Got a Qlarant “Notice of Suspension of Medicare Payments”? The 15-Business-Day Rebuttal Playbook for California Hospices.

A Qlarant Notice of Suspension of Medicare Payments is not an audit request and not a denial. It’s a payment freeze already in effect by the time you open the envelope — and a 15-business-day window to file a rebuttal that is explicitly not appealable. This is the playbook: what reviewers actually look for, the documentation package that works, and the mistakes that sink otherwise legitimate rebuttals.

For the broader context on how 447 California hospices ended up suspended in April 2026, start with our overview of the CMS sweep. This post assumes the letter is already in your hand.

What a Rebuttal Actually Is (and Isn’t)

The rebuttal right comes from 42 C.F.R. § 405.372(b). It is a written statement submitted to the UPICW (Qlarant) that:

• Argues, claim by claim, that each example in the suspension letter met all applicable Medicare coverage and payment requirements
• Provides pertinent evidence that justifies termination of the suspension
• Must be received within 15 business days of the provider’s receipt of the notice

Three things the rebuttal is not:

• It is not an appeal. Under § 405.375(c), the response to your rebuttal is “not an initial determination and is not appealable.”
• It is not a refund request. Funds stay in the suspense account until the investigation resolves.
• It is not a chance to argue policy. “The national live discharge rate statistic is misleading” is not a rebuttal. Evidence that the five specific example claims in your letter met Medicare criteria is.

From the letter itself: “Merely providing general assertions or denials will typically be insufficient to overcome the allegation(s).” That sentence is not filler. It is the #1 reason rebuttals fail.

Where to Send It

Every California UPICW rebuttal goes to the same address:

Kristi Arias
Manager, Program Integrity
Western Unified Program Integrity Contractor
Qlarant Integrity Solutions, LLC
28464 Marlboro Avenue
Easton, Maryland 21601-2732
Attention: UPICW Rebuttal and Suspension Department

Status inquiries (not rebuttals) can be emailed to adminactions_upicw@qlarant.com. Any actual request to remove the suspension has to come through the written rebuttal process.

The Documentation Package, Claim by Claim

Your Qlarant letter lists a table of Claim Control Numbers (CCNs) with dates of service. Those are your example claims — typically five. For each one, your rebuttal needs to include every document that shows all applicable Medicare coverage and payment requirements were met. At minimum:

1. Signed Election Statement

Signed by the beneficiary or authorized representative. This is the first thing reviewers check — a missing or unsigned election statement sinks the claim regardless of everything else.

2. Election Statement Addendum (where applicable)

Required if the beneficiary or another applicable party requested it. Confirm timing requirements were met. The addendum requirement has been in effect since 2020 — reviewers check it.

3. Face-to-Face Encounter Documentation

Required beginning with the third benefit period. This is commonly where post-2022 CMS reviewers find gaps. You need proof the encounter happened and was performed by a qualified medical professional (physician or nurse practitioner employed by or under contract with the hospice).

4. Initial 90-Day Certification of Terminal Illness

Must include the physician narrative. A signed cert without the narrative is a denial. The narrative must support the six-months-or-less prognosis with clinical findings, not boilerplate.

5. Recertification of Terminal Illness for Every Subsequent Benefit Period

Each recert also requires the physician narrative. This is the second-most-common failure mode — a clean initial cert followed by boilerplate recerts that don’t connect the clinical picture to continued six-month eligibility.

6. Plan of Care (POC)

Active and signed by the IDT. Must reflect the beneficiary’s current condition and be updated as condition changes.

7. Interdisciplinary Team (IDT) Meeting Documentation

Showing the POC was reviewed and updated at the required frequency. The IDT notes should connect to the recertification narrative — reviewers look for consistency between what the team documented and what the physician certified.

Why Most Rebuttals Fail

From what is visible in the letters and the broader enforcement record, three failure patterns dominate:

Failure 1: General Assertions

“Our hospice has always followed Medicare guidelines” or “Our live discharge rate is explained by patient-specific circumstances” — without per-claim documentation — is a failed rebuttal. The regulation requires evidence specific to each allegation.

