Physician-Led Utilization Management & Advisory Services
HEALTH PLAN COVERAGE POLICY

Payer Medical Policy Review & Applicability

Medical policies translate benefit design, coverage requirements, evidence, and plan-specific rules into reviewable clinical conditions. Physician review identifies the policy that actually governs the member and requested service, then applies it to the complete medical record.

The first question is not whether the patient meets a policy. It is whether the correct policy has been identified.Review should confirm the payer and product, governing authority, policy scope, and the version effective for the date of service or determination under review before applying requirements to the record.
The governing coverage framework comes first.A commercial policy, Medicare Advantage policy, Medicaid requirement, or delegated medical-group policy cannot be treated as interchangeable. Product, benefit, jurisdiction, effective date, and controlling law matter.
THE FIRST QUESTION

Which coverage policy actually governs this request?

The same service may be reviewed differently depending on the member's product and controlling coverage requirements. A defensible determination begins by identifying the correct benefit and policy framework before applying clinical criteria.

COMMERCIAL

Health plan medical policy

Plan-specific coverage requirements may define covered indications, prerequisites, exclusions, documentation requirements, and other conditions for a requested service.

Review implicationVerify the member's product, applicable benefit, current policy version, and required clinical documentation.
MEDICARE ADVANTAGE

Medicare rules remain foundational

MA organizations must follow applicable Medicare coverage criteria and may use internal coverage criteria only within the limits permitted by CMS when Medicare coverage criteria are not fully established.

Review implicationIdentify controlling NCD/LCD and other Medicare coverage rules first; do not allow plan criteria to supersede applicable Medicare requirements.
MEDICAID

State and managed-care requirements

Coverage may depend on the applicable state Medicaid program, managed-care contract, benefit, and plan policy.

Review implicationConfirm the correct state/program requirements and current policy before making the clinical determination.
DELEGATED UM

Medical group or IPA policy framework

Delegated organizations may perform utilization review within contracted responsibilities while remaining subject to the applicable benefit, payer requirements, delegation terms, and governing law.

Review implicationClarify who holds the determination authority and which payer or delegated policy controls the review.
COVERAGE HIERARCHY

Clinical criteria support the review. They do not override controlling coverage requirements.

Licensed decision-support criteria, specialty guidance, and published evidence may inform medical-necessity analysis when authorized and relevant, but the reviewer must first identify the benefit and coverage rules governing the request.

MEDICARE ADVANTAGE

Plan policy must be reconciled with Medicare coverage rules.

For Medicare Advantage, CMS requires plans to follow Traditional Medicare coverage criteria in applicable statutes, regulations, NCDs, and LCDs. When Medicare coverage criteria are not fully established, CMS permits the use of publicly accessible internal coverage criteria under specified conditions and evidence standards.

1

Start with Medicare

Determine whether a statute, regulation, NCD, LCD, or other applicable Traditional Medicare coverage criterion addresses the service.

2

Identify gaps

Determine whether Medicare criteria are fully established for the specific coverage question or whether additional permitted criteria may be needed.

3

Evaluate plan criteria

When permitted, confirm that internal criteria are current, publicly accessible, evidence-based, and used within CMS requirements.

4

Apply to the member

Match the governing requirements to the submitted clinical record and explain the material facts supporting the determination.

Important:Medicare Advantage is not simply commercial UM with a Medicare insurance card. Applicable Medicare coverage and patient-status requirements remain part of the governing framework.
PHYSICIAN-ADVISOR WORKFLOW

From benefit and policy to a patient-specific determination.

Policy application is disciplined: identify the member and service, locate the governing policy, verify the policy version, and connect each material requirement to the medical record.

1

Confirm product & benefit

Identify payer, line of business, member product, requested service, and relevant benefit.

2

Find governing policy

Locate the current applicable Medicare, Medicaid, health-plan, or delegated coverage policy.

3

Verify version & scope

Check effective date, jurisdiction, product applicability, definitions, prerequisites, and exclusions.

4

Match the clinical record

Assess diagnosis, severity, prior treatment, diagnostic findings, contraindications, alternatives, and other required facts.

5

Document clear reasoning

State which requirements are met or not met and identify the material clinical facts driving the determination.

ILLUSTRATIVE REVIEW

Advanced imaging or specialty treatment request

A member is referred for an advanced diagnostic study or specialty therapy. The reviewer first confirms the member's product and governing coverage policy, then evaluates whether required prior testing, treatment failure, clinical findings, contraindications, or other policy conditions are documented.

If the request involves Medicare Advantage, the reviewer additionally determines whether Traditional Medicare coverage criteria govern the service and whether any plan-specific criteria are permissible for the unresolved coverage question.

CURRENT-SOURCE PRINCIPLE

Medical policies and coverage criteria change.

Use the current policy version applicable to the member, product, date of service, and jurisdiction. For Medicare Advantage, verify current CMS coverage and utilization-management requirements rather than relying on a commercial-policy framework.

CMS Medicare Advantage Resources ↗

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POLICY APPLICABILITY PATHWAY

Identify the governing policy before testing the clinical record.

Policy requirements structure the review. They do not replace patient-specific physician judgment.

01

Identify payer & product

Confirm the applicable benefit, product, delegated arrangement, and review context.

02

Identify governing authority

Determine the controlling benefit terms, Medicare authority when relevant, payer policy, and delegated requirements.

03

Confirm version & effective date

Use the policy applicable to the date of service or determination under review rather than automatically applying the current version.

04

Determine applicability

Confirm that diagnosis, service, indication, setting, benefit, and policy scope match the question under review.

05

Apply requirements to the record

Evaluate whether the submitted clinical documentation supports each material requirement.

06

Make the physician determination

Explain which requirements are met or not met and identify the patient-specific clinical facts driving the conclusion.