What is an across-the-board denial?
An across-the-board denial is a payment refusal applied in bulk: the health plan uses the same rule to cut a percentage or a group of items across many claims, without examining each item. Brazilian billing teams call it denial linear because of that uniformity. The claim is not cut for what is wrong with it, but for belonging to a category.
It is a market classification, like the split between administrative and clinical denials. RN 503/2022, issued by the Agência Nacional de Saúde Suplementar (ANS), Brazil's federal regulator of private health plans, is the main rule on denials in contracts, and it does not use the expression [1]. The full picture of denial types is in the guide Claim denials, and each type is detailed in the guide Types of denials.
In practice, across-the-board denials tend to take four forms (illustrative examples):
- Flat percentage. A standard discount on a group of items, such as supplies or fees, on every claim for one type of care.
- Cap with no exceptions. Every inpatient day beyond a set number is cut, without looking at the clinical justification for each stay.
- Reduction to a reference price. Every item billed above a price list is cut down to it, even when the contract sets a different price for that item.
- Generic message in series. The same reason, with the same short justification, repeated across dozens of claims in one batch.
Blanket cut or contract rule: the difference that shapes the appeal
Not every denial applied in bulk is improper. If the contract says a fee is included in a bundle, the health plan can remove that fee from every claim under that bundle. In that case, it is applying the contract, and an appeal only succeeds if the item does not fit the rule.
The difference lies in the basis. RN 503/2022 requires the audit routine to be written into the contract, including the situations in which the provider may be denied (art. 14, I) [1]. A cut that matches no written situation loses its contractual reference, and that gap is the first argument of the appeal.
| Situation | How to recognize it | Basis for the appeal |
|---|---|---|
| Contract rule applied correctly | A clause or annex provides for the cut and the item fits it | Usually do not appeal; fix the billing at the source |
| Contract rule applied to an item that does not fit | The clause exists, but the item falls outside it (another code, another bundle, a listed exception) | Item by item, showing why the rule does not reach that item |
| Cut with no situation listed in the contract | No clause provides for the percentage, cap or reduction applied | RN 503/2022, art. 14, I, and the contract's pricing clauses |
| Missing or generic justification | Repeated reason that does not explain the item, or no access to audit criteria | RN 503/2022, art. 5, V: formal request for the justifications |
| Denial that blocks the appeal | Appeal refused in the system, or a rule that bars appeals of certain cuts | RN 503/2022, art. 5, VI |
What happens when the contract is silent is not written in the rule. RN 503/2022 sets what the contract must contain and provides for administrative sanctions against health plans that break its rules (art. 21) [1]. Whether a cut with no contractual basis is owed or not is a contract matter and, ultimately, one for the courts.
What does RN 503/2022 require on denials?
RN 503/2022 does not list permitted denials or set deadlines in days. It requires those rules to be written into the contract, in line with article 17-A of Law 9,656/1998 (the Health Plans Law), which requires a written contract with billing and payment deadlines and procedures [1][3].
| What the rule says | Article [1] | Practical effect on across-the-board denials |
|---|---|---|
| The administrative and clinical audit routine must be written into the contract, with the situations that may lead to a denial | Art. 14, I | The cut must match a situation in the contract; if it does not, the hospital appeals based on the contract itself |
| The contract must set the deadlines to appeal, to respond and to pay after a denial is reversed | Art. 14, II | The hospital knows how long it has to appeal and when it should receive reversed amounts |
| The appeal deadline must equal the response deadline | Art. 14, sole paragraph | A bulk appeal does not give the health plan more time to respond |
| Clauses that prevent access to audit routines and denial justifications are banned | Art. 5, V | The hospital can demand the criterion behind the cut and the justification for each item |
| Clauses that prevent appeals are banned | Art. 5, VI | No cut is “beyond appeal” because of a contract clause |
| Bans V and VI apply only when claims are sent in the current TISS standard | Art. 5, sole paragraph | Claims outside the standard weaken both protections |
| Audits must follow the rules of the professional councils | Art. 14, III | A clinical cut requires a qualified auditor and a rationale |
The rule does not literally say denials must be made item by item. But the TISS standard (Brazil's mandatory claims data exchange standard), which governs the statements health plans send back, requires the claim review statement (demonstrativo de análise de conta) to list the denied items on reviewed claims, each with a reason code from table 38 of TUSS, the standard's terminology [4][5]. The health plan's response is structured by item, and the appeal can be too.
Law 9,656/1998 and RN 503/2022 remain the basis. The comment period for Public Consultation 170, which proposes a new rule for these contracts, closed in July 2026 [6]. Among other points, the draft provides for access to the audit information and documents behind a denial and for payment of the undisputed part of the claim [7]. Details are in the guide RN 503/2022: the payer contract.
How do you spot an across-the-board denial on the statement?
