Reconsideration by the Part D Independent Review Entity

If a Part D plan sponsor issues an unfavorable or partially favorable redetermination decision, the enrollee, the enrollee's representative, or the enrollee's prescriber may appeal the decision to the Independent Review Entity (IRE), also commonly called the Part D Qualified Independent Contractor (QIC), by requesting a reconsideration. C2C Innovative Solutions, Inc. is the current Part D IRE. If a Part D plan sponsor dismisses a request for a plan reconsideration, the enrollee or other proper party has the right to request review of the dismissal by the IRE. 

For more information on reconsiderations and appointing a representative, see section 60 and 20 of the Parts C & D Enrollee Grievances, Organization/Coverage Determinations, and Appeals Guidance, using the link in the "Downloads" section below.

How to Request a Reconsideration or Review 

An enrollee, an enrollee's representative, or an enrollee's prescriber may request a standard or expedited reconsideration of a plan denial of coverage or payment, or a review of a plan dismissal of a reconsideration request.

• The request must be filed with the IRE within 60 calendar days from the date of the plan sponsor's redetermination decision notice.
• All requests must be made in writing, which includes by fax.
• An enrollee, an enrollee's representative, or an enrollee's prescriber may use the model "Request for Reconsideration of Medicare Prescription Drug Denial" form to request a reconsideration with the IRE (using the left navigation menu, go to the "Forms" webpage).

Reconsideration appeals requests must be sent to the IRE, C2C, at one of the following addresses:

Part D IRE Portal Address:

https://www.c2cinc.com//Appellant-Signup

Standard Mail:

C2C Innovative Solutions, Inc. 
Part D Drug Reconsiderations 
P.O. Box 44166
Jacksonville, FL 32231-4166

Courier or Tracked Mail such as FedEx or UPS:

C2C Innovative Solutions, Inc.
Part D QIC
301 W. Bay St., Suite 1110
Jacksonville, FL 32202

The IRE’s website has many features that allow enrollees, enrollee representatives, plan sponsors, and physicians or other prescribers to obtain information regarding the Medicare Part D reconsideration process. To access the IRE’s website, use the link in the "Related Links" section below.  Also provided in the "Related Links" section below is a link to the Part D QIC Reconsideration Procedure Manual (click on the "Part D QIC Manual" link).

The Medicare Parts C & D IRE Decision Database can be located at https://www.cms.gov/qic-decision-search.

How the IRE Processes Reconsideration Requests

Once the benefit request is received by the IRE, the IRE must make its decision and provide written notice of its decision as quickly as the enrollee's health requires, but no later than 72 hours for expedited requests or 7 calendar days for standard requests from receipt of the request. This timeframe may be extended for up to 14 calendar days if the case involves an exception request and the IRE has not received the supporting statement from the doctor or other prescriber supporting the request, and/or the proper documentation of representation has not been received. 

For payments, the IRE must make its decision and provide written notice of their decision (and instruct plans to make payment, when appropriate) within 14 calendar days after receiving a request. For expedited reconsiderations, initial notice may be provided verbally, so long as a written follow-up notice is mailed to the enrollee within 3 calendar days of the verbal notification.

If the decision is unfavorable or partially favorable, the decision notice will contain the information needed to file a request for a hearing with an Administrative Law Judge within the Office of Medicare Hearings and Appeals (OMHA). Parties to the hearing may waive their right to the oral hearing and request that a decision be made based on the record. Use the left navigation menu on this page to link to other pages that contain detailed information about hearings with an ALJ and obtaining an on the record review by OMHA, or any other level of appeal.

Fact Sheet: Part D Benefit Reconsideration Appeals Data

These reports summarize and highlight some of the key data on reconsiderations from January 1, 2017 to the most recently available date. To view the Fact Sheets, click on the link "Fact Sheets Part D Reconsideration Appeals Data" link in the "Downloads" section below.