ARCLIGHT

Analysis / April 2026

Rationale Drift in Medicare Audit Appeals

How denial rationales shift across Medicare audit stages, weakening consistency, accountability, and a provider's opportunity to respond.

Overview

Research and evidence for a more accountable system.

Rationale drift occurs when the basis for denying a claim changes across audit and appeal stages without a clear account of why the earlier rationale was abandoned. This analysis explains how shifting rationales can undermine consistent adjudication, force providers to answer a moving target, and make accurate contractor-performance measurement more difficult.

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