What is a daily rate and fee denial?
It is a denial, full or partial, of the amount billed for the patient's days in a bed (the diária, or daily rate, similar to room and board) and for the use of hospital structure and services (the taxas, or facility fees, such as operating room, equipment and observation). The health plan (operadora) refuses payment when it finds the days were not authorized, do not match the clinical course, exceed the recorded length of stay or conflict with the contract.
It is a specific case of hospital claim denials, with one difference in proof. Daily rates and fees are proven with time: admission, transfer and discharge times, an authorization for each period and clinical notes that justify the stay. When the clock on the claim does not match the record or the authorization code, a denial follows.
Why do daily rates and fees weigh so much on the claim?
Daily rates and fees are the second-largest slice of revenue at Anahp hospitals. In Observatório Anahp 2025 (Anahp Observatory), with 2024 data, they made up 24.48% of gross revenue, behind only “other operating revenue” (26.13%) and ahead of drugs (21.34%) [1].
See the numbers as a table
| Revenue type | % of gross revenue (2024) |
|---|---|
| Other operating revenue (physician fees, packages etc.) | 26.13% |
| Daily rates and fees | 24.48% |
| Drugs | 21.34% |
| Supplies | 14.31% |
| OPME (implants) | 7.61% |
| Other service revenue | 4.53% |
| Donations | 0.84% |
| Medical gases | 0.76% |
On the claim, daily rates, fees and medical gases are billed with codes from TUSS table 18. TUSS (Unified Supplementary Health Terminology) is the code set of the TISS standard, the national data-exchange standard set by ANS, Brazil's health plan regulator; table 18 uses CNSaúde (the national health confederation) as its reference [5]. What each code includes is set in each payer contract, the topic of the guide Hospital daily rates and fees.
Average length of stay at Anahp hospitals fell from 4.29 days in 2022 to 3.76 days in 2025 [6]: with shorter stays, each denied day is a larger share of the days billed for each admission.
Daily rate denials tend to start at authorization
One cause is billing days beyond what the health plan authorized. The admission authorization code (senha) covers a number of days; if the patient stays longer, the hospital needs an extension before discharge. Without it, the extra days are denied with code 1917 [2].
The TISS standard has a dedicated form for this: the Request for Inpatient Stay Extension or Treatment Supplement, linked to the number of the initial Admission Request form (item 62.24 of the Organizational Component) [5]. Timing matters. Since 12/01/2025, table 38 includes code 3248 for a request made after discharge [2]. How to request the extension, and with what justification, is in the guide Inpatient stay extension.
The second cause is an expired authorization code, returned as 1414 “data de validade da senha expirada” (authorization code expired) [2]. No ANS rule sets that validity; it comes from the contract or the payer's manual, as the guide Expired authorization code explains.
The law protects the stay, not an unauthorized claim. Law 9,656/1998 bars limiting the length, maximum amount or number of hospital stays (art. 12, II, “a”), and Superior Court of Justice (STJ) Precedent 302 holds that a clause limiting hospital stays in time is abusive [3][7]. In the payer–hospital relationship, however, art. 17-A requires the contract to define which acts need authorization [3]. So the health plan may require an extension to pay the extra days, if the contract sets that routine.
Which codes appear on daily rate and fee denials?
These denials have their own codes in TUSS table 38, used by the health plan in authorization and billing responses [2][5]. Below are the main ones, quoted from the official ANS lookup on 10/17/2026, with an English gloss.
| Code | Table 38 description (gloss) | Typical cause | Document that answers it |
|---|---|---|---|
| 1917 | FALTA PRORROGAÇÃO PARA QUANTIDADE DE DIÁRIAS COBRADAS (no extension for days billed) | Days beyond the authorization | Approved extension; protocol of a timely request |
| 3248 | INTERNAÇÃO JÁ CONCLUÍDA, PRORROGAÇÃO NÃO PERMITIDA (stay closed, no extension) | Extension requested after discharge | Protocol proving the request before discharge |
| 1903 | PERMANÊNCIA HOSPITALAR INCOMPATÍVEL COM A EVOLUÇÃO CLÍNICA (stay inconsistent with clinical course) | Record does not justify the days | Daily physician and nursing progress notes |
| 1904 | PERMANÊNCIA HOSPITALAR INCOMPATÍVEL COM O PROCEDIMENTO AUTORIZADO (stay inconsistent with authorized procedure) | More days than expected for the procedure | Record of complication |
| 3189 | COBRANÇA DE ITEM ASSISTENCIAL EM QUANTIDADE INCOMPATÍVEL COM A PERMANÊNCIA HOSPITALAR (quantity inconsistent with length of stay) | More daily rates, daily fees or gas hours than time in hospital | Census, admission and discharge times; gas orders and administration times |
| 3200 | COBRANÇA DE ITEM ASSISTENCIAL SEM O REGISTRO DE PERMANÊNCIA COMPATÍVEL (no matching length-of-stay record) | Item billed without a stay record that supports it | Census and notes for the period |
| 3183 | COBRANÇA DE ITEM ASSISTENCIAL COM PERMANÊNCIA MENOR QUE O PERÍODO ESTIPULADO (stay shorter than the required period) | Observation below the contract minimum | Observation entry and exit times |
| 3188 | COBRANÇA DE ITEM ASSISTENCIAL EM PERMANÊNCIA HOSPITALAR NÃO AUTORIZADA (item billed during unauthorized stay) | Items billed on days without authorization | Extension for the period |
Codes 1917, 3248, 3188, 3189, 3200 and 3183 have been in force since 12/01/2025, and 1903 and 1904 since 11/16/2006 [2]. The old daily-rate, fee and gas messages (such as 1912, 1914, 2307, 2408 and 2409) are not in TUSS version 202607; the table uses generic care-item messages instead [2]. The meaning of each message is in the guide TISS denial codes.
