Basis Appeals

PR-96: Non-covered charge(s), patient responsibility

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PR-96: Non-covered charge(s), patient responsibility

PR-96 is the member-responsibility flavor of the non-covered denial. The plan is telling you the service is not covered, and you owe the amount to the provider. It is worth checking before you pay, because sometimes the plan is wrong or an exception applies.

What your letter emphasized

  • The specific plan provision cited by the plan
  • Any exception (medical necessity, ACA preventive service, network-adequacy failure)
  • Regulatory protections (essential health benefits, MHPAEA, preventive services)
  • Whether the coverage exclusion is genuinely applicable to the service you received

What the insurer's likely response is

Reversal. If the plan applied the wrong exclusion or the service actually is covered, they reverse.

Detailed citation of exclusion. The plan points to a specific plan-document exclusion. Read it carefully.

Upheld with one-liner. Insufficient response under 29 CFR 2560.503-1(g)(1); push back.

Alternative coverage offered. Plan offers to cover a substitute.

How to handle each outcome

Reversal: confirm reprocessing and that you no longer owe.

Exclusion citation: if the citation is clear and applies, your appeal may not succeed on plan-document grounds. Consider whether federal law overrides (MHPAEA, ACA essential benefits, ACA preventive services).

One-liner uphold: file second-level appeal citing the plan's obligation to identify a specific plan provision.

Alternative offered: decide if the alternative works.

Common PR-96 arguments

ACA preventive service. If the service is on the ACA preventive-service list and you are in the recommended population, cite 42 USC 300gg-13 and demand no cost sharing.

MHPAEA parity. For mental health or substance use disorder services, the coverage exclusion may be a parity violation if a comparable medical service is covered. Cite 42 USC 300gg-26.

Essential health benefits. Non-grandfathered plans cannot exclude essential health benefits. If your denied service is essential (hospitalization, prescription drugs, mental health, and so on), cite 42 USC 18022(b) and argue the exclusion is invalid.

Network adequacy. If your plan is HMO and the out-of-network exclusion is causing PR-96, argue network adequacy (no in-network provider available).

Genuine coverage exclusion. If the plan document plainly excludes the service and no federal override applies, your appeal on this narrow question is weak.

What to gather

  • Your plan document
  • The full EOB
  • The provider's chart notes
  • Evidence for any exception argument (ACA preventive list reference, comparable medical service under MHPAEA)

Practical steps before appealing

Before you appeal, consider:

  • Ask the provider to write off the balance. Some providers will write off small member balances rather than pursue collections. Ask.
  • Set up a payment plan. Most providers offer payment plans without interest.
  • Apply for financial assistance. Hospitals must offer financial assistance under IRS Section 501(r) if the hospital is tax-exempt.
  • Verify the bill. Sometimes the provider is billing you before the plan has finished processing. Wait for the final EOB.

If none of those apply and the amount is large, appeal.

When to escalate

External review under ACA section 2719 applies if the denial has a medical-judgment component. Otherwise state DOI complaint is the right escalation for coverage disputes and network-adequacy problems.

When to negotiate the bill

Even if the plan does not reverse, you can negotiate the amount you actually pay. Providers routinely accept 40 to 60 percent of the billed amount for cash-pay settlements. Ask before you pay in full.

When to consider bankruptcy or dispute the debt

For very large PR-96 balances, especially in states with strong medical-debt consumer protections, consult a consumer-rights attorney or a nonprofit financial counselor. Do not let a large medical bill go to collections without exploring your options first.

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Not legal advice. Not medical advice. Basis Appeals is a document assistant.