An accreditation-denial appeal is an organization's written request that its accreditor reverse a denial, filed under the accreditor's own published appeal policy and argued against the standards cited in the decision. Integral Healthcare Solutions (IHS) works for organizations that have received a denial: IHS analyzes the denial against your record and drafts the appeal your organization submits.

IHS is a healthcare consulting firm, not a law firm, and this page is not legal advice. The accreditor sets the deadline and makes the decision.

What is an accreditation-denial appeal?

Each accreditor publishes its own appeal or reconsideration process, so the governing text is that accreditor's policy plus the standards cited in the denial. Two published examples:

URAC. URAC's Accreditation Process page states: "If you do not receive full accreditation, you may appeal the decision. A final determination will be made by the Executive Committee of URAC's Board of Directors" (URAC, Accreditation Process). The same page lists decision categories that include "Corrective Action (non-accredited status. Deficiencies require correction)" and "Denial," and states that "Applications are presented to the Accreditation Committee twice a month and clients are notified within 10 business days of the decision." URAC's detailed appeal procedure was not part of the sources reviewed for this page, so this page states no URAC appeal deadline. An appeal deadline will be in your URAC decision letter or URAC's current appeal policy; read it the day the decision arrives, because this page cannot tell you the period.

ACHC. Each ACHC program publishes its own accreditation process document. In the Office-Based Surgery version, "The organization submits a written request for appeal to its ACHC Account Advisor no later than 30 calendar days from the date on ACHC's Denial letter" (ACHC Accreditation Process [1227], Office-Based Surgery, revised 07/20/2023). That document also states that an appeal will not be granted if the request arrives after the 30-day period, if the organization has an outstanding balance, or if it has a payment plan that is not current. The same document has a separate Dispute Process for individual standard deficiencies on the Deficiency Assessment Report, with a written request due to the Account Advisor no later than 10 calendar days from receipt of that report, and it states that a company wishing to dispute a denial decision must follow the appeal process. Whether an organization holding both a Denial letter and a Deficiency Assessment Report has any use for the dispute path is IHS's reading of the document and is not settled; read Section VI.D and VI.E of your own program's process document immediately.

The same ACHC document describes what the appeal must contain: "The written request outlines the standard(s) noted in the Deficiency Assessment Report that the organization believes ACHC incorrectly determined as a deficiency. The organization must also provide evidence to support that, at the time of the survey, the organization was in compliance with the standard(s). Any evidence the organization submits must have been presented to and reviewed by the Surveyor(s) at the time of the survey." It states that the ACHC Appeals Committee "is composed of a minimum of three individuals with clinical and/or program expertise," that the committee "will evaluate and determine whether ACHC followed its stated Accreditation Process in conducting the organization's accreditation survey" and notifies the organization whether it upholds or reverses the Denial, and that "All decisions made by the ACHC Appeals Committee are final" (ACHC Accreditation Process [1227], Office-Based Surgery, revised 07/20/2023).

Who needs it and what triggers it

• A URAC decision short of full accreditation. URAC states that an organization that does not receive full accreditation "may appeal the decision" (URAC).
• An ACHC Denial letter, which starts the 30-calendar-day period in the Office-Based Surgery process (ACHC Accreditation Process [1227], Office-Based Surgery, revised 07/20/2023).
• A missed ACHC Plan of Correction. ACHC states: "Failure to submit an approved Plan of Correction, with evidence, within the required time frame will result in a change of accreditation status from Accreditation Pending to Denial of Accreditation" (ACHC [1227]).

Other accreditors' appeal policies were not part of the sources reviewed for this page; IHS reads the applicable policy from the accreditor's current document at the start of an engagement.

How IHS helps

IHS analyzes the denial against your record and drafts the appeal your organization submits. The work runs in this order:

1. Gap assessment against the governing text. IHS reads the accreditor's appeal policy and every standard cited in the decision, then analyzes each cited finding, standard by standard, against the record your organization submitted.
2. Document and evidence mapping. IHS sorts the findings into those already answered in the submitted record and those that would need new evidence, and builds an evidence index.
3. Drafting. IHS drafts the appeal and the evidence index. Thomas G. Goddard, JD, PhD, writes the argument himself.
4. Hearing preparation. Where the accreditor holds a hearing, IHS prepares your organization's representatives for it.

IHS's reading, October 2026: the ACHC Office-Based Surgery process requires that appeal evidence "must have been presented to and reviewed by the Surveyor(s) at the time of the survey." On that reading, a finding that can be answered only with new evidence may not fit an ACHC appeal under that process, and the sorting step shows your organization which findings fall on each side. This is IHS's reading of one ACHC program document, not ACHC's statement, and other ACHC programs may differ.

