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Types of denials: administrative, technical and across-the-board

The types of denials (denials) in Brazilian hospitals, who handles each one and what evidence the appeal needs. The differences between the types, with examples from TUSS table 38 and how to challenge each one.

By Published on 9 min read

What are the types of denials in Brazil?

Brazil's market uses three types of denial. An administrative denial comes from a process failure: enrollment, authorization, coding, price or deadline. A technical denial questions whether the billed item was clinically necessary and is documented. A linear, or across-the-board, denial is a cut with no review of each item.

In Brazil, denial is the health plan's refusal to pay all or part of a hospital claim. Health plans are called operadoras. The three-way split is a market convention, not a rule of ANS (Agência Nacional de Saúde Suplementar, the National Agency for Supplementary Health, Brazil's private health plan regulator). ANS tracks denial volume by health plan, but it does not receive the reason for each denial [10]. Classifying by type is the hospital's job. It pays off because it answers two questions: who handles the denial and what evidence the appeal needs. The full picture is in the guide Claim denials.

Denials are also classified by extent (total or partial) and by timing (initial, or final after appeals). These cuts combine with the three types. The timing split is covered in the guide Initial and final denials.

For US readers, the closest parallel is the split between administrative denials (eligibility, authorization, coding, timely filing) and clinical, or medical necessity, denials. Brazil adds a third category for cuts with no stated item-level reason.

The three types side by side

The table sums up what sets each type apart in billing. The codes come from table 38 of TUSS (Terminologia Unificada da Saúde Suplementar, Unified Terminology for Supplementary Health). It is the list of reasons the health plan uses in the claim review statement [3].

AdministrativeTechnicalAcross-the-board (linear)
What it questionsThe process: enrollment, authorization, documents, coding, price, deadlineClinical appropriateness: indication, quantity, medical record entryNothing specific: a percentage or group of items is cut with no item-level reason
Where it startsFront desk, authorization team, billingCare delivery and clinical documentationThe health plan's payment policy
Who handles it at the hospitalBilling and the authorization teamPhysician and nursing auditorsContract management, leadership and legal
Table 38 examples [3]1414 (authorization code expired); 3209 (duplicate billing of a procedure or item); 1705 (amount billed too high)3217 (procedure or item with no or insufficient justification); 3190 (item quantity incompatible with the procedure); 3040 (technical denial, to be specified)No dedicated message; usually comes with a generic code or no item-level reason
Appeal evidenceEligibility proof, authorization code, contract clause and fee scheduleMedical record, orders, nursing administration records, progress notes, operative reportThe contract (listed denial cases) and a request for item-level reasons
PreventionContract rules set up in the billing system and pre-submission reviewComplete clinical documentation and concurrent auditNegotiation and contract language
The type of denial sets who handles it and what the appeal needs Denial classification flow in Brazil. Administrative: process failure (enrollment, authorization code, coding, price or deadline); handled by billing and the authorization team; documentary evidence (authorization code, member card, contract). Technical: clinical disagreement (indication, quantity, medical record entry); handled by physician and nursing auditors; evidence from the medical record, orders and nursing administration records. Across-the-board: cut with no item-level reason (percentage or group of items); handled by contract management and legal; evidence is the contract plus a request for item-level reasons. Source: market classification; ANS RN 503/2022; TISS standard; TUSS table 38. The type of denial sets who handles it and what the appeal needs Denial on the claim review statement (reason code from TUSS table 38) What does the reason question? Administrative Process failure Enrollment, auth code, coding, price or deadline WHO HANDLES IT Billing and the authorization team APPEAL EVIDENCE Documents: auth code, member card, contract Technical Clinical disagreement Indication, quantity, medical record entry WHO HANDLES IT Physician and nursing auditors APPEAL EVIDENCE Medical record, orders, nursing administration Across-the-board Cut with no item reason Percentage or group of items WHO HANDLES IT Contract management and legal APPEAL EVIDENCE Contract and request for item-level reasons Source: market classification (not an ANS definition); RN 503/2022; TISS standard; TUSS table 38.
Market classification of denial types in Brazil (not an ANS definition), based on RN 503/2022, the TISS standard and TUSS table 38. Produced by Accrua.
View the diagram as a table
TypeWhat the reason questionsWho handles itAppeal evidence
AdministrativeProcess failure: enrollment, authorization code, coding, price or deadlineBilling and the authorization teamDocuments: authorization code, member card, contract
TechnicalClinical disagreement: indication, quantity, medical record entryPhysician and nursing auditorsMedical record, orders, nursing administration records
Across-the-boardCut with no item-level reason: percentage or group of itemsContract management and legalContract and request for item-level reasons

What is an administrative denial?

An administrative denial is a refusal to pay because of a process failure, unrelated to clinical decisions. The care may have been correct and necessary; the problem is in the data, the document, the code, the price or the deadline.

