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Compliance Consulting · Service 2

Clinical Denial Pattern Audit

Physician-authored review of a 20–50 claim sample assessing whether the plan's medical necessity criteria were applied in a clinically defensible and consistent manner — framed for ERISA fiduciary defense or DOL audit response.

$4,000 – $10,000 · 15–20 business days · Pattern analysis, not individual adjudication
Why this credential is the exact fit

This service is directly aligned with the founding physician’s payer-side utilization-review work: reviewing claims, reading denial rationales, and assessing whether criteria were properly applied. The reframe is purely contextual — instead of making the denial decision, the physician audits whether prior decisions were defensible. The analytical muscle is identical. InterQual and MCG fluency is the exact qualification. Understanding how criteria are interpreted in practice — not just what they say on paper — requires operational experience.

What the deliverable contains

  • 01
    Sample Methodology Description

    How the claim sample was selected, what was included and excluded, what denial types and condition categories are represented, and what criteria sets are assessed.

  • 02
    Denial Rationale Categorization

    Grouping of sampled denials by type, criteria cited, and condition category — establishing the pattern baseline before mismatch analysis begins.

  • 03
    Criteria Mismatch Analysis

    Where the denial rationale does not align with the criteria the plan claims to apply — specific examples showing "criteria cited in denial letter" vs. "criteria actually applicable per plan's own clinical policy."

  • 04
    Clinical Defensibility Assessment

    Per denial category: Defensible / Questionable / Indefensible — with physician narrative explaining the clinical basis for each classification.

  • 05
    Pattern Summary and Risk Grading

    Physician summary of the systematic findings — whether the pattern reflects appropriate clinical judgment, systematic over-restriction, inconsistent application, or criteria misapplication across the sample.

  • 06
    Physician Narrative Section

    Written physician interpretation of the pattern findings — the section a pure actuarial or compliance analyst cannot produce. Framed for submission to counsel, inclusion in a DOL response, or use in fiduciary defense proceedings.

When to use this

You represent an employer plan sponsor facing a DOL audit or member class action and need a physician to assess whether the TPA's denial decisions were clinically defensible.

A self-insured plan client wants pre-litigation risk assessment before exposure becomes litigation — a physician audit of denial patterns before the DOL asks for the same records.

You are defending a TPA or ASO administrator facing fiduciary breach claims and need independent physician documentation that criteria application was clinically sound.

A regional carrier is facing an MHPAEA enforcement action and the behavioral health denial pattern — not just the written criteria — is under scrutiny.

Fee Range
$4,000–$10,000
Sample size & complexity
Turnaround
15–20 days
From receipt of complete docs
Sample Size
20–50 claims
Pattern analysis

Required inputs from client: De-identified denial letters, clinical criteria cited in denials, plan's clinical policy manual, member clinical records if available.

This is not: a re-adjudication of individual claims, a recommendation to overturn or uphold specific denials, or a legal opinion on ERISA fiduciary breach. That conclusion belongs to retained counsel.

Request Clinical Denial Pattern Audit →
Specimen

See the Clinical Denial Pattern Audit specimen

Abbreviated 10-claim specimen with fictional data. Criteria mismatch table, defensibility grading, pattern identification — methodology demonstrated.

View Specimen →
Also available

Need plan-level criteria analysis too?

The MHPAEA Parity Review examines how the plan's written criteria compare across BH and M/S — the criteria design question, not the application pattern question.

MHPAEA Parity Review →

Ready to proceed?

Send only the plan type, denial sample size, and general scope first — no documents required to start.

Request Case Review