When insurers do not pay, the single best tool to use is called a “Grievance Letter” which was enacted into law in 2000 through the efforts of ACS among others.


Each insurer must have a written grievance policy that is available to providers upon request. Each insurer must designate a contact person (the “Grievance Officer”) to receive grievances and answer provider questions on those grievances. Insurers may recommend, but may not require, a specific form for the submission of grievances.

Insurers must file semi-annual grievance reports to the Department which include information such as the number of grievances received by an insurer, the kinds of grievances, and the time to resolution. If the Department is not pleased with what it sees, it will audit the insurer with a Market Conduct Evaluation.


Starting July 1, 2020, the Arizona Department of Insurance (ADOI) became the
Department of Insurance and Financial Institutions (DIFI). You will note the change in nomenclature below.


Basically what a Grievance Letter does better than any other approach is to get serious attention from the insurer. This is because the insurer must report on a semi- annual basis to the DIFI how all of the provider grievances were handled. For example, were the majority of the grievances decided in favor of the providers or the insurer? If DIFI finds that the providers’ grievances are not being sufficiently considered by the insurer, then DIFI can order an audit. DIFI sends personnel to the insurer to go through their books and assess fines if appropriate. No insurer wants to go through that process and so they take Grievance Letters very seriously, much more so than the usual letters and calls they receive on a daily basis.


We call the Grievance Letter an “arrow through the heart.” We strongly recommend using it whenever appropriate. Please do not be intimidated by the title of the letter. It is basically the same as the usual insurance complaint letter, simply sent to a different person at the insurance company (the “Grievance Officer”).


To use the system, go to and follow the links and directions. It is all self-explanatory and easy to complete. 

ACS helps members get paid for their services. Contact ACS at 602-284-9979 or