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Due Process Denied

Medicare Appeals, Wound Care, and the Right to a Meaningful Hearing

Medicare's appeals system offers multiple levels of review, but those levels can create the appearance of due process while withholding its substance. This paper uses a wound-care appeal case study to show how related claims from the same patient, same wound, same care plan, and same product can be fragmented across multiple appeal numbers, reviewers, and judges - while the denial theory shifts at every stage. The result is what the paper calls a "no-rebuttal ratchet": providers respond to one rationale, only to face a new one in the next decision, often while recoupment continues. Due Process Denied argues that Medicare can protect program integrity without forcing providers into a multi-front procedural endurance contest. It proposes practical reforms including episode-of-care docketing, Material Issues Notices, rationale ledgers, QIC claim maps, pre-denial reviewer conferences, contractor accuracy metrics, and recoupment stays when rationale drift or appeal-scope ambiguity prevents meaningful review.