External review

The independent review that binds the plan — by state.

When a plan upholds its own denial, external review hands the decision to an independent organization whose ruling the plan must follow. Where you file depends on your state — some run their own program, others default to the federal process.

State process vs. federal

Most states run their own external-review program through a state agency. A small number default to the federal HHS-administered process operated by MAXIMUS. And one rule cuts across all of it: ERISA self-funded plans use the federal process regardless of the state.

Federal-process states

ALFLGATXWI

All other states run their own program.

In-depth state guides

ALFederal process

Alabama

Defaults to the federal HHS-administered process (MAXIMUS).

How it works in Alabama
AK

Alaska

Runs its own external review through Alaska Division of Insurance.

How it works in Alaska
AZ

Arizona

State-run External Independent Review — the final step of Arizona's four-level appeal; no fee.

How it works in Arizona
AR

Arkansas

Runs its own external review through Arkansas Insurance Department.

How it works in Arkansas
CA

California

State-run Independent Medical Review (IMR) — free, binding, with a six-month filing window.

How it works in California
CO

Colorado

Runs its own external review through Colorado Division of Insurance.

How it works in Colorado
CT

Connecticut

Runs its own external review through Connecticut Insurance Department.

How it works in Connecticut
DE

Delaware

State-run external review — the Independent Health Care Appeals Program.

How it works in Delaware
DC

District of Columbia

Runs its own external review through DC Department of Insurance, Securities and Banking.

How it works in District of Columbia
FLFederal process

Florida

Uses the federal HHS-administered external review (MAXIMUS) — not a state-run program.

How it works in Florida
GAFederal process

Georgia

Defaults to the federal HHS-administered process (MAXIMUS).

How it works in Georgia
HI

Hawaii

Runs its own external review through Hawaii Department of Commerce and Consumer Affairs, Insurance Division.

How it works in Hawaii
ID

Idaho

Runs its own external review through Idaho Department of Insurance.

How it works in Idaho
IL

Illinois

Runs its own external review through Illinois Department of Insurance.

How it works in Illinois
IN

Indiana

Runs its own external review through Indiana Department of Insurance.

How it works in Indiana
IA

Iowa

Runs its own external review through Iowa Insurance Division.

How it works in Iowa
KS

Kansas

Runs its own external review through Kansas Insurance Department.

How it works in Kansas
KY

Kentucky

Runs its own external review through Kentucky Department of Insurance.

How it works in Kentucky
LA

Louisiana

Runs its own external review through Louisiana Department of Insurance.

How it works in Louisiana
ME

Maine

Runs its own external review through Maine Bureau of Insurance.

How it works in Maine
MD

Maryland

Runs its own external review through Maryland Insurance Administration.

How it works in Maryland
MA

Massachusetts

Runs its own external review through Massachusetts Office of Patient Protection.

How it works in Massachusetts
MI

Michigan

State-run external review — the Patient's Right to Independent Review Act (PRIRA).

How it works in Michigan
MN

Minnesota

Runs its own external review through Minnesota Department of Commerce.

How it works in Minnesota
MS

Mississippi

Runs its own external review through Mississippi Insurance Department.

How it works in Mississippi
MO

Missouri

Runs its own external review through Missouri Department of Commerce and Insurance.

How it works in Missouri
MT

Montana

State external review — filed with the insurer, which randomly assigns an IRO from the state list; 120-day window.

How it works in Montana
NE

Nebraska

Runs its own external review through Nebraska Department of Insurance.

How it works in Nebraska
NV

Nevada

Runs its own external review through Nevada Office for Consumer Health Assistance.

How it works in Nevada
NH

New Hampshire

Runs its own external review through New Hampshire Insurance Department.

How it works in New Hampshire
NJ

New Jersey

State-run IHCAP external review — free, the state assigns the reviewer; 45-day decisions.

How it works in New Jersey
NM

New Mexico

Runs its own external review through New Mexico Office of Superintendent of Insurance.

How it works in New Mexico
NY

New York

State-run external appeal through the DFS — the state assigns the reviewer; decisions in 30 days.

How it works in New York
NC

North Carolina

State-run external review — the Smart NC.

How it works in North Carolina
ND

North Dakota

Runs its own external review through North Dakota Insurance Department.

How it works in North Dakota
OH

Ohio

Runs its own external review through Ohio Department of Insurance.

How it works in Ohio
OK

Oklahoma

Runs its own external review through Oklahoma Insurance Department.

How it works in Oklahoma
OR

Oregon

State-run external review — the state randomly assigns the reviewer; a 180-day window, published outcomes.

How it works in Oregon
PA

Pennsylvania

Runs its own external review through Pennsylvania Insurance Department.

How it works in Pennsylvania
RI

Rhode Island

Runs its own external review through Rhode Island Office of the Health Insurance Commissioner.

How it works in Rhode Island
SC

South Carolina

Runs its own external review through South Carolina Department of Insurance.

How it works in South Carolina
SD

South Dakota

Runs its own external review through South Dakota Division of Insurance.

How it works in South Dakota
TN

Tennessee

Runs its own external review through Tennessee Department of Commerce and Insurance.

How it works in Tennessee
TXFederal process

Texas

Defaults to the federal HHS-administered process (MAXIMUS), not a state program.

How it works in Texas
UT

Utah

Runs its own external review through Utah Insurance Department.

How it works in Utah
VT

Vermont

State-run external review — the state rotates the reviewer; a generous deadline and a free consumer advocate.

How it works in Vermont
VA

Virginia

Runs its own external review through Virginia State Corporation Commission, Bureau of Insurance.

How it works in Virginia
WA

Washington

Runs its own external review through Washington State Office of the Insurance Commissioner.

How it works in Washington
WV

West Virginia

Runs its own external review through West Virginia Offices of the Insurance Commissioner.

How it works in West Virginia
WIFederal process

Wisconsin

Defaults to the federal HHS-administered process (MAXIMUS).

How it works in Wisconsin
WY

Wyoming

Runs its own external review through Wyoming Department of Insurance.

How it works in Wyoming

Every state — who runs your review

Whether your state runs its own external-review program or defaults to the federal HHS process. States with an in-depth guide are linked; the rest show the process that governs there.

For a state without a full guide yet: external review is requested through your state insurance department (state program) or through HHS / MAXIMUS (federal process), generally within four months of the final internal denial. We don't list a filing URL we haven't verified.

Build the internal appeal first.

External review usually opens only after internal appeals are exhausted. Upload a denied EOB and Merits builds that internal appeal — cited to the rule and timed to your plan's deadline.