How to appeal a Humana solid-organ transplant denial
42 CFR Part 422 Subpart M (Medicare Advantage) · 60-day window · 30-day decision
To appeal a Humana solid-organ transplant denial, file an internal appeal within 60 days of the date on the denial letter through Humana's member or provider portal, under 42 CFR Part 422 Subpart M (Medicare Advantage). Humana returns standard decisions in 30 days; if it upholds the denial you can request an independent external review within 4 months.
The framework that applies to your appeal
Medicare Advantage plans follow a separate appeal track from commercial plans. Reconsideration must be requested within 60 days; if the plan misses its deadline, the case auto-forwards to the IRE (Maximus).
Humana-specific note: Heavily Medicare Advantage focused. MA-specific appeal track (42 CFR Part 422 Subpart M) applies — 60 days to request reconsideration, NOT the 180 days for commercial plans. Auto-forward to IRE (Maximus) if Humana misses deadline.
What Humana's policy requires for solid-organ transplant
Cited policy: Humana Letermovir (Prevymis) Prior Authorization for CMV Prophylaxis
Indications per FDA label: (1) HSCT CMV-seropositive adult recipients (Nov 2017 original); (2) high-risk D+/R- adult kidney transplant recipients (Jun 6, 2023 expanded label). 480 mg PO/IV daily (or 240 mg with cyclosporine). Duration up to 200 days post-tx per label.
How Humana denies solid-organ transplant — and how to counter it
Where Humana pushes back: 1) Letermovir only for HSCT, not solid organ; 2) Use valganciclovir instead (cheaper); 3) D+/R- not high enough risk.
Counter-arguments that hold up: FDA label was EXPANDED Jun 6, 2023 to include adult kidney transplant recipients at high risk for CMV (D+/R- serostatus mismatch) for prophylaxis up to 200 days post-tx. Pivotal data: Limaye Chemaly et al. NEJM 2023 — letermovir non-inferior to valganciclovir for clinically significant CMV infection at week 52 (10.4% vs 11.8%) with significantly LESS myelosuppression (leukopenia 26% vs 64%) — critical advantage in transplant recipients on MMF/MPA. AST IDCOP CMV consensus (Razonable Clin Transplant 2019) + ISHLT 2018/2023 endorse extended prophylaxis in high-risk D+/R- kidney recipients. Document D+/R- serostatus + post-tx day.
What Humana typically denies for solid-organ transplant
Across Humana's commercial and Medicare books, denials cluster around a small number of patterns. For solid-organ transplant, expect:
- MA plan step therapy on Part B drugs
- Skilled nursing facility days
- Prior auth on specialty drugs
- OON emergency reduction
Treatments most often denied in this category
These are the solid-organ transplant treatments most often flagged for prior auth, step therapy, or medical necessity review:
- Basiliximab (Simulect)
- rATG (Thymoglobulin)
- Alemtuzumab (Campath)
- Tacrolimus IR (Prograf)
- Tacrolimus ER (Astagraf-XL)
- Tacrolimus ER (Envarsus-XR)
How to submit the appeal to Humana
- Read the denial letter — note the exact denial reason code and the appeal deadline (60 days from the date on the letter).
- Gather supporting documentation: physician letter of medical necessity, relevant clinical notes, peer-reviewed citations supporting the treatment for your indication, and the policy or coverage document Humana cited in the denial.
- File the appeal through Humana's portal (members: https://www.humana.com ; providers: https://www.humana.com/provider). Standard decision returns within 30 days; expedited urgent appeals return within 72 hours.
- If denied again, request external review by an independent reviewer within 4 months of the final internal denial. In KY, the state insurance department coordinates external review for fully-insured plans; ERISA self-funded plans use a federal external review through DOL/EBSA.
Clinician or prior-auth team handling this on the practice side? See Humana's prior-authorization criteria by drug: Humana PA criteria on ApprovalHelp.
Frequently asked questions
How long do I have to appeal a Humana solid-organ transplant denial?
Humana allows 60 days from the date on the denial letter to file an internal appeal. Standard decisions come back within 30 days; expedited decisions for urgent care typically within 72 hours.
What's the fastest way to submit a Humana appeal?
Members can submit through the Humana member portal at https://www.humana.com. Providers should use the provider portal at https://www.humana.com/provider. Faxed and mailed appeals are accepted but take longer.
What denials does Humana most often issue for solid-organ transplant?
For solid-organ transplant, Humana most often denies on: 1) Letermovir only for HSCT, not solid organ; 2) Use valganciclovir instead (cheaper); 3) D+/R- not high enough risk. The strongest counters: FDA label was EXPANDED Jun 6, 2023 to include adult kidney transplant recipients at high risk for CMV (D+/R- serostatus mismatch) for prophylaxis up to 200 days post-tx. Pivotal data: Limaye Chemaly et al. NEJM 2023 — letermovir non-inferior to valganciclovir for clinically significant CMV infection at week 52 (10.4% vs 11.8%) with significantly LESS myelosuppression (leukopenia 26% vs 64%) — critical advantage in transplant recipients on MMF/MPA. AST IDCOP CMV consensus (Razonable Clin Transplant 2019) + ISHLT 2018/2023 endorse extended prophylaxis in high-risk D+/R- kidney recipients. Document D+/R- serostatus + post-tx day.
What if Humana denies the appeal too?
After an internal appeal denial you have the right to an external review by an independent reviewer (IRO) — request it within 4 months of the final internal denial.
Related appeal guides
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