Denial and Clawback Response Guide.

Answer a denial or a clawback demand correctly and on time, appealing on the merits what you can support and escalating the serious ones to professionals.

The third step of protecting against clawbacks.

Part A. Support and appeal on the merits

For a denial or demand you can support with documentation, assemble the record and appeal within the deadline, which is often short and unforgiving.

Denial or demand

Documentation that supports us

Appeal deadline

Filed

Part B. Escalate the serious ones

If a clawback is large, alleges a pattern, or questions whether your billing was truthful, stop and get a nonprofit accountant and an attorney before you respond (routed: yes / no / not applicable)

How you respond can determine whether a fixable dispute becomes a serious one. Serious or truthfulness-touching demands route to professionals, to compliance and risk, and to the Audit Response Plan.

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