the formal appeal process if those services had initially been authorized by NHP. Continued authorization will not, however, be granted for services that were terminated pursuant to the expiration of a defined benefit limit. www.nhp.org 10-13 2017-02 01

Standard Clinical Appeals (continued) Commercial Standard Level I Appeal (Level II = n/a) Standard External Reviews Providers, if acting in the capacity of an authorized representative, may request that NHP reconsider an appeal decision if the provider has or will soon have additional clinical information that was not available at the time the decision was made. Upon a reconsideration request, NHP will agree in writing to a new time period for review. To initiate reconsideration, contact the Appeal Coordinator. Contact Information Member Appeal/Grievance Coordinator Neighborhood Health Plan 399 Revolution Drive, Suite 820 Somerville, MA 02145 Phone: 800-462-5449 Fax: 617-526-1980 Access to Appeal File by Member or Member Representative Members or their representative have the right to receive a copy of all documentation used in the processing of their appeal, free of charge. Limitations may be imposed, only if, in the judgment of a licensed health care professional, the access requested is reasonably likely to endanger the life or physical safety of the individual or another person. The member (or an authorized representative) must submit their request in writing to NHP and it will be processed by the Appeal and Grievance Coordinator, in consultation as necessary with the Compliance Office. Requests for access to appeal files will be processed as quickly as possible, taking into consideration the member s condition, the subject of the appeal, and the time frames for further appeals. Continuation of Ongoing Services During Appeal If the internal appeal filed concerns the denial, modification or termination of an NHP covered service that the member is receiving at the time of the adverse action, the member has the right to continue his or her benefits through the conclusion of the appeals process. There are timeframes for requesting continuation of coverage, as explained in the table above. Continued authorization will not, however, be granted for services that were terminated pursuant to the expiration of a defined benefit limit. If the internal appeal filed concerns the denial, modification or termination of a non-covered service that the member is receiving and NHP does not reverse the adverse action, the member may be liable for payment of the service. www.nhp.org 10-14 2017-02 01

Notification of Decision If NHP does not act upon an appeal within the required timeframe, or an otherwise agreed upon extension, the appeal will be decided in the member s favor. Any extension deemed necessary to complete review of an appeal must be authorized by mutual written agreement between the member (or an authorized representative) and NHP. Dental Services Appeals NHP delegates the internal grievance/appeal process for routine dental services for some Commercial/QHP members to Delta Dental. Please verify the member s dental coverage with NHP s Customer Service Department. Reconsideration of Appeal Decision Providers, if acting in the capacity of an authorized representative, may request that NHP reconsider an appeal decision if the provider has or will soon have additional clinical information that was not available at the time the decision was made. Upon a reconsideration request, NHP will agree in writing to a new time period for review. To initiate reconsideration, contact the individual identified in the decision letter upon receipt. Consumer Protection from Collections and Credit Reporting During Appeals Effective 7/1/15, Massachusetts Law requires health care providers (and their agents) to abstain from reporting a member s medical debt to a consumer credit reporting agency or sending members to collection agencies or debt collectors while an internal or external appeal is going on. This consumer protection also extends for 30 days following the resolution of the internal or external appeal. Behavioral Health Appeals Management for all behavioral health related appeals is delegated to NHP s Behavioral Health Partner, Beacon Health Options. For more information, please see the Behavioral Health Provider Manual or contact Beacon directly at 800-414-2820. www.nhp.org 10-15 2017-02 01