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Peer-to-peer

Peer-to-peer review after a behavioral-health denial: how to prepare

A peer-to-peer can reverse a denial in one call, but windows are short and payer-specific. Here is who should be on the call, what the one-page brief needs, what to ask, and how to document it.

By the ClaimParrot editorial team · Who we are · Reviewed · 6 min read · 9 cited sources

Quick answer

A peer-to-peer review is a call between the treating clinician and the payer's physician or clinical reviewer about a denial or a pending adverse decision. Request it inside the payer's window, which can be as short as 48 hours, ask for a reviewer in a matching specialty, bring a one-page brief tied to each stated reason, and log who said what.

Peer-to-peer review at a glance
QuestionShort answer
Is it required by federal law?No. Availability and windows are set by each payer and contract; formal appeal rights exist separately
Who takes the callThe treating clinician, or another qualified clinician who knows the case
Who reviews for the payerA physician or other appropriate professional; Medicare Advantage and Medicaid rules require relevant expertise
What to bringA one-page brief: stated reasons, criteria cited, dated record facts, risk at a lower level, and the step-down plan
After the callLog the reviewer, credentials, reference number and outcome; appeal in writing if it is upheld
01

What is a peer-to-peer review?

It is an informal clinical conversation, offered by many payers, in which the treating clinician discusses a denial or a pending adverse decision with the payer's reviewer. It can change the decision on the spot. It is not a formal appeal, and it usually does not replace or pause the written appeal deadline.

In behavioral health, peer-to-peers come up most around concurrent review for residential, inpatient psychiatric, PHP and IOP care, and around ABA authorizations. Some payers offer the conversation before a decision is final, as a chance to add information; others offer it only after a denial. Read the notice or the payer's provider manual for which applies, and see the payer guides for the major behavioral-health payers.

02

When do you have to request it?

As soon as the denial or the reviewer's call arrives. Each payer sets its own window: one Florida Medicaid plan requires requests within 48 hours of the denial letter for behavior analysis services, and some plans offer the call only before a decision, others only after. If the window has closed, file a written appeal instead.

Record the time the denial was received, the deadline the payer gives for scheduling, and every attempt to schedule. If the payer cannot offer a slot inside its own window, ask for that in writing and file the expedited appeal in parallel so the clock is protected.

What five payers publish about peer-to-peer review (public pages checked October 14, 2026)
PayerWhat its public material saysSource
Optum Behavioral HealthWhen outpatient continued care does not meet criteria, the case goes to peer-to-peer review with an Optum peer reviewer before any denial; Optum may also ask to speak with the attending psychiatrist before authorizing an admission or continued stayOptum network manual
Carelon Behavioral HealthThe care manager may arrange a peer-to-peer before deciding; only a psychiatrist, or for some levels a doctoral psychologist, can deny; after a denial the provider can appeal and speak with another peer reviewerCarelon provider handbook
AetnaA physician may request a peer-to-peer review; no behavioral-health window is stated on the pageAetna utilization management
Sunshine Health (Florida Medicaid)Behavior analysis services only: request within 48 hours of the denial letter date; not used for denials based on missing documentationSunshine Health peer-to-peer page
Home State Health (Missouri)Ended the pre-decision peer-to-peer offer for behavioral health on September 22, 2025; post-denial peer-to-peer continues through the denial letter's instructionsHome State Health notice

Payers change peer-to-peer rules, sometimes by plan or by state. Check the current provider manual or bulletin for each case rather than relying on last year's process.

03

Who should be on the call, and who should the reviewer be?

The treating clinician should take the call, with UR staff preparing and listening. Ask for a reviewer with matching expertise, such as a psychiatrist for psychiatric care, an addiction specialist for SUD care or a child psychiatrist for adolescents. Federal rules for Medicare Advantage and Medicaid require reviewers with appropriate expertise.

Medicare Advantage organizations must have a physician or other appropriate health care professional with relevant expertise review a request before issuing an adverse medical-necessity decision. Medicaid managed care plans must have any denial or reduction made by someone with appropriate expertise in the enrollee's behavioral-health needs. In employer-plan appeals, the plan must consult a health care professional with appropriate training and experience who was not involved in the first decision.

This matters in practice. In the American Medical Association's 2025 survey, only 16% of physicians who had done peer-to-peers said the payer's reviewer often or always had appropriate qualifications (AMA survey, May 2026). Ask the reviewer's name, credentials and specialty at the start of the call and write them down.

04

What should the one-page brief contain?

Only what the clinician needs to answer the reviewer's stated reasons in a few minutes: the decision and dates, the criteria cited, the record facts that meet each criterion, what would happen at a lower level of care, and a specific, time-limited request. One page forces the case into the reviewer's frame.

The peer-to-peer prep sheet generator builds the same structure as a printable page.