What your organization supplies: the decision, the full submission and correspondence, any new evidence, and the name of the person who signs and sends the appeal.

The limit: your organization submits the appeal under its own name. IHS does not contact the accreditor and does not attend any hearing as your organization's representative.

What to have ready

Gather these before the introductory call:

• The denial or decision letter, with its date, since ACHC's 30-calendar-day period runs "from the date on ACHC's Denial letter" (ACHC Accreditation Process [1227], Office-Based Surgery, revised 07/20/2023).
• The decision category the accreditor assigned. URAC's categories include "Corrective Action" and "Denial" (URAC, Accreditation Process).
• The Deficiency Assessment Report or equivalent findings list, since an ACHC appeal "outlines the standard(s) noted in the Deficiency Assessment Report" (ACHC [1227]).
• The date your organization received the Deficiency Assessment Report, since the ACHC Dispute Process runs 10 calendar days from receipt (ACHC [1227]).
• The full submission as sent, including policies, procedures and evidence files.
• Records showing which documents the surveyors were shown and reviewed at the time of survey (ACHC [1227]).
• All correspondence with the accreditor during the review.
• Any Plan of Correction submitted, with its evidence and dates (ACHC [1227]).
• Confirmation that your account with the accreditor has no outstanding balance and that any payment plan is current, two of the grounds on which ACHC states an appeal will not be granted (ACHC [1227]).
• Any new evidence created since the decision, kept separate from the submitted record.
• The name of the person who will sign and send the appeal.

With these in hand, the introductory call can start from the deadline.

How it compares

An appeal is one of several paths after a denial. The accreditor's own text defines each.

The choice among these belongs to your organization and depends on the findings, the deadline and the evidence available.

What it costs

URAC and ACHC do not publish an appeal fee on the pages we reviewed; fees depend on scope. ACHC's Office-Based Surgery process does state that an appeal will not be granted if the organization has an outstanding balance or a payment plan that is not current. IHS scopes each engagement after a free introductory call.

What this is not

• This is not legal advice, and IHS is not a law firm.
• IHS does not guarantee the accreditor's decision. The accreditor sets the deadline and decides, and ACHC states its Appeals Committee decisions are final.
• IHS does not submit the appeal, contact the accreditor, or attend a hearing as your representative. Your organization submits under its own name.

Frequently asked questions

Can we appeal an accreditation denial?

URAC and ACHC both publish appeal processes. URAC states that an organization that does not receive full accreditation may appeal the decision. ACHC's Office-Based Surgery accreditation process document (revised 07/20/2023) publishes an appeal process; check the process document for your own ACHC program.

How long do we have to appeal an ACHC denial?

In ACHC's Office-Based Surgery process document, revised 07/20/2023, the written request goes to the organization's ACHC Account Advisor no later than 30 calendar days from the date on the Denial letter. Check the process document for your own ACHC program.

Who decides a URAC accreditation appeal?

URAC states that a final determination is made by the Executive Committee of URAC's Board of Directors.

Can we submit new evidence in an accreditation appeal?

Under ACHC's Office-Based Surgery process, any evidence submitted must have been presented to and reviewed by the surveyors at the time of the survey. Other accreditors set their own rules, which IHS reads from the accreditor's current policy.

What is the difference between appealing a denial and reapplying?

In ACHC's Office-Based Surgery process, the Appeals Committee "will evaluate and determine whether ACHC followed its stated Accreditation Process in conducting the organization's accreditation survey" and notifies the organization whether it upholds or reverses the Denial. ACHC also states that after a Denial of Accreditation the organization may reapply at any time it is ready for survey.

What is URAC Corrective Action status, and is it the same as a denial?

URAC lists Corrective Action and Denial as separate decision categories. URAC describes Corrective Action as non-accredited status in which deficiencies require correction.

What should an accreditation appeal letter contain?

In ACHC's Office-Based Surgery process, the written request outlines the standards in the Deficiency Assessment Report that the organization believes were incorrectly determined as deficiencies, with evidence that the organization was in compliance at the time of survey. IHS drafts the appeal and evidence index for the organization to submit.

Why are accreditation appeals denied?

ACHC's Office-Based Surgery process states that an appeal will not be granted if the request arrives after the 30-calendar-day period, if the organization has an outstanding balance, or if a payment plan is not current. The same document requires evidence that the organization was in compliance at the time of survey, and the Appeals Committee's decision is final.

Should a lawyer or an accreditation consultant write the appeal?

Your organization decides whether to involve counsel. IHS is a consulting firm, not a law firm; it analyzes the findings against the record and drafts the appeal, with Thomas G. Goddard, JD, PhD, writing the argument, and your organization submits it.