The reasons group by the step where they start:

  • Enrollment and eligibility: invalid member card number (table 38 message 1001), member inactive on the date of service, waiting period (carência) [3].
  • Authorization: procedure without authorization, expired authorization code (1414), item or inpatient day beyond what was authorized [3].
  • Billing: duplicate billing (3209), wrong TUSS code, amount billed too high (1705) [3].
  • Submission: claim sent after the contract deadline, XML batch with structural errors.

Administrative denials tend to be the easiest to prevent, because they depend on internal processes. When the denial is wrong, the evidence is an objective document, such as the dated authorization code or the contract clause. When it is correct (the hospital's error), the fix is to correct the source and rebill, if the contract allows.

Each reason and how to prevent it is covered in the guide Common denial reasons, and the meaning of each message in TISS denial codes.

Technical denials: a disagreement about care

A technical denial is a refusal to pay because the health plan's auditor disagrees with the clinical appropriateness of what was billed. The question becomes: was the item necessary, and is it documented in the medical record?

Typical examples: supplies above the expected amount, an inpatient day with no documented justification, a test that does not match the working diagnosis. Table 38 has messages for these cases, such as 3217 (procedure or item with no or insufficient justification) and 3190 (item quantity incompatible with the procedure) [3].

Two professional rules define who issues and who challenges a technical denial:

  • Physician audit. Resolução CFM nº 2.448/2025 (Federal Council of Medicine Resolution 2,448/2025) defines medical auditing as an act reserved to physicians and requires disagreements to rest on the patient's clinical history [4]. It also bars auditors from denying a procedure that was authorized and shown to have been performed. In March 2026, the Federal Council of Medicine (CFM) reported that a federal court had suspended articles of the resolution, including that ban [5]. The official text of the resolution, checked on October 17, 2026, marks art. 12, VI and art. 15, XIV, among other provisions, as suspended. The suspension comes from a decision in case 1017752-74.2026.4.01.3400 [11].
  • Nursing audit. Resolução Cofen nº 720/2023 (Federal Nursing Council Resolution 720/2023) reserves auditing within the nursing team to registered nurses. Its listed activities include counter-audits and denial appeals, with the nurse's Coren (state nursing council) number on each opinion [6].

In practice, the hospital's physician or nurse auditor writes or signs off on the technical appeal, based on the clinical record. Generic justifications tend to be rejected. See the guides Physician audit, Nursing audit and Medical claims auditing.

What is an across-the-board denial?

An across-the-board denial, called denial linear in Brazil, is a cut the health plan applies to a percentage of the claim or to a group of items, with no specific reason for each item. It tends to strain the hospital–health plan relationship the most, because the hospital has nothing to fix: no error is identified.

The term has two meanings in the market, and they should be kept apart:

SituationExampleHow to handle it
Cut with no item-level reasonA flat percentage discount on all claims for one type of care, with no item-by-item justificationChallenge it based on the contract and ask for the reason for each item
Automatic cut by a limit written in the contractInpatient days above the contract cap; an item billed outside a fixed bundleIn practice, a contractual administrative denial: the evidence is the clause, and prevention is setting up the limit in the system

If the limit is in the contract, the denial has a reason: check whether the claim followed the clause. If there is no item-level reason, the argument is RN 503/2022 (ANS Normative Resolution 503/2022). It requires the contract to list the cases in which a denial may apply, and it bars blocking access to denial reasons and to the appeal [1]. Those two bans only apply when the claim is submitted in the current TISS standard (Troca de Informação de Saúde Suplementar, Brazil's mandatory health data exchange standard) [1].

The TISS standard also helps: the claim review statement must list the denied items for each claim analyzed [2]. The guide Across-the-board denials covers the appeal in detail.

How the type changes the appeal

The type of denial sets the evidence, the owner and the argument of the appeal. Getting the type wrong often leads to a rejected appeal: sending administrative documents for a technical denial, or clinical text for a price denial.

For every type, the appeal goes through the TISS standard, with a protocol number that proves receipt [2], within the contract deadline [1].

TypeCore argumentCommon appeal mistake
AdministrativeThe data, document or contract rule was correctAppealing a correct denial instead of fixing and rebilling
TechnicalThe item was clinically necessary and is documentedGeneric justification with no excerpt from the medical record
Across-the-boardThere is no item-level reason and no contract case for the denialAppealing item by item without asking for reasons or citing the clause

The full step-by-step and a justification template by reason are in the guide Denial appeals. The clauses the contract must include are in the guide RN 503/2022: the payer contract.

What could change with Public Consultation 170/2026?

Denials of authorized procedures could change. The draft rule in ANS Public Consultation 170/2026 bars denying an authorized and performed procedure, unless an audit points to a technical disagreement. It also guarantees access to the audit documents behind the denial [9]. Comments were accepted until July 3, 2026. As of October 17, 2026, the final rule had not been published [9].