A fee outside the contract is a contract denial, not a records denial
Fee denials can start in the contract, not at the bedside. Law 9,656/1998 requires a written payer–provider contract with service prices and adjustment criteria [3], and RN 503/2022 requires it to set the grounds for denial [4]. A fee not in the negotiated table, included in another item or billed at a different price tends to be denied.
Three situations lead to this kind of denial:
- Fee outside the contract table. Equipment or service use the health plan did not accept in negotiation. Prevention: set up only accepted fees per payer.
- Fee included in the daily rate or package. If the daily rate includes nursing and linen, or the package includes the operating room and recovery, a separate charge is denied. Packages already accounted for 13.1% of health plans' care expenses in 2025, up from 3.8% in 2019, per ANS data compiled in Anahp reports [6]. Table 38 has a specific message for this case: 3211 “COBRANÇA DE PROCEDIMENTO/ITEM ASSISTENCIAL INCLUSO NO PACOTE NEGOCIADO” (procedure or item included in the negotiated package), in effect since 12/01/2025 [2]. See the guide Hospital bundled pricing.
- Price above the negotiated rate. Code 1705 “valor apresentado a maior” (amount billed above the agreed value) is the typical return when the system table lags the contract [2].
In these cases, the appeal relies on the contract clause or price schedule, not the medical record.
Cause, prevention and proof: the pre-billing check
One way to avoid these denials is to check the claim against the clock before submission.
| Origin | Check question | Prevention | Typical code if it fails |
|---|---|---|---|
| Authorization | Are the days billed covered by the authorization and extensions? | Expiry alert; extension requested before the last authorized day | 1917, 3248, 1414 |
| Clinical record | Do the notes justify each day and each ICU day? | Daily physician and nursing notes; ICU criteria recorded | 1903, 1904 |
| Time | Do daily rates, fees and gases fit the stay? | Automatic quantity vs. admission and discharge check | 3189, 3200 |
| Contract | Is the fee in the payer table, outside the package and at the negotiated price? | Payer tables set up and reviewed at each adjustment | 1705, 3211 |
| Emergency room | Does observation have entry and exit times? | Mandatory time stamp in the system | 3183 |
Two routines support this check: a daily inpatient list with authorized days, elapsed days and the extension deadline; and a quantity rule that keeps any claim from leaving with more daily rates, fees or gas hours than the stay.
How to appeal a daily rate or fee denial
The appeal answers the code returned. The TISS standard provides specific denial appeal messages (appeal, protocol, status request and response) [5].
- Read the code and justification. RN 503/2022 bars the health plan from blocking access to denial justifications or blocking the appeal, provided billing follows the current TISS version [4].
- Identify the origin and attach the proof. Authorization (1917, 3248): protocol of the timely extension request. Clinical record (1903, 1904): notes for the denied days. Contract: clause or price schedule.
- Meet the contract deadline. RN 503/2022 requires deadlines for appeal, response and payment after reversal, with the appeal deadline equal to the response deadline [4]. The rule does not set the number of days.
- Fix valid denials at the source, so the error does not repeat.
ICU days and long stays have their own points in the guide ICU and long-stay denials; the general process is in Denial appeal.
What we see in operations
At Accrua, room and board charges and facility fees are checked against three sources before submission: the authorization number and approved extensions, the length of stay documented in the medical record, and what the contract includes in each daily rate or bundle. Accrua OS runs this check on every health plan claim, with the contract, the current price table and that health plan's denial history already loaded.
Two alerts get priority. The first is a number of inpatient days above what was authorized while the patient is still admitted, when there is still time to request an extension before discharge. The second is a fee billed separately when the contract already includes it in the daily rate or bundle: a contract denial that no medical record can fix.
Removing or keeping an item that changes the value is the biller's or auditor's decision, with the clause and the record side by side. When the same fee keeps going out against the contract, we fix the rule in the hospital's charge master, at the source.
Where to start
- Pull recent daily rate and fee denials by table 38 code, payer and inpatient unit.
- Build a daily inpatient list with authorized days, elapsed days and the extension deadline.
- Create a quantity rule that blocks claims with daily rates, fees or gases beyond the stay.
- Review each payer's fee table against the contract and packages, and update it at every adjustment.
- Organize appeals by origin: authorization, clinical record or contract, with the document that answers each code.