One-page peer-to-peer brief
SectionWhat to writeExample of a useful line
DecisionLevel of care, dates and units denied, reason as quotedPHP days 8-14 denied: “symptoms manageable in IOP”
Criteria citedCriteria set, edition and the dimension or rule namedPayer level-of-care guideline, risk and functioning dimensions
Facts that meet themDated, observable facts with record page numbersDay 6 safety assessment documents a plan and intent; safety plan updated
Lower-level riskWhy the offered level would not be safe or effectiveIOP attempt in March ended in an ED visit after 9 days
The askSpecific days or units and the step-down conditions7 more PHP days; step down when 5 days without self-harm urges
QuestionsWhat documentation would change the decisionWhich facts would you need to see for continued PHP?
05

What should the clinician say and ask on the call?

Lead with the patient's current risk and the specific facts that meet the cited criteria, then ask what would change the decision. Keep it clinical and concrete. Questions that pin down the reviewer's reasoning are as valuable as arguments, because the answers shape the written appeal if the call does not succeed.

  1. 01Confirm the reviewer's name, credentials, specialty and the case reference number.
  2. 02Ask the reviewer to state the specific criterion they believe is not met.
  3. 03Answer that criterion with the dated facts from the brief.
  4. 04Explain what is likely to happen at the lower level, based on this patient's history.
  5. 05Make the specific request: how many days or units, and the step-down conditions.
  6. 06If the reviewer will not approve, ask what documentation would change the decision and how to send it.
06

How should the call be documented?

Write a call note the same day: date and time, who was on the call, the reviewer's credentials, the reasons the reviewer gave, what was approved or denied, any documents the reviewer asked for and the reference number. Record what was actually said. That note becomes evidence if the case goes to a written appeal or external review.

If the decision is upheld, file the written appeal within the plan's deadline, expedited if the patient is still in care; the continued-stay guide covers the fast paths. If the reviewer named criteria you have not seen, request them in writing with the criteria request letter.

Fictional example

An adolescent PHP peer-to-peer

Lakeshore Youth Services receives a denial for continued PHP days for a 16-year-old with an eating disorder and depression. The notice offers a peer-to-peer within one business day and names the payer's adolescent level-of-care guideline.

The UR nurse drafts a one-page brief: weight trend over two weeks, two purging episodes on program days, a failed IOP trial in the spring, and a request for 10 more days with step-down when weight is stable for a week. She asks for a child and adolescent psychiatrist and gets an adult psychiatrist instead, which she records.

The treating psychiatrist walks the reviewer through the brief. The reviewer approves 5 days and asks for weekly weights. The team logs the call, sends the weights, and prepares a written appeal for the remaining 5 days in case the next review goes against them.

Names, dates, payers and amounts are invented for illustration.

Where ClaimParrot fits

What a ClaimParrot packet does here

  • Every level-of-care packet includes a peer-to-peer brief: the opening statement, the points with their evidence, the asks and the questions for the reviewer.
  • If the call does not reverse the decision, the same packet already holds the appeal letter draft and the deadline plan: $99, within 3 business days, and the first packet is free (pricing).
  • It is built from a de-identified summary and checked by a person before delivery (Trust & security).

Every draft is reviewed and approved by your team. ClaimParrot does not make medical-necessity determinations or give legal advice.

Common questions

Frequently asked questions

Does a peer-to-peer pause the appeal deadline?

Usually not. The written appeal deadline in the notice keeps running whether or not a peer-to-peer happens. If the call does not resolve the denial, file the appeal within the original window.

Can a therapist or nurse do the peer-to-peer instead of the psychiatrist?

Some payers accept another licensed clinician involved in the case; others require the attending physician. Check the payer's rules. Whoever takes the call should know the patient and be able to speak to the clinical facts directly.

What if the payer's reviewer is not in the same specialty?

Ask for a reviewer in a matching specialty and record the answer. Federal rules for Medicare Advantage do not always require the same specialty, but they do require appropriate expertise; a mismatch is worth noting in a written appeal.

Should the call be recorded?

Only with everyone's consent and as state law and your policy allow. A detailed written note made the same day, with the reviewer's name and the reference number, is the standard record and is usually enough.

Sources

Primary sources and references

  1. 2025 AMA prior authorization physician survey (released May 13, 2026) · American Medical Association · checked
  2. 42 CFR 422.566: Medicare Advantage organization determinations, including who must review them (paragraph (d)) · eCFR, National Archives · checked
  3. 42 CFR 438.210: Medicaid managed care coverage and service authorization timeframes · eCFR, National Archives · checked
  4. 29 CFR 2560.503-1: ERISA claims procedure (deadlines, concurrent care, full and fair review) · eCFR, National Archives · checked
  5. National Network Manual (effective Sept. 1, 2026): notification, concurrent review and peer-to-peer review · Optum Behavioral Health · checked
  6. Provider Handbook, section 10: utilization management, continued stay and peer-to-peer review · Carelon Behavioral Health · checked
  7. Utilization management: criteria used and peer-to-peer review · Aetna · checked
  8. Peer-to-peer requests for behavior analysis services · Sunshine Health (Florida Medicaid plan) · checked
  9. Peer to peer advisor review process for behavioral health (effective Sept. 22, 2025) · Home State Health (Missouri) · checked

General information, not legal or medical advice. Payer rules change; confirm deadlines and requirements in the notice and the plan documents. Read our editorial policy.

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