Audits & Appeals

Your Payer Requested Your Chart Notes: What to Send, What Not to Send

A letter asking for your chart notes just arrived. Here's how to tell a routine records retrieval from a real audit, what to send, what never to send, and how to respond on time.

By Javier Alvarez, CEO of Farela · Published July 24, 2026 · ← All articles

The envelope, or the portal message, is short and bloodless. It lists a handful of patient names and dates of service and asks you to send the records by a date about three weeks out. Then your stomach drops, because nobody explains what this means to a solo RD, and the internet's answer is always written for physician groups with a compliance officer.

Here is the first thing to know: not every records request is an audit. A large share of the letters dietitians receive are not questioning your claims at all. Before you do anything else, figure out which kind you have. That single step is the difference between a photocopying task and a financial event.

Step zero: what kind of request is this?

Read the letter carefully. The type is almost always stated, though not always in plain language.

Type	Who sends it	What it's about	Is your money at risk?
Risk adjustment / HEDIS retrieval	Usually a vendor working for the plan — names like Inovalon, Ciox, Datavant, or a similar retrieval company	The plan's own quality scores and risk-adjustment data	No
Pre-payment review	The payer's claims or medical review department	Whether a pending claim should be paid	Payment is on hold
Post-payment review / audit	The payer's audit unit	Whether claims already paid were supported	Yes — recoupment
SIU (special investigations unit)	The payer's fraud unit	Suspected fraud, waste, or abuse	Yes, and more

Risk adjustment and HEDIS: the one that isn't an audit

If the letter comes from a third-party retrieval vendor, mentions HEDIS, quality measures, Stars, risk adjustment, or medical record review for the plan's annual reporting, and lists a broad set of members rather than specific claims — that's a data-gathering exercise. The plan is documenting the health status of its population, or reporting quality measures. It is not deciding whether to pay you or take money back. There is no recoupment on the other end of it.

You still respond, and you still send only what's requested. But you can stop bracing for impact.

The medical-necessity reviews

The other three are about your claims. The tells:

Pre-payment review: the letter references specific pending claims and says payment is being held or the claim is suspended pending documentation. Cash flow stops until you respond.
Post-payment review: it references claims already paid, often with dates several months back, and usually cites the payer's right to review and recover overpayments. This is the one that ends in a recoupment demand if the notes don't hold up.
SIU: the letterhead or the signature line says special investigations, program integrity, or fraud. The language is more formal, the request is often broader, and the deadline may be shorter. Call a health care attorney before you respond to this one. Do not treat an SIU letter as routine paperwork.

If you genuinely can't tell what you're holding, call the number on the letter and ask directly: "Is this a risk-adjustment retrieval or a medical-necessity review? Are any claims currently pending or under recovery?" Write down who you spoke to and when.

What to send

The rule is simple and it does not change by request type: exactly what was requested, for exactly the dates requested, complete.

For a typical MNT records request, that means:

The complete note for each listed date of service — assessment, intervention, plan, and the documented time that supports the units you billed.
The physician referral or order, if the payer requires one and it's part of the request.
Anything else specifically named: intake forms, consent, a treatment plan, a growth chart.

Complete means complete. A note that references an attached food log the reviewer never sees is a note with a hole in it. If your EHR splits the encounter across sections, export the whole encounter, not just the narrative field.

What not to send

This is where well-meaning RDs create problems that didn't exist.

Don't send extra dates of service. If they asked for three visits, send three. A reviewer looking at a fourth note you volunteered can flag it, and now you have four claims in play instead of three.

Don't send other patients' information. This sounds obvious and it happens constantly — a scanned batch with a stray page, a PDF export that pulled the wrong record, an unredacted schedule screenshot. Page-check every packet before it leaves. A disclosure of the wrong patient's PHI is its own separate problem, with its own separate consequences.

Don't send your entire chart when one note was requested. Volume doesn't read as thoroughness; it reads as an invitation to browse.

Don't send an explanation instead of a record. A long letter arguing why the visit was necessary cannot substitute for a note that shows it. Keep the cover letter short and factual.

And above all: never alter, rewrite, or backdate a note. Your EHR records when every entry was created and every edit was made. Reviewers can and do ask for the audit trail. A note that was clearly rewritten after the request date is no longer a documentation dispute you can lose money over — it is an allegation of falsified records, which is a different category of problem entirely, with licensure and criminal exposure attached. A thin note costs you one claim. A doctored note can cost you your practice.

If a note is genuinely incomplete, most systems allow a clearly labeled late entry or addendum that is timestamped as such and leaves the original intact. That is a legitimate correction. Overwriting history is not. Send both the original and the addendum, and say so in your cover letter.

Deadlines

The deadline is in the letter, and it varies by payer, state, and review type — there's no single number, and anyone quoting you one is guessing. What's consistent:

Calendar it the day the letter arrives. Not the day you get around to it.
A missed deadline on a medical-necessity review is usually treated as no documentation at all. Perfect notes you didn't send on time don't count.
Extensions are commonly granted if you ask in writing, before the deadline. A short email or portal message stating the request ID, the reason, and the specific new date you need. Silence gets you nothing.

