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Denial appeal deadlines: what RN 503/2022 says

In Brazil, the denial appeal deadline for a denial is set in each contract. What the regulator requires on appeal, response and payment deadlines, and how to track them by health plan.

By Published on 10 min read

What is the deadline to appeal a denial?

The deadline to appeal a denial is whatever the contract between the hospital and each health plan (operadora) says. Neither Law 9,656/1998 nor RN 503/2022, a normative resolution of the National Agency for Supplementary Health (Agência Nacional de Saúde Suplementar, ANS), sets a number of days to contest a denial [1][2].

RN 503/2022 governs written contracts between health plans and providers. Art. 14 requires the contract to describe the administrative and clinical audit routine, the cases that can lead to a denial and three deadlines: for the provider to appeal, for the health plan to respond, and for the health plan to pay once the denial is reversed [1]. A denial is the full or partial refusal to pay items on a claim; the overview is in the guide Hospital claim denials.

So the deadline varies from one health plan to another.

The five deadlines the rule requires in the contract

The law and RN 503 require five payment-related deadlines in the contract, none with a number of days [1][2].

The denial deadlines the contract must set (RN 503/2022)Timeline: claim submission, payment and denial on the statement; hospital appeal, health plan response within the same number of days, and payment after reversal. The rule sets no number of days for any of these deadlines. The deadlines the contract must setNone has a number of days in the rule: each contract sets its own Claim submitted Statement with denial Appeal logged (TISS) Health plan response Reversed amount paid Payment deadline Law 9,656, art. 17-A; RN 503, art. 13 Appeal deadline: X days RN 503, art. 14, II Response deadline: same X days RN 503, art. 14, sole paragraph Post-reversal deadline RN 503, art. 14, II Parity: X = X Source: ANS — RN 503/2022, arts. 13 and 14; Law 9,656/1998, art. 17-A, § 2, II. Start date and day count (calendar or business days) are left to the contract.
Source: ANS — RN 503/2022, arts. 13 and 14; Law 9,656/1998, art. 17-A, § 2, II. The claim and denial deadlines the contract must set; the rule sets no number of days for any of them, and the health plan's response deadline must equal the appeal deadline. Produced by Accrua.
View the timeline as a table
BetweenDeadlineWhere it is requiredDays in the rule
Claim submitted → statementPaymentLaw 9,656/1998, art. 17-A, § 2, II; RN 503, art. 13None set
Statement → appeal loggedAppeal (X days)RN 503, art. 14, IINone set
Appeal → health plan responseResponse (same X days)RN 503, art. 14, sole paragraphNone set; equal to the appeal deadline
Response → reversed amount paidPost-reversal paymentRN 503, art. 14, IINone set
DeadlineWhere it is requiredDoes the rule set days?What the contract must state
Claim submission (billing)Law 9,656/1998, art. 17-A, § 2, II; RN 503, art. 13NoDeadline and method for each type of claim
Claim paymentLaw 9,656/1998, art. 17-A, § 2, II; RN 503, art. 13NoPayment deadline and when the count starts
Denial appealRN 503, art. 14, IINoDays for the hospital to appeal and the start date
Health plan responseRN 503, art. 14, II and sole paragraphNo, but it must equal the appeal deadlineThe same number of days given to the hospital
Payment after reversalRN 503, art. 14, IINoDeadline to pay the reversed amount

The deadlines to answer authorization requests (art. 15) and to give notice of termination (art. 16) have no number either [1]. The only deadline in days, in article 17-A of the law and in RN 503, is for negotiating the annual adjustment: 90 days from the start of the year (Law 9,656/1998, art. 17-A, § 3; RN 503, art. 12, § 3) [1][2].

A clause-by-clause review of the rest of the contract is in the guide RN 503/2022: what the payer contract must say.

How does parity between appeal and response work?

Parity means the hospital and the health plan get the same number of days: one to appeal, the other to respond to the appeal (art. 14, sole paragraph) [1]. If the contract gives the hospital 30 days, the health plan has 30 days to respond (illustrative example).

With 15 days for the hospital and 60 for the health plan, the contract is out of line with the rule (illustrative example).

