Denial Facts

Where independent external review goes unused

By Axion Labs · August 19, 2026, updated November 4, 2026

Data verified November 4, 2026 · CMS Transparency in Coverage Public Use File (PY2027 release, PY2025 claims), data.healthcare.gov — US Government public domain

External review is free, decided by an organization your insurer does not control, and binding on the plan. Nationally it is used once for every 17,061 denials, and 22.2% (1,092 of 4,918; interval 22.2-23.8% for counts CMS withheld; 32.6% without SelectHealth) of the reviews that happen are overturned. This page lists the insurers with the largest volume of denials, and shows against each how little that stage was used.

83,907,852
Claims denied nationally
4,918
External reviews filed
1 in 17,061
Denials reaching review
22.2%
Of those, overturned
62
Insurers with zero filed
A card for a forum reply: 176,949 internal appeals not overturned, 4,918 external reviews filed.

Plain text to paste into a reply for somebody else. It holds the figures, who can ask for review, and the sources. The card never carries a price; its one denialfacts link comes last.

External review after a health insurance denial: the record so far
These are past decisions, not a prediction for any one case.

All insurers in the federal file (individual-market plans on HealthCare.gov, plan-year 2027 release, 2025 claims; employer plans are not in it):
  Internal appeals: 64,647 of 241,596 overturned (26.8%)
  External reviews: 1,092 of 4,918 overturned (22.2%)
  176,949 internal appeals were not overturned and 4,918 external reviews were filed. Not every upheld appeal qualifies for external review, so 176,949 is an upper bound on who could have asked.

California, health plans regulated by the DMHC only; not self-funded employer plans, which fall under the federal ERISA law:
  Independent Medical Review decisions, 2021 onward: 12,146 decisions, 65.4% overturned

Who can ask for external review: the person whose claim was denied, once the plan has upheld the denial on internal appeal or missed its own deadline to decide it, for a denial that turns on medical judgment, on a finding that the treatment is experimental or investigational, or on a rescission of coverage. A denial for an administrative or eligibility reason may not qualify.
When: generally within four months of the final internal denial (45 CFR 147.136).

Sources:
CMS Transparency in Coverage public use file, plan-year 2027 release (issued October 22, 2026): https://data.healthcare.gov/
DMHC, Independent Medical Review (IMR) Determinations, Trend (read September 25, 2026): https://data.chhs.ca.gov/dataset/independent-medical-review-imr-determinations-trend
45 CFR 147.136, internal claims and appeals and external review: https://www.ecfr.gov/current/title-45/section-147.136
Table: denialfacts.com/external-review-gap

The review itself is free federally; a state fee is capped at $25 per review. The Appeal Kit, $29, writes the request with your details in it. It dates your four-month window and lists what to enclose.

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14-day refund, no questions, one email to hello@getaxionlabs.com. If the independent reviewer upholds the denial, send us the decision and we refund.
Read the last column, not the first. A large denial count is a large book of business. A denial count of 17,059,387 across 62 insurer records against zero external reviews is something else: the one stage the insurer does not decide, and it went unused.