Your step-by-step response

Identify the type. Retrieval, pre-payment, post-payment, or SIU. Everything else follows from this.
Calendar the deadline and set a reminder a week out.
Verify the requester. If a vendor is asking, confirm they're acting for a plan your patient is actually enrolled with. Don't send records to an entity you can't verify.
List exactly what's requested — patient, date of service, document type — as a checklist. Work the checklist.
Pull the records as they exist. Export clean, legible PDFs with signatures visible. Don't edit anything.
Page-check for stray PHI. Every page, every packet.
Write a one-page cover letter. Request ID, list of what's enclosed by patient and date, your NPI and contact, and one factual line of context where it helps ("each note documents total session time supporting the units billed").
Send with proof of delivery — certified mail or a portal submission receipt — and keep a complete copy of exactly what you sent.
Diary the follow-up. If you hear nothing in 30 days on a payment-related review, call and ask for status in writing.

What auditors are actually checking

On a medical-necessity review, the reviewer is answering four questions. Everything else is noise.

Does the documented time support the units billed? Time-based MNT codes need documented minutes. A note with no time statement cannot support 4 units, no matter how good the clinical content is.
Does the note show medical necessity for the diagnosis on the claim? Why this patient needed MNT on this date. Our guide to charting for medical necessity covers what reviewers want to see.
Are the diagnosis codes consistent across note, referral, and claim? A mismatch here is one of the most common reasons a claim falls apart under review — and one of the most common causes of routine nutrition claim denials too.
Is the note signed and dated? An unsigned note is, to a reviewer, not a note.

If a review ends badly, you're not out of options — the findings carry appeal rights, and the process looks a lot like appealing a denied nutrition claim, with more at stake. Payer-specific expectations differ, and documentation requirements by payer is worth reading before you're the one holding the letter.

One more time, plainly: this is general information, not legal advice. If a request escalates to alleged fraud, comes from an SIU, or carries a large recoupment demand, get a health care attorney involved before you respond.

How Farela helps: Farela runs an audit behind every claim before it goes out — checking that the chart actually supports the CPT and ICD codes on the claim, that the documented time matches the units, and that the diagnosis is consistent across the note and the claim. When a records request shows up months later, you're sending documentation that already lines up. Farela doesn't represent you in an audit and doesn't give legal advice — it just makes sure the notes and the claims never drifted apart in the first place. Start a 7-day free trial.

Frequently asked questions

Why is my insurance company asking for my chart notes?

There are several reasons and they are not equally serious. The most common is a routine risk-adjustment or HEDIS records retrieval, usually run by a vendor on the plan's behalf, which is about the plan's own quality and risk scores and not about taking money back from you. The others are medical-necessity reviews: pre-payment review, where the payer holds payment until it sees the note, and post-payment review, where it has already paid and is checking whether it should have. Read the letter to see which one you have.

Do I need patient authorization to send records to an insurance company?

Generally no, when the request is tied to payment or health care operations for a patient that plan covers. HIPAA permits disclosures for treatment, payment, and operations without separate authorization. But you should still send only the minimum necessary to answer the request, verify the requester is who they claim to be, and confirm a business associate agreement or equivalent authority is in place when a third-party vendor is asking. If the request looks unusual or comes from an entity you cannot verify, slow down and confirm before you send anything.

What happens if I miss the deadline on a records request?

On a medical-necessity review, a missed deadline is usually treated the same as having no documentation at all, which means the claim is denied or the money is recouped even if your notes were perfect. Deadlines are set in the letter and vary by payer and review type. Calendar the date the day the letter arrives, and if you need more time, ask in writing before the deadline passes. Extensions are commonly granted when you ask early; they are rarely granted after the fact.

Can I fix a chart note before sending it to the payer?

No. Never alter, rewrite, or backdate a note after a records request arrives. EHR systems keep audit trails and metadata showing when every entry was created and edited, and payers know to look. Changing a note turns a documentation dispute, which is a billing problem, into an allegation of falsified records, which is a fraud problem. If a note is genuinely incomplete, you may be able to add a clearly labeled and dated late entry or addendum that does not overwrite the original, and you send both. When in doubt, send what exists and explain the gap in your cover letter.

Should I send my entire chart or just the dates they asked for?

Just the dates requested. Sending extra dates of service, unrelated notes, or your full chart gives the reviewer material to question that was never under review, and can widen a narrow request into a broader one. Send exactly what was asked for, complete for those dates, and nothing else.

Do I need a lawyer if a payer requests my records?

Not for a routine retrieval or a standard records request you can answer with clean documentation. You should talk to a health care attorney if the letter comes from a special investigations unit, alleges fraud or abuse, demands a large repayment, extrapolates an error rate across claims you did not submit for review, or threatens to terminate your contract or refer you elsewhere. This article is general information, not legal advice.