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Under the Affordable Care Act, a denied health insurance claim can go through two stages: an internal appeal, where the plan reviews its own decision, and an external review, where an independent reviewer decides. HealthCare.gov states that an internal appeal must be filed "within 180 days (6 months) of receiving notice that your claim was denied," and that an external review request must be filed in writing "within 4 months after the date you receive a notice or final determination." Which agency oversees each stage depends on the kind of plan, and that is the question most appeal guides skip.

This article relays how federal agencies describe the appeal process in the United States. It is general information, not legal, medical, insurance or financial advice. It makes no judgment about whether any particular denial is correct or worth appealing. Your plan documents, your plan's member services and the regulators named below are the authorities for your own claim.

Sources read September 11, 2026. Deadlines and timeframes below are quoted from the agency pages named in each sentence. Some plans, including grandfathered plans and government programs, follow different rules.

How to appeal a denied health insurance claim: the two stages

HealthCare.gov's page on appealing an insurance company decision, read September 11, 2026, describes the structure in two sentences. First: "If your claim is denied or your health insurance coverage canceled, you have the right to an internal appeal." Second: "You have the right to take your appeal to an independent third party for review. This is called an external review."

The second stage is the one with teeth. HealthCare.gov puts it plainly: with external review, "the insurance company no longer gets the final say over whether to pay a claim."

The sequence usually runs in this order:

  1. The plan issues a denial notice that states its reason.
  2. The member, often with the provider's office, files an internal appeal with the plan.
  3. The plan decides the internal appeal within a federal timeframe.
  4. If the plan upholds its denial, the member may request an external review by an independent reviewer.

Step 1: Read the denial notice before anything else

The notice is the starting document for everything that follows. It states what was denied, the reason, and the deadline and method for appealing. For services already received, the denial often shows up first on the explanation of benefits, and our walkthrough of how to read an explanation of benefits, line by line covers where the reason codes and remark codes sit on that page.

It also matters which document is in hand. A provider's bill and a plan's EOB are different papers that arrive at different times, and an appeal is filed against the plan's decision, not against the bill. Our comparison of an EOB and a medical bill sets out how to tell them apart.

HealthCare.gov's internal appeals page, read September 11, 2026, gives the timeframes within which a plan must tell a member that a claim was denied: "Within 15 days if you're seeking prior authorization for a treatment," "Within 30 days for medical services already received," and "Within 72 hours for urgent care cases."

Step 2: The internal appeal

The internal appeal asks the plan to take a second look at its own decision. HealthCare.gov describes it as a request that the insurer "conduct a full and fair review of its decision."

The deadline. HealthCare.gov states that the internal appeal must be filed "within 180 days (6 months) of receiving notice that your claim was denied." The Department of Labor, writing about employer plans, phrases the same rule as "You have at least 180 days to file an appeal." The words "at least" matter: a plan may allow more time, and the plan's own notice states its deadline.

What goes in. HealthCare.gov describes completing the insurer's forms, or writing to the insurer with the member's name, claim number and health insurance ID number, and submitting "any additional information that you want the insurer to consider, such as a letter from the doctor."

The National Association of Insurance Commissioners, in a consumer article dated August 17, 2020 and read September 11, 2026, on how to appeal a denied health claim, adds practical record-keeping points. It lists gathering "your policy, the Summary of Benefits Coverage (SBC), and your denial letter," to "keep notes of all conversations you have with company representatives," and to "keep copies of everything you send to the insurance company for your records." On the content of an appeal letter, it describes giving "specific reasons why your claim should be paid under your policy" and including supporting evidence such as records or a letter from the treating physician.

The right to the file. For employer plans, the Department of Labor's publication on filing a claim for your health benefits, read September 11, 2026, states: "The plan must provide you copies of documents, records, and other information relevant to your claim for free if you request them."

The decision timelines, side by side

Two federal sources describe how long the plan has to decide an internal appeal. Their numbers line up, and seeing them together makes the pattern clear.

Situation HealthCare.gov (internal appeals page) Department of Labor (employer plans)
Service not yet received (pre-service) "within 30 days" "no more than 30 days"
Service already received (post-service) "within 60 days" "no more than 60 days"
Urgent care Expedited; final decision "at least within 4 business days" "no more than 72 hours"
Filing window for the member 180 days from the denial notice "at least 180 days"

Both pages read September 11, 2026. The two agencies describe urgent timing differently, and the plan's own notice states which rule it follows.

The honest limit of this table: it is the federal floor. Plans can decide faster, states can set their own rules for the plans they regulate, and the plan document is where the plan's actual commitments are written.

Step 3: External review

HealthCare.gov's external review page, read September 11, 2026, sets out the second stage.

