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Revised Process for Provider Complaints Against MA Plans

Learn about CMS’ new centralized MA dispute resolution process and how to adapt to the change.

CMS issued an electronic form for providers seeking assistance from CMS to resolve claims issues with Medicare Advantage (MA) plans.1 The process will remain centralized, rather than handled by CMS’ regional offices. CMS has previously indicated that it will look for patterns among submitted complaints. The increased scrutiny is intended to encourage MA plans to address issues in a timely manner.

Updated details about the complaint submission process are available below.

When Should Providers Use This Process?

This process should be used for provider appeal complaints and claims payment disputes.

  • Provider Appeal Complaint: Submitted by a contracted or non-contracted provider alleging an MA plan’s failure to follow the applicable appeals process. Noncompliance includes when an MA plan fails to alert the provider of the appeal process or fails to respond to a submitted appeal.
  • Claims Payment Dispute: Provider’s dispute over the amount the MA plan paid for an approved service. Appealable decisions include those in which the plan partially approved claims or instances when submitted services were altered by the plan, e.g., downcoding, bundling, or approving at a lower level of care, resulting in a lower payment amount.

What Is the Process for Filing Complaints?

Providers can access the online complaint form here. The form requires basic information about the complainant, beneficiary, provider, and MA plan, as well as a complaint summary and optional fields for date(s) of service and claim number. MA plans will no longer receive an attachment of the original provider complaint form.

What Happens After Filing the Complaint?

Provider complaints will be placed into a queue in the Health Plan Management System Complaints Tracking Module. CMS will review the complaints and triage prior to assigning a contract number. Prior communications related to this process indicated CMS will direct the MA plan to investigate the case within 30 days and work directly with the provider toward resolution.

Why Did CMS Make This Change?

The centralized process described above allows the agency to identify trends in provider complaints, investigate matters as appropriate, and work with the MA plan to address issues. CMS previously clarified that the 10 regional offices still maintain responsibility for MA plan oversight despite centralization of the complaint process.

What Healthcare Organizations Can Do

Healthcare organizations should implement a workflow for utilizing the new CMS complaint process. The workflow should be grounded in documented criteria developed by the revenue cycle team that govern when a claim should be submitted through the complaint process. If the provider is part of the MA plan’s network, a review of contract language for the plan in question should be a stage gate in the criteria. This not only helps the organization avoid submitting invalid complaints but also provides documentation to support the plan’s violation of its contractual obligation to the provider.

Finally, organizations should identify a single point of contact within the revenue cycle team who is responsible for final review and approval of claims based on the established criteria and will be listed on the complaint form.

If you have questions or need assistance with Medicare Advantage, please reach out to a professional at Forvis Mazars.

  • 1“Health Plan Management System (HPMS) Complaints Tracking Module Updates for Managing Provider Complaints,” aha.org, December 22, 2025.

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