How much each type weighs in industry data

There is no official public statistic by type of denial: the National Association of Private Hospitals (Associação Nacional de Hospitais Privados, Anahp) measures the total. At its member hospitals, initial denials were 15.93% of amounts receivable from health plans in 2025, and accepted denials were 1.72% of gross health plan revenue [7]. The two figures use different bases and should not be divided by each other.

ZG Soluções's 2026 Revenue Cycle Panorama, based on the company's client data, attributed 67.9% of the denied amount to avoidable failures [8]. Its methodology differs from Anahp's, so the figures are not directly comparable. See Industry data.

What we see in operations

At Accrua, we classify every denial in the hospital's history by type and reason, using the TUSS table 38 code and what the remittance statement says. That split comes before the appeal, because each type calls for different proof: for administrative denials, the document or authorization code; for technical denials, the part of the medical record that supports the care; for across-the-board cuts, the contract clause and evidence that no claim-level review took place.

To stop administrative and technical denials at the source, Accrua OS reads the whole claim before submission and checks it against the contract, the authorization rule and that health plan's denial history for that item. When a denial comes in, agents draft the appeal with the evidence the health plan asks for. Accepting the denial or dropping the appeal stays with a person.

Across-the-board cuts rarely get solved one claim at a time. In that case, we gather the affected claims and the relevant clause so the hospital can take the issue to contract negotiation. What we learn in each appeal feeds the next claim.

Where to start

  1. Classify the last 12 months of denials by type, health plan and table 38 code.
  2. Assign an owner per type: billing and authorizations for administrative, physician and nursing auditors for technical, contract management for across-the-board.
  3. Tackle recurring administrative denials with pre-submission review rules.
  4. Build an evidence kit per type, with the documents each reason requires.
  5. Take across-the-board denials to the negotiating table, with the total amount per health plan.

Frequently asked questions about types of denials

What are the types of denials in Brazil?

The market classifies denials as administrative (process failure), technical (disagreement on clinical appropriateness) or across-the-board, also called linear (cuts with no item-level review). Denials are also described as total or partial, and initial or final.

What is the difference between a technical and an administrative denial?

An administrative denial points to a process failure, such as an expired authorization code or a wrong code, and is challenged with documents. A technical denial questions the clinical need for the item and is challenged with the medical record, through a physician or nurse auditor.

Are across-the-board denials allowed?

RN 503/2022 requires the contract to list the cases in which a denial may apply and bars blocking access to denial reasons and to appeals. A cut with no item-level reason, outside the contract's listed cases, can be challenged under those rules, as long as billing follows the current TISS standard.

Who can file a technical denial appeal?

The technical opinion belongs to the physician auditor (CFM Resolution 2,448/2025) and the nurse auditor (Cofen Resolution 720/2023). The Cofen rule lists denial appeals among the nurse auditor's activities.

Does ANS define the types of denials?

No. ANS requires the denial cases to be in the contract and standardizes the reasons in TUSS table 38, but it does not split denials into administrative, technical and across-the-board. That classification is an industry convention.

Sources

  1. ANS — Resolução Normativa nº 503, de 30 de março de 2022 (Normative Resolution 503 of March 30, 2022, contracts between health plans and providers), arts. 5, V and VI, and sole paragraph, and 14.
  2. ANS — Padrão TISS: Componente Organizacional, versão 202609 (TISS standard: Organizational Component, version 202609), September 2026, items 33, 51, 55 and 56.
  3. ANS — Terminologia TUSS, tabela 38 (TUSS terminology, table 38: TISS standard messages), version 202607 (official ANS spreadsheet “TUSS - Demais terminologias”), checked on 10/18/2026; online lookup on the TUSS platform (Open Concept Lab).
  4. Conselho Federal de Medicina (Federal Council of Medicine) — Resolução CFM nº 2.448/2025 (medical auditing).
  5. Conselho Federal de Medicina — “Planos de saúde agem para restringir acesso de pacientes a diagnóstico e tratamento médico” (Health plans act to restrict patient access to diagnosis and treatment), March 24, 2026.
  6. Conselho Federal de Enfermagem (Federal Nursing Council) — Resolução Cofen nº 720/2023 (nurse auditors), amended by Resolução Cofen nº 733/2023.
  7. Anahp — Balanço Observatório Anahp, 9ª edição (Anahp Observatory Update, 9th edition), March 2026 (2025 data).
  8. ZG Soluções — Panorama do Ciclo de Receita 2026 (2026 Revenue Cycle Panorama; company client base).
  9. ANS — Consulta Pública nº 170/2026 (Public Consultation 170/2026, draft rule on contracts between health plans and providers) and Deliberações da 644ª Reunião da Diretoria Colegiada (decisions of the 644th Board meeting). link ·
  10. ANS — Nota Técnica nº 25/2020/GASNT (Technical Note 25/2020, Denial Indicators Panel).
  11. Conselho Federal de Medicina (Federal Council of Medicine) — Resolução CFM nº 2.448/2025, official text (DOU, November 4, 2025), with the suspended provisions marked, accessed 10/17/2026.