When it opens. "If your insurance company still denies you the service or payment for a service, you can ask for an external review." The request must be written and filed "within 4 months after the date you receive a notice or final determination."

What it decides. "An external review either upholds your insurer's decision or decides in your favor." And the outcome binds the plan: "Your insurer is required by law to accept the external reviewer's decision."

How long it takes. "Standard external reviews are decided as soon as possible, no later than 45 days after the request was received." Expedited reviews are decided "no later than 72 hours, or less, depending on the medical urgency."

What it costs. HealthCare.gov states that under the HHS-administered federal external review process "there's no charge," and that where another process is used, a charge cannot exceed $25 per review.

Which denials qualify. This is where many readers get surprised. HealthCare.gov lists denials involving medical judgment, denials on the ground that a treatment is experimental or investigational, and cancellations of coverage based on a claim that the application contained false or incomplete information. A denial about something else, for example whether a person was enrolled at all, may not fit those categories, and the notice or the regulator can say whether external review is available.

Who runs it. Depending on the state and the plan, the external review may be run by the state, by the federal Department of Health and Human Services, or through an independent review organization the plan contracts with.

When the situation is urgent

Both stages have a fast track. HealthCare.gov describes an expedited appeal where "the timeline for the standard appeal process would seriously jeopardize your life or your ability to regain maximum function." It also notes: "If you have an urgent health situation, you can ask for an external review at the same time as your internal appeal." The NAIC describes asking the plan to expedite when the member or the doctor believes a denial could be life-threatening. Whether a situation meets that standard is a clinical judgment that belongs to the treating clinician, not to an article.

Which rulebook governs your plan, and who to call

Most appeal guides stop after the steps. The more useful question is which regulator stands behind them, because that decides who answers the phone when a plan misses a deadline or refuses to cooperate.

If the coverage is… Main rules described by Who a member can contact
An individual or family plan, including a Marketplace plan HealthCare.gov internal appeals and external review pages The state Department of Insurance; the plan's notice names the external review route
A fully insured employer plan Department of Labor claims rules plus state insurance law The Department of Labor's EBSA and the state Department of Insurance
A self-funded employer plan Department of Labor claims rules (ERISA) EBSA, which the Department of Labor lists at 1-866-444-3272
A grandfathered plan Plan terms; the Department of Labor notes that external review is required of plans "not grandfathered under the Affordable Care Act" The plan administrator, then EBSA or the state regulator
Medicare or Medicaid Separate program rules, not covered here Medicare at 1-800-MEDICARE; Medicaid through the state Medicaid agency

Whether an employer plan is fully insured or self-funded is stated in the plan's Summary Plan Description, and the employer's benefits office can confirm it. The NAIC's advice for insured plans is short: "Contact your state Department of Insurance if you feel your insurer is not cooperating."

Some denials trace to network status rather than medical judgment. Where that is the stated reason, the plan's network rules are the starting point, as set out in our guide to in-network and out-of-network allowed amounts, and the records a member kept when checking whether a doctor was in network can become part of the appeal file.

What this article cannot tell you

It cannot tell you whether a denial is right. It cannot say whether an appeal will succeed, what a plan document means for a specific claim, or which deadline applies to a plan that follows state rules or its own longer timeframes. The Department of Labor notes that a person "may decide to seek legal advice if your claim's appeal is denied or if the plan failed to establish or follow reasonable claims procedures," and a licensed attorney is the professional for that question.

What the regulators need from a reader who calls: the denial notice, the claim number, the member ID, the plan's name, and the dates the notice was received and any appeal was sent.

Frequently asked questions

How long do I have to appeal a denied health insurance claim?
HealthCare.gov states that an internal appeal must be filed "within 180 days (6 months) of receiving notice that your claim was denied." The Department of Labor says employer plans must allow "at least 180 days." The plan's denial notice states its own deadline.

What is the difference between an internal appeal and an external review?
An internal appeal asks the plan to review its own decision. An external review sends the dispute to an independent reviewer, and HealthCare.gov states that the insurer "is required by law to accept the external reviewer's decision."

How long does an external review take?
HealthCare.gov states that standard external reviews are decided no later than 45 days after the request is received, and expedited reviews no later than 72 hours, or less depending on medical urgency.

Who can help if my plan is an employer plan?
The Department of Labor's Employee Benefits Security Administration handles questions about employer plan claims and lists its number as 1-866-444-3272. For insured plans, the state Department of Insurance is also a contact.


Sources, all read September 11, 2026: HealthCare.gov, "How to appeal an insurance company decision," "Internal appeals" and "External review," no dates shown. U.S. Department of Labor, Employee Benefits Security Administration, "Filing a Claim for Your Health Benefits," no date shown. National Association of Insurance Commissioners, "Health Insurance Claim Denied? How to Appeal the Denial," dated August 17, 2020.

