Pinson&Tang Resources

Sepsis Denial Rationales: Response from the Sepsis-3 Lead Author

November 21, 2025

Sepsis remains one of the most frequently denied diagnoses for hospitals in the United States by payers. A significant number of these sepsis denials occur when patients meet only Sepsis-2 SIRS criteria, which continues to be used by many hospitals despite the adoption of the Sepsis-3 definition in 2017. In cases where the Sepsis-3 criteria are not met, such denials would be considered appropriate.

In recent years, however, certain payers claim to use the Sepsis-3 definition as justification to deny sepsis but base their denial on adaptations not supported by the official Sepsis-3 criteria.

We requested Dr. Marvyn Singer, lead author of the Sepsis-3 definition, to provide his perspective regarding specific rationales used by payers to deny the diagnosis of sepsis and assess whether these rationales align with Sepsis-3 guidelines.

Below are the common payer denial rationales found in DRG downgrade letters, along with Dr. Singer’s response:  

Payer Sepsis Denial RationaleDr. Singer's Response
“There was no documentation found within the medical record to support an acute change in baseline SOFA score of 2 or more points after an initial bolus/challenge (unless contraindicated) that is related to infection and not explained by other causes.”This is incorrect.

“after an initial bolus/challenge”  only applies to the diagnosis of septic shock, not sepsis.
“SOFA values must be present after an initial fluid challenge to achieve a minimum of 30 mL/kg of crystalloids (e.g., normal saline, Lactate Ringer’s) (Surviving Sepsis 2021, Recommendation 5)”This is incorrect.

No specific volume requirement was mentioned in Sepsis-3.
30 ml/kg was an SSC recommendation (notably based on no good evidence!)
“Direct organ dysfunction is not a dysregulation response and therefore is not counted in the SOFA score.”

“Example: A low PaO2/FIO2 from acute (pneumonia) or chronic (COPD, etc.) lung disease is direct organ dysfunction and not counted towards meeting SOFA criteria.”
This is incorrect.

Direct organ dysfunction following, for example, pneumonia, urosepsis or meningitis are consequent to an excessive host response triggered by the infection – both local and (usually) systemic.
“[Payer] requires the medical record meet the following guideline for Sepsis: Sepsis is defined as life-threatening organ dysfunction caused by a dysregulated host response to infection.
[Payer] recognizes clinical criteria that are made up of three areas:

1) Documented infection, presumed or confirmed, AND

2) Documentation by the clinician that there is life threatening, acute organ dysfunction/failure present due to a dysregulated septic response to infection. Organ dysfunction/failure includes, but not limited to:
--AKI using KDIGO
--Acute Hypoxemia P/F less than 300
--Hyperbilirubinemia total bilirubin greater than 4 mg/dL
--Thrombocytopenia less than 100K
--Paralytic ileus absent bowel sounds
--Critical illness myopathy or neuropathy
--Type 2 myocardial infarction
--Encephalopathy sepsis derived equals metabolic type
--Coagulopathy INR greater than 1.5
--Hypotension SBP less than 90 mm Hg or fallen by greater than 40 from baseline, MAP less than 70 mm Hg, AND

3) Appropriate pharmacotherapy is ordered/given based on the causative organism
This is incorrect.

1) Agree, must have presumed or confirmed infection.


2) This is incorrect.
 … can score 1 point in 2 organ systems and that qualifies as sepsis

3) This is incorrect. Many viral diseases have no treatment.

To hear Dr. Marvyn Singer, lead author of Sepsis-3, debunk these payer denial issues, explain the evolution of Sepsis-2 SIRS to Sepsis-3, along with the new SOFA-2 score, watch the webinar replay. To access this special session and all our webinar replays, purchase the 2026 CDI Pocket Guide® or Unbound Edition. Or you can purchase this webinar on-demand for $29.


Existing CDI Pocket Guide® customers can log in to their CDI+ portal to view Dr. Singer's session along with the complete webinar library.

(c) Copyright 2025 Pinson & Tang LLC

See our original CDI Pocket Guide® for more information on this topic.

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