Where independent external review goes unused
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.
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.
Get my Appeal Kit, $2914-day refund, no questions, one email to hello@getaxionlabs.com. If the independent reviewer upholds the denial, send us the decision and we refund.
Largest denial volumes, with how rarely external review was reached
| Insurer | State | Claims denied | External reviews | Denials per review |
|---|---|---|---|---|
| Blue Cross Blue Shield of Texas | Texas | 13,945,257 | 107 | 1 in 130,330 |
| Centene Venture Company Florida | Florida | 5,291,270 | 258 | 1 in 20,509 |
| Blue Cross and Blue Shield of NC | North Carolina | 4,465,115 | 100 | 1 in 44,651 |
| Blue Cross and Blue Shield of Florida | Florida | 3,199,676 | 11 | 1 in 290,880 |
| Blue Cross and Blue Shield of Alabama | Alabama | 3,008,219 | 13 | 1 in 231,401 |
| Celtic Insurance Company | Texas | 2,698,996 | 0 | none filed |
| Blue Cross and Blue Shield of South Carolina | South Carolina | 2,323,759 | 246 | 1 in 9,446 |
| SelectHealth, Inc. | Utah | 1,741,801 | 3,028 | 1 in 575 |
| BlueCross BlueShield of Tennessee | Tennessee | 1,719,613 | 13 | 1 in 132,278 |
| Superior Health Plan | Texas | 1,556,425 | 0 | none filed |
| Blue Cross Blue Shield of Oklahoma | Oklahoma | 1,517,965 | 16 | 1 in 94,873 |
| Community Health Choice, Inc. | Texas | 1,462,532 | 0 | none filed |
| HMO Louisiana, Inc. | Louisiana | 1,360,028 | 174 | 1 in 7,816 |
| Blue Care Network of Michigan | Michigan | 1,248,675 | 68 | 1 in 18,363 |
| UnitedHealthcare Insurance Company | Alabama | 1,120,917 | 0 | none filed |
| Celtic Insurance Company | Tennessee | 1,099,147 | 23 | 1 in 47,789 |
| Ambetter of Magnolia Inc. | Mississippi | 1,048,108 | 0 | none filed |
| Absolute Total Care, Inc | South Carolina | 1,027,842 | 15 | 1 in 68,523 |
| Celtic Insurance Company | Missouri | 981,732 | 0 | none filed |
| Oscar Insurance Company | Texas | 829,696 | 51 | 1 in 16,269 |
| UnitedHealthcare of Florida, Inc. | Florida | 703,125 | 0 | none filed |
| Coordinated Care Corporation Indiana | Indiana | 671,270 | 70 | 1 in 9,590 |
| Common Ground Healthcare Cooperative | Wisconsin | 639,167 | 0 | none filed |
| Celtic Insurance Company | Kansas | 621,666 | 29 | 1 in 21,437 |
| Buckeye Community Health Plan | Ohio | 603,488 | 11 | 1 in 54,863 |
| Health First Commercial Plans, Inc. | Florida | 573,724 | 0 | none filed |
| Health Net of Arizona, Inc. | Arizona | 518,619 | 50 | 1 in 10,372 |
| Oscar Insurance Company | Tennessee | 500,557 | 30 | 1 in 16,685 |
| Celtic Insurance Company | Alabama | 487,433 | 19 | 1 in 25,654 |
| Celtic Insurance Company | Oklahoma | 458,772 | 18 | 1 in 25,487 |
| Capital Health Plan | Florida | 448,953 | 0 | none filed |
| Florida Health Care Plan, Inc. | Florida | 419,165 | 0 | none filed |
| Molina Healthcare of Texas, Inc. | Texas | 391,061 | 0 | none filed |
| UnitedHealthcare Insurance Company | Louisiana | 382,768 | 0 | none filed |
| UnitedHealthcare of North Carolina, Inc | North Carolina | 363,243 | 0 | none filed |
| Sendero Health Plans, Inc. | Texas | 336,574 | 0 | none filed |
| HMO Partners, Inc. | Arkansas | 297,161 | 0 | none filed |
| Anthem Insurance Companies, Inc. | Indiana | 293,847 | 11 | 1 in 26,713 |
| Security Health Plan of Wisconsin, Inc. | Wisconsin | 287,953 | 0 | none filed |
| QCA Health Plan, Inc. | Arkansas | 286,478 | 0 | 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)
- We cannot overturn your denial. Only your plan, or an independent reviewer, can do that.
- We cannot make your plan cover a service it genuinely excludes.
- We cannot guarantee external review applies to your denial. It covers medical judgment, experimental or investigational determinations, and rescission, a purely administrative denial may not qualify, and we say so on those pages rather than selling you past it.
- We have no customer testimonials and publish none. Our evidence is the federal dataset and the regulation cites, both of which you can check.
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 →
Or let the $29 Appeal Kit date each step and write the claim-file and external-review requests.
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.comEverything 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.
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).