Prior authorization is a plan's approval, obtained before care is delivered, that a service or drug meets the plan's coverage conditions. HealthCare.gov defines preauthorization as "a decision by your health insurer or plan that a health care service, treatment plan, prescription drug or durable medical equipment is medically necessary," and adds the sentence most people never see: "Preauthorization isn't a promise your health insurance or plan will cover the cost." A claim is held when that step is required and has not been completed.

This article explains an administrative process in the United States. It is general information, not medical, insurance, legal or financial advice. It does not say what care anyone should get, decline or delay, does not define what is medically necessary for any person, and does not say whether a claim should be appealed. Clinical questions belong with your clinician, and coverage questions belong with your plan. This site's full position is set out on its disclaimer page.

Sources read September 8, 2026. Prior authorization rules differ by plan type, by state and by federal program, and several federal requirements have phased in on their own schedule.

What is prior authorization in health insurance?

The National Association of Insurance Commissioners, in a consumer article on prior authorization dated November 5, 2024 and read September 8, 2026, puts it in one line: "Prior authorization requires your doctor or provider to obtain approval from your health plan before providing health care services or prescribing prescription drugs."

The NAIC also describes what the plan is doing with the request: "Prior authorization is a check that your plan covers the proposed care. It's also a way the health plan can decide if the care is medically necessary, safe, and cost effective." And it states the consequence of skipping it: "Without prior authorization, your health plan may not pay for your treatment or medication."

You may see the same process called preauthorization, precertification or prior approval. The names vary by plan and mean the same administrative step.

Two things it is not. It is not a clinical decision about your care, which is between you and your clinician. And it is not a payment guarantee, which is the point the HealthCare.gov glossary entry for preauthorization, read September 8, 2026, makes explicitly.

Why a claim gets held

A claim is a request for payment submitted after care. Prior authorization is a request for approval submitted before it. When the second one is required and missing, the first one has nowhere to land.

Holds usually trace to one of a small number of situations: the service required authorization and none was requested, an authorization exists but for a different code, date, quantity or facility than the one billed, the authorization expired before the care happened, or the request is still pending a decision when the claim arrives.

The distinction that matters most to a person reading a notice is between a hold and a denial. A held or pended claim is one the plan has not finished processing. A denied claim is one the plan has processed and refused. They can look similar on an explanation of benefits, and the reason code on that notice is where the plan states which it is. What the plan then owes you by way of process depends on which of the two it is.

Which services tend to require it

Requirements are set by each plan and published in its own documents, so no list here is authoritative for your coverage. What is generally true is that the requirement attaches to categories of higher cost or higher complexity rather than to routine visits, and that drug formularies carry their own separate approval steps.

There is one situation where federal consumer guidance is explicit. CMS, on its page about ending surprise medical bills dated September 10, 2024 and read September 8, 2026, states that "emergency services must continue to be covered without any prior authorization, and regardless of whether or not a provider or facility is in-network."

Where a service sits inside a plan's network rules is a separate question that runs alongside authorization rather than replacing it, and our explainer on in-network and out-of-network allowed amounts covers that side.

Plan design also shapes how much of this a member encounters, since referral and authorization practices differ across plan types, as set out in our comparison of what the HMO, PPO and EPO letters change.

The federal timeframes, and exactly who they bind

This is the part that most consumer pages state as though it were universal, and it is not.

The CMS Interoperability and Prior Authorization Final Rule, known as CMS-0057-F, was published on January 17, 2024, and its fact sheet was read on September 8, 2026. CMS identifies the plans it reaches as "Medicare Advantage (MA) organizations, state Medicaid and Children's Health Insurance Program (CHIP) Fee-for-Service (FFS) programs, Medicaid managed care plans, CHIP managed care entities, and Qualified Health Plan (QHP) issuers on the Federally Facilitated Exchanges (FFEs)," which CMS calls "impacted payers."

For those payers, CMS's fact sheet sets decision timeframes of "72 hours for expedited (i.e., urgent) requests and seven calendar days for standard (i.e., non-urgent) requests." It also states that "beginning in 2026, impacted payers must provide a specific reason for denied prior authorization decisions, regardless of the method used to send the prior authorization request," and requires those payers to publicly report certain prior authorization metrics annually on their websites, with initial metrics due by March 31, 2026. CMS gives compliance dates generally beginning January 1, 2026 for the operational provisions and generally January 1, 2027 for the application programming interface requirements.