The rule does not say when each deadline starts or whether days are calendar or business days. These points are left to the contract:

  • Appeal start date: for example, the date the claim review statement is made available. It lists the denied items for each claim form [4].
  • Response start date: the appeal's protocol date. In the TISS standard (Troca de Informação de Saúde Suplementar, Brazil's mandatory health plan data exchange standard), receipt of an appeal generates a protocol number that proves delivery [4].
  • Day count: calendar or business days, the same for both parties.
  • Start date for payment after reversal: the date of the response that accepts the appeal.

The step-by-step submission is in the guide Denial appeals.

Rule, TISS code and market practice: what is what

Different sources talk about the deadline, with different weight. Only the first is a regulatory requirement.

SourceWhat it says about the deadlineWeight for the hospital
Law 9,656/1998 and RN 503/2022The contract must set the deadlines; appeal equals responseMandatory; noncompliance exposes the health plan to ANS sanctions (RN 503, art. 21) [1]
TUSS table 38Codes to report a denial for a missed deadlineStandardizes the message; does not create or change a deadline
Each contract's clauseThe number of days and how they are countedThe deadline that applies to that health plan
“Market” ranges (30, 60, 90 days)Figures repeated in industry contentNo regulatory basis; they do not replace the contract

Deadline codes in table 38. Table 38 of TUSS (Terminologia Unificada da Saúde Suplementar, the unified terminology for Brazilian health plans) lists the messages used to justify a denial. On the official ANS database, on October 17, 2026 [3]:

  • 2909, “deadline for requesting a denial appeal has expired”: in effect since 04/01/2013.
  • 2907, “180-day deadline for requesting a review exceeded”: not in TUSS version 202607 (official ANS spreadsheet); in the online lookup it shows no effective, implementation or end dates. The number 180 appears only in the code's name.
  • 3214, “claim billed after the deadline set in the provider contract”: in effect since 12/01/2025, with implementation by 06/30/2026. It refers to claim submission.

The “180 days” in a code's name is not a rule: the contract deadline applies. The other codes are in the guide TISS denial codes.

Rules cited by mistake. The appeal deadline is sometimes attributed to RN 395/2016, which was replaced by RN 623/2024. That rule covers requests from plan members, and ANS states that it does not govern requests from providers [5].

What Anahp says. The 2025 contracting manual of the National Association of Private Hospitals (Associação Nacional de Hospitais Privados, Anahp) for hospitals and health plans notes that ANS sets no payment deadlines and suggests considering automatic extension of billing deadlines when systems are unstable [7]. It is a recommendation, not a regulatory requirement.

What if the contract sets no deadline?

A contract without the denial deadlines does not comply with RN 503, and the party answerable to ANS is the health plan (art. 21) [1]. The gap, however, gives the hospital no automatic number of days: the rule has no default deadline.

The Anahp manual suggests escalating disagreements in stages: a meeting, written notice and an out-of-court notice with a deadline for the response [7]. Three steps reduce the risk:

  1. Record the gap in writing to the health plan and request an amendment with the three denial deadlines and parity.
  2. Appeal early, without waiting for a definition, and keep the TISS protocol for every appeal.
  3. Submit claims in the current TISS version. RN 503 forbids the health plan from blocking appeals or access to denial justifications, but only when billing follows that standard (art. 5, V and VI, and sole paragraph) [1].

Collecting late payments is covered in the Late payment by health plans guide.

How to track deadlines by health plan

Different deadlines in each contract call for a single tracking table, reviewed at each renewal. The template below uses the rule's five deadlines and the start dates.

FieldHealth plan A (illustrative example)Health plan BHealth plan C
Contract clause and versionClause 9, 2025 amendment
Claim submission deadline30 days from discharge
Payment deadline30 days from claim protocol
Denial appeal deadline60 calendar days
Appeal start dateStatement made available
Health plan response deadline60 calendar days (parity)
Payment after reversalNext payment cycle
Parity respected?Yes
Appeals rejected for deadline (code 2909) this month0

Values in the “Health plan A” column are illustrative.

Three routines make the table useful:

  • Due-date alert. Each denial gets its appeal deadline when the statement is imported.
  • Response alert. Each logged appeal gets the health plan's response deadline; once it passes, the hospital sends the status request provided in TISS [4] and records the delay.
  • Missed-deadline indicator. Appeals rejected with code 2909, by health plan, show the denial lost only because of the deadline.

To compare health plans, the ANS Denial Indicators Dashboard (Painel de Indicadores de Glosa) shows each plan's average payment time, in days between the claim protocol and the last payment of each closed claim form [8]. The cash effect of delays is in the guide Hospital average collection period.