An across-the-board denial shows up as a pattern, not as one claim. The starting point is the claim review statement, which lists each denied item with its reason code [4].
Three signs often point to a blanket cut:
- Uniformity. The same percentage, or the same reduction, appears on claims for different patients, procedures and care teams.
- Generic reason. The code or justification does not explain the item. TUSS table 38 includes messages such as 3040 (clinical denial, to be specified) and 3217 (billing with no justification or insufficient justification) [5]. When the same message repeats in series, with nothing added, request item-level justification.
- Detachment from the contract. The amount cut matches no clause, annex or negotiated price list.
To see the pattern, the hospital must cross denials by health plan, reason code, item group and period. The ANS also tracks denials: its Denial Indicators Dashboard shows initial and final denials by health plan, but the agency does not receive the reason for each denial [8]. The internal map of reasons belongs to the hospital. The guide Denial management shows how to build it, and the guide TISS denial codes explains each code.
How to contest an across-the-board denial, step by step
Contesting an across-the-board denial works in four layers. The first two are handled in the appeal (recurso de glosa); the last two, in the relationship with the health plan.
1. Item by item. Even if the cut was made in bulk, the appeal should address each denied item, with the stated reason and the evidence that overturns it: authorization, medical record, operative report, invoice or contract price list. A generic appeal against “the percentage” tends to get an equally generic answer. The step-by-step is in the guide Denial appeals.
2. Contract. For each cut, cite the clause that supports the amount billed, or record that the cut matches no denial situation listed in the contract, as RN 503/2022, art. 14, I, requires [1]. Attach the pricing clause, the bundle annex or the negotiated price list.
3. Standard and deadlines. Send the appeal through the TISS denial appeal message and keep the protocol number, which proves receipt [4]. Track the health plan's response deadline, which must equal your appeal deadline [1]. If justifications do not arrive, request them formally under art. 5, V [1].
4. Negotiation. If the same cut keeps coming back, individual appeals are not enough. Take the pattern, with figures by period and item, to contract management with the health plan, and propose the clause that should exist. The guide Hospital-payer contract shows what to negotiate.
| Layer | Question to answer | Typical evidence | Who leads |
|---|---|---|---|
| Item | Was the item performed, recorded and billed correctly? | Medical record, authorization, invoice, TUSS code | Billing and internal audit |
| Contract | Is there a written denial situation for this cut? | Pricing clause, bundle annex, negotiated price list | Billing and contract management |
| Standard and deadlines | Was the appeal sent in TISS, on time, with a protocol number? | Appeal protocol, statement, deadline calculation | Billing |
| Negotiation | Is the cut recurring and does it need to change in the contract? | Historical series by health plan, code and item group | Revenue management, leadership and legal |
When the administrative appeal runs out, the path continues through the contract: the penalties it provides for (RN 503/2022, art. 4, V) [1] and, if needed, the courts, which call for case-by-case legal advice.
What the contract should say to prevent blanket cuts
The best defense against across-the-board denials is a contract that leaves no room for them. At review or renewal, check that the contract includes:
- Denial situations described by item type, not just a generic reference to “health plan audit” (art. 14, I) [1].
- Bundles with a detailed composition, stating what is included and what is billed separately. The guide Hospital bundled pricing covers this.
- The three deadlines in art. 14, II, with parity between appeal and response and a payment deadline after reversal [1].
- How the hospital accesses justifications and audit criteria, as art. 5, V provides [1].
- Penalties for breaking the denial and payment rules, a mandatory clause (art. 4, V) [1].
A full clause checklist is in the guide RN 503/2022: the payer contract.
What we see in operations
At Accrua, a flat-rate denial (a blanket denial) shows up first as a pattern, not as a single item. When we reconcile claim review statements in Accrua OS, we group denials by health plan, code and percentage and look for repetition: the same cut on different claims, the same code in series, the same percentage applied to unrelated items.
Once the pattern shows, the appeal goes item by item. The agent drafts it with the evidence for each denied item and the contract clause on audit and denial grounds; a biller or auditor reviews and decides. A generic appeal against a blanket cut gives the health plan room to answer generically too.
The consolidated pattern, with claims, amounts and response times, becomes material for the contract conversation. RN 503/2022 requires the contract to describe denial grounds and deadlines; we bring the hospital what its history shows, so the negotiation starts from the claims. Changing a contract is always a person's decision.
Where to start
- Cross the last 6 to 12 months of denials by health plan, reason code, item group and percentage cut, and flag the patterns that repeat.
- Check each pattern against the contract and separate contract rules from cuts with no written denial situation.
- Appeal item by item in the TISS standard, with evidence and clause, and track the health plan's response deadline.
- Formally request justifications when the reason is generic or repeated in series.
- Take recurring patterns to contract negotiation, with figures, and propose the missing clauses.