Failure 2: Defending the Statistic, Not the Claims

The elevated live discharge rate (whether the letter cites 55%, 70%, 90%, or 100%) is the allegation’s hook, not its substance. Defending the statistic (“our patient population is different”) is weaker than defending the example claims (“here are five certifications with narratives that support the six-month prognosis and documentation that the live discharges were for appropriate clinical reasons”).

Failure 3: Missing a Single Required Document

If any one of the documentation elements above is missing for an example claim, that claim is a point for the government — even if the other four are airtight. Reviewers don’t grade on a curve.

Failure 4: Late Submission

The 15-business-day clock is strict. Qlarant will consider extension requests on a case-by-case basis, but do not plan around one. Build the rebuttal on the assumption that the deadline is hard.

The Narrative Section: What to Actually Say

A good rebuttal has two parts: (1) the claim-by-claim documentation package, and (2) a narrative section that does three things:

• Address each specific allegation in the letter. If the letter cites elevated live discharge rate, walk through what actually happened with the live-discharged patients whose claims were flagged.
• Connect the documentation to the regulation. For each example claim, cite the specific Medicare coverage requirement (42 C.F.R. § 418.22 for certification, § 418.25 for admission, § 418.56 for POC, etc.) and point to the document in your package that demonstrates compliance.
• Where something is genuinely not in compliance, address it directly. A rebuttal that ignores a problem looks worse than one that acknowledges it and explains what was done to correct it.

What Happens After You Submit

From 42 C.F.R. § 405.375:

• The suspension continues while your rebuttal is reviewed. Submitting does not restart payments.
• You will receive a written response. It will explain whether the suspension continues or terminates.
• The response is not an initial determination and is not appealable.
• If the suspension is lifted, accumulated suspended funds are applied first to any determined overpayment and any interest under § 405.378, and then to any other obligation to CMS or HHS. Only the balance is released to the provider.
• If CMS ultimately determines an overpayment, the Medicare Administrative Contractor (currently Wellpoint Federal, formerly National Government Services) will issue a separate overpayment demand — that notice is appealable under standard Medicare appeal rights.

While the Suspension Is in Place

Two important details that surprise operators:

• Claims continue to be processed. Denials can still be issued and carry standard appeal rights under § 405.903(d). Keep filing claims and keep appealing denials.
• The suspension applies to claims in process, not just future claims. Anything already submitted that hasn’t paid out is frozen too.

The 60-Day Overpayment Rule Is Still Running

One trap the letter flags near the end: under § 1128J(d)(2) of the Social Security Act and 42 C.F.R. § 401.305, you are statutorily required to return any identified overpayment within 60 days, independent of this proceeding. If your rebuttal preparation uncovers overpayments in non-example claims, the 60-day clock is running. Pretending you didn’t see them is a False Claims Act liability, not just a compliance footnote.

Should You Use Counsel?

Yes. A suspension on credible allegation of fraud is a legal proceeding. Documentation review benefits from experienced compliance consultants. The narrative section benefits from healthcare regulatory counsel. The combination of the two — a consultant who has seen what UPIC reviewers reject plus an attorney who can frame the narrative against the specific regulations — is what the most successful rebuttals look like.

Further Reading

• CMS Pauses Medicare Payments for 447 California Hospices: What the Qlarant Letter Means
• The Live Discharge Rate Trap — How to Check Yours Before You’re Next
• Payments Frozen, Payroll Friday: A Cash-Flow Survival Playbook
• 42 C.F.R. § 405.372 — Proceeding for Suspension of Payment (eCFR)
• 42 C.F.R. § 405.375 — Notice of Rebuttal Response (Cornell LII)

The Bottom Line

The Qlarant rebuttal process is narrow, strict, and not appealable. The hospices that come out of the April 2026 sweep with their suspensions lifted will be the ones whose rebuttals answer each example claim with complete, regulation-aligned documentation within 15 business days. Everything else is noise.