Largest denial volumes, with how rarely external review was reached

InsurerStateClaims deniedExternal reviewsDenials per review
Blue Cross Blue Shield of TexasTexas 13,945,257107 1 in 130,330
Centene Venture Company FloridaFlorida 5,291,270258 1 in 20,509
Blue Cross and Blue Shield of NCNorth Carolina 4,465,115100 1 in 44,651
Blue Cross and Blue Shield of FloridaFlorida 3,199,67611 1 in 290,880
Blue Cross and Blue Shield of AlabamaAlabama 3,008,21913 1 in 231,401
Celtic Insurance CompanyTexas 2,698,9960 none filed
Blue Cross and Blue Shield of South CarolinaSouth Carolina 2,323,759246 1 in 9,446
SelectHealth, Inc.Utah 1,741,8013,028 1 in 575
BlueCross BlueShield of TennesseeTennessee 1,719,61313 1 in 132,278
Superior Health PlanTexas 1,556,4250 none filed
Blue Cross Blue Shield of OklahomaOklahoma 1,517,96516 1 in 94,873
Community Health Choice, Inc.Texas 1,462,5320 none filed
HMO Louisiana, Inc.Louisiana 1,360,028174 1 in 7,816
Blue Care Network of MichiganMichigan 1,248,67568 1 in 18,363
UnitedHealthcare Insurance CompanyAlabama 1,120,9170 none filed
Celtic Insurance CompanyTennessee 1,099,14723 1 in 47,789
Ambetter of Magnolia Inc.Mississippi 1,048,1080 none filed
Absolute Total Care, IncSouth Carolina 1,027,84215 1 in 68,523
Celtic Insurance CompanyMissouri 981,7320 none filed
Oscar Insurance CompanyTexas 829,69651 1 in 16,269
UnitedHealthcare of Florida, Inc.Florida 703,1250 none filed
Coordinated Care Corporation IndianaIndiana 671,27070 1 in 9,590
Common Ground Healthcare CooperativeWisconsin 639,1670 none filed
Celtic Insurance CompanyKansas 621,66629 1 in 21,437
Buckeye Community Health PlanOhio 603,48811 1 in 54,863
Health First Commercial Plans, Inc.Florida 573,7240 none filed
Health Net of Arizona, Inc.Arizona 518,61950 1 in 10,372
Oscar Insurance CompanyTennessee 500,55730 1 in 16,685
Celtic Insurance CompanyAlabama 487,43319 1 in 25,654
Celtic Insurance CompanyOklahoma 458,77218 1 in 25,487
Capital Health PlanFlorida 448,9530 none filed
Florida Health Care Plan, Inc.Florida 419,1650 none filed
Molina Healthcare of Texas, Inc.Texas 391,0610 none filed
UnitedHealthcare Insurance CompanyLouisiana 382,7680 none filed
UnitedHealthcare of North Carolina, IncNorth Carolina 363,2430 none filed
Sendero Health Plans, Inc.Texas 336,5740 none filed
HMO Partners, Inc.Arkansas 297,1610 none filed
Anthem Insurance Companies, Inc.Indiana 293,84711 1 in 26,713
Security Health Plan of Wisconsin, Inc.Wisconsin 287,9530 none filed
QCA Health Plan, Inc.Arkansas 286,4780 none filed

Top 40 by volume of denials, of 97 insurer records reporting both figures. Source: CMS Transparency in Coverage Public Use File (PY2027 release, PY2025 claims), data.healthcare.gov — US Government public domain.

States where not one denial reached external review

Alaska (245,546 denied) · Arkansas (1,437,735 denied) · Delaware (449,381 denied) · Hawaii (203,127 denied) · Mississippi (1,141,675 denied) · Montana (323,019 denied) · New Hampshire (158,490 denied) · North Dakota (105,786 denied) · South Dakota (95,138 denied) · West Virginia (707,610 denied) · Wyoming (352,901 denied)

What this does and does not show. It does not show that any of these denials was wrong, nobody can say that about a review that never happened. It shows that the free, binding, independent stage of a two-stage federal appeal system is barely used, and that the people who do use it succeed 22.2% of the time. That gap is an information problem, which is the entire reason this site exists.
What we will not pretend.
Work out your two deadlines

The federal timeframes: 180 days from the date on the denial notice to file the internal appeal, then 4 months from the final internal denial to request independent external review. Put your date in and get the actual calendar dates, with the days remaining.

Runs entirely in your browser, the date you type is never sent to us and never stored. Open the full calculator →

This page exists because of one gap, and that gap is the reason the site exists at all: the stage that actually overturns denials is free, binding on the plan, and used once for every 17,061 denials. Read the last column against the first. A large denial count can simply mean a large book of business. A large denial count with no independent reviews behind it is a different thing, and it is worth knowing which of the two sent your letter.

Axion Labs · hello@getaxionlabs.com
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Everything you need for your appeal: your two deadlines, the argument that fits your denial reason, the letters, a brief for your doctor on what the reviewer checks, and the external review request. One payment. No subscription. No cut of your claim. Opens on screen the moment you pay. 14-day refund, no questions, one email to hello@getaxionlabs.com.

Where these numbers come from

Counts: CMS Transparency in Coverage Public Use File (PY2027 release, PY2025 claims), data.healthcare.gov — US Government public domain. Rights and timeframes: 29 CFR 2560.503-1 (180 days, and your free right to the claim file) and 45 CFR 147.136 (4 months, and what qualifies), explained at HealthCare.gov. Expedited review is decided in about 72 hours under both sections.

Reading either regulation from a script rather than a browser: eCFR answers automated fetches with a challenge page, so the same two sections are mirrored as government PDFs at govinfo.gov (29 CFR 2560.503-1) and govinfo.gov (45 CFR 147.136).

This page presents federal statistics and a general description of appeal rights created by federal law. It is not legal, medical, or insurance advice, and no outcome is guaranteed. Your denial letter and plan documents govern your specific case. Free help is available from your state's Consumer Assistance Program and from the federal Marketplace at HealthCare.gov.

How both appeals work → · All 152 insurer-state records →

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