Time-limited
Federal external review: filing deadline extended to October 2, 2026
The HHS-administered federal process was closed between July 1 and August 3, 2026 and reopened on July 31. If that closure stopped you filing, you may have until October 2, 2026. It applies in Alabama, Florida, Georgia, Texas and Wisconsin — and in any state to a self-insured non-Federal governmental plan that uses the federal process.
CMS — External appealsState 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
All other states run their own program.
All 51 guides — who runs your review, and what is distinctive
Every state and the District of Columbia, each written from that jurisdiction's own statutes and regulator. The badge shows whether the state runs its own program or defaults to the federal HHS process.
- ALAlabamaFederal HHSThe appeal leaves the state: it is decided by a federal contractor, not by Montgomery.
- AKAlaskaState program180 days, and the request can go to the insurer or straight to the Division.
- AZArizonaState programThe last of four appeal levels — a specialist physician chosen by the state, and no fee.
- ARArkansasState programFour months to file — but the benefit in dispute has to be at least $500.
- CACaliforniaState programFree, binding, and six months to file — a longer window than the federal one.
- COColoradoState programThe carrier has to ask the state who will review its own denial — and then pay for it.
- CTConnecticutState programReviews eligibility and rescission too — not only whether the care was necessary.
- DEDelawareState programWhile the appeal is pending, medical debt collectors are told to stand down.
- DCDistrict of ColumbiaState programTwo physicians decide, and you can ask to appear in person.
- FLFloridaFederal HHSNot a state program: eligible denials go to the federal HHS process run by MAXIMUS.
- GAGeorgiaFederal HHSACA denials route federally to MAXIMUS, while Georgia's own independent review keeps running alongside it — carrier-paid, with a $500 floor.
- HIHawaiiState program130 days, a $15 fee refunded if you win — and a health-coverage law that predates the ACA by 36 years.
- IDIdahoState programAn internal appeal that goes 35 days without an answer stops being a barrier.
- ILIllinoisState programState-run review filed with IDOI rather than the insurer — free, randomly assigned, and two of every three requests are ruled ineligible.
- INIndianaState programThe reviewer has to be board certified in the specialty at issue — and answers in 15 business days.
- IAIowaState programAn urgent request can be started by telephone — the paperwork catches up afterwards.
- KSKansasState programThe treating physician can file it — the statute names the provider as a requester.
- KYKentuckyState programAn urgent case is decided in 24 hours — a third of the time most states allow.
- LALouisianaState programSilence counts: no grievance decision in 30 days and the internal process is treated as exhausted.
- MEMaineState programTwelve months to apply — the longest external-review window in the country.
- MDMarylandState programAn independent expert reviews it — then the Insurance Commissioner can order the carrier to pay.
- MAMassachusettsState programState-run review at the Health Policy Commission — random reviewer, $25 fee, 43.5% overturned in 2024.
- MIMichiganState programState-run PRIRA review through DIFS — free, 127 days to file, and the Director signs the binding decision.
- MNMinnesotaState programSix months to file — but first work out which of two agencies your plan belongs to.
- MSMississippiState programThe fast track opens only on the treating provider's written certification — not on the patient's account.
- MOMissouriState programNo filing deadline at all, and no requirement to exhaust the plan's appeals first.
- MTMontanaState programFiled with your insurer, which must draw a reviewer at random from the state's list.
- NENebraskaState programThe reviewer is drawn at random — but only from those qualified for that particular service.
- NVNevadaState programThe statute names the physician as someone who receives the denial and files the review — four months, in their own right.
- NHNew HampshireState program180 days, no cost — and dental plans are inside the scheme, not outside it.
- NJNew JerseyState programStage 3 after the