The question What CMS's fact sheet says
Who is bound Medicare Advantage organizations, Medicaid and CHIP fee-for-service programs, Medicaid and CHIP managed care entities, and QHP issuers on the federally facilitated exchanges
Standard decision Seven calendar days
Expedited decision 72 hours
Denial reasons A specific reason required, beginning in 2026
Public metrics Posted annually by impacted payers, initial metrics due March 31, 2026

The information gain is in the first row. If your coverage is an employer sponsored plan that is not one of those payer types, these particular federal timeframes are not the rule that governs your request. Many states set their own prior authorization timelines for the plans they regulate, and plans set their own service standards. Your state Department of Insurance is the body that can say what applies where you live, and your plan document is the authority for your plan.

When a request is denied

The NAIC's consumer article describes the sequence available to a member without prescribing an outcome. Its first suggestion is to call the health plan to understand the stated reason, since a request that failed on missing or incorrect information may be resolved by correcting it. Beyond that, it describes working with the provider's office to submit an appeal with additional supporting information, following the health plan's instructions, and it adds: "Contact your state insurance department to help guide you through the process or help you file a complaint if appropriate."

HealthCare.gov sets out the general two stage structure for plans it covers, on its page about appealing an insurance company decision. "You have the right to an internal appeal," meaning you "may ask your insurance company to conduct a full and fair review of its decision," and "if the case is urgent, your insurance company must speed up this process." Then: "You have the right to take your appeal to an independent third party for review. This is called an external review," with the effect that "the insurance company no longer gets the final say over whether to pay a claim."

Whether an appeal is worth pursuing, and on what grounds, is not something an article can judge. The denial notice states the reason and the deadline, and the plan, your clinician's office and your state regulator are the parties who can act on it.

What happens after an approval

An approval settles the coverage question for that service. It does not settle what you owe.

Once the claim is processed, the ordinary cost sharing runs: the deductible until it is met, then coinsurance or a copayment, calculated against the figure the plan allows. That sequence is set out in our guide to how a deductible and coinsurance work, and it is the reason an authorized service can still produce a substantial patient responsibility.

This is also why HealthCare.gov's sentence about preauthorization not being a promise of payment is worth keeping in view. Authorization, coverage and payment are three separate determinations made at three different moments, and a yes at the first does not settle the third.

Where to take a question this article cannot answer

Your clinician's office, for anything about the care itself and for submitting or resubmitting an authorization request. Your plan's member services, for whether a service requires authorization, what a pending or denied status means and what the reason code says. Your plan administrator or benefits contact, for what the plan document requires. Your state Department of Insurance, for the timelines and rules that apply to plans regulated in your state and for complaints; the National Association of Insurance Commissioners maintains the directory of state insurance departments, read September 8, 2026. Nothing on this site interprets a diagnosis, a treatment plan or a clinical necessity determination.

Frequently asked questions

What is prior authorization in health insurance?
The NAIC defines it as a requirement for "your doctor or provider to obtain approval from your health plan before providing health care services or prescribing prescription drugs." HealthCare.gov describes preauthorization as a decision by the plan that a service, treatment plan, drug or piece of equipment is medically necessary.

Does prior authorization guarantee my plan will pay?
No. HealthCare.gov states that "preauthorization isn't a promise your health insurance or plan will cover the cost." Coverage and payment are determined when the claim is processed, and ordinary cost sharing still applies.

How long does a plan have to decide?
It depends on the plan. Under the CMS Interoperability and Prior Authorization Final Rule, impacted payers, which CMS lists as Medicare Advantage organizations, Medicaid and CHIP fee-for-service programs, Medicaid and CHIP managed care entities and QHP issuers on the federally facilitated exchanges, must send decisions within 72 hours for expedited requests and seven calendar days for standard requests. Other plans are governed by state rules and their own standards.

What happens if prior authorization was not obtained?
The NAIC states that "without prior authorization, your health plan may not pay for your treatment or medication." The claim may be denied or held, and the plan's notice states the reason and what process is available.

Is emergency care subject to prior authorization?
CMS states that emergency services "must continue to be covered without any prior authorization, and regardless of whether or not a provider or facility is in-network." Questions about how that applied to a particular bill can go to the federal No Surprises Help Desk on 1-800-985-3059.


Sources, all read September 8, 2026: HealthCare.gov glossary, "Preauthorization," no date shown. National Association of Insurance Commissioners, "What Is Prior Authorization?", dated November 5, 2024. Centers for Medicare and Medicaid Services, "CMS Interoperability and Prior Authorization Final Rule CMS-0057-F" fact sheet, dated January 17, 2024. CMS, "Ending Surprise Medical Bills," dated September 10, 2024. HealthCare.gov, "How to appeal an insurance company decision," no date shown. NAIC state insurance department directory. No dollar amount, denial rate or universal timeline is asserted in this article; the timeframes stated are attributed to the payer types CMS names in the rule.