What may change with Public Consultation 170/2026

ANS Public Consultation 170/2026 discussed a rule that would replace RN 503, with input accepted until July 3, 2026. As of October 17, 2026, the final text had not been published [9].

The draft proposes paying the undisputed part of a partially denied claim without waiting for the appeal review [9]. It is not yet known whether the final text will keep parity between appeal and response. Until publication, RN 503/2022 and each contract's deadlines apply.

What we see in operations

At Accrua, the deadlines in each contract are loaded into Accrua OS alongside the price table, the authorization rule and that health plan's denial history. That is what makes it possible to track what RN 503/2022 leaves to the parties: the deadline to contest, the deadline for the health plan to respond and the deadline to pay after a reversal.

Agents track the deadline and status of each denial and draft the appeal with the evidence the health plan asks for, leaving time for a person to review it. Dropping an appeal or accepting a denial is never automatic: a biller or auditor decides, with everything consolidated and the source in view.

When we review a hospital's contracts, we check whether all three deadlines are written down and whether the time to contest matches the health plan's time to respond. A contract with no deadline or uneven deadlines becomes a negotiation item. A denial rejected because the appeal window expired, code 2909, is treated as a process failure to fix.

Where to start

  1. Collect the deadline clause from each active contract and amendment.
  2. Build the tracking table with the five deadlines, start dates and day count for each health plan.
  3. Flag gaps and unequal deadlines and take them to the next renewal or price negotiation.
  4. Set alerts for appeal and response deadlines based on the statement date and the TISS protocol.
  5. Review monthly the appeals rejected for missed deadlines (code 2909) and the actual payment time after reversal, by health plan.

Frequently asked questions about denial appeal deadlines

What is the denial appeal deadline under RN 503/2022?

RN 503/2022 sets no number of days. It requires the contract between the hospital and the health plan to set the appeal deadline and makes it equal to the health plan's response deadline.

Is there a 180-day deadline to appeal a denial?

Not in the rule. The number appears in the name of code 2907 in TUSS table 38, which is not in version 202607 of the official ANS table. The deadline that applies is the one in each health plan's contract.

How long does the health plan have to respond to an appeal?

The same number of days the contract gives the hospital to appeal. Parity is in the sole paragraph of art. 14 of RN 503/2022.

Can the health plan reject an appeal sent after the deadline?

Yes, if the contract deadline has passed. The rejection usually comes with code 2909 from TUSS table 38, “deadline for requesting a denial appeal has expired”.

What if the contract has no appeal deadline?

Record the gap in writing, request an amendment with the three deadlines and parity, appeal without delay and keep the TISS protocol.

Sources

  1. ANS — Resolução Normativa nº 503, de 30 de março de 2022 (Normative Resolution 503 of March 30, 2022, on contracts between health plans and providers), arts. 4, 5, 12, 13, 14, 15, 16, 20 and 21.
  2. Lei nº 9.656/1998 (Law 9,656/1998, health plans), art. 17-A, §§ 2 and 3, added by Law 13,003/2014.
  3. ANS — Terminologia TUSS, tabela 38 (TUSS terminology, table 38: TISS messages), codes 2909 and 3214 checked in version 202607 (official ANS spreadsheet “TUSS - Demais terminologias”) on 10/18/2026; code 2907 seen only in the online lookup (OCL, 10/17/2026).
  4. ANS — Padrão TISS: Componente Organizacional (TISS standard: Organizational Component), version 202609 (September 2026), items 51, 55 and 56.
  5. ANS — Perguntas e respostas sobre a RN 623/2024 (FAQ on RN 623/2024), 09/17/2025, item 8.
  6. Anahp — Balanço Observatório Anahp (Anahp Observatory Report), 9th edition, March 2026 (2025 data), chart 10.
  7. Anahp — Manual de contratualização entre hospitais e operadoras (Contracting manual for hospitals and health plans), 2025, sections 2, 7 and 12.
  8. ANS — Nota Técnica nº 25/2020/GASNT (Technical Note 25/2020, Denial Indicators Dashboard), items 16 to 21.
  9. ANS — Consulta Pública 170/2026 (Public Consultation 170/2026; news of 07/03/2026), Deliberations of the 644th Board meeting (10/09/2026) and draft normative resolution (SEI process 33910.000171/2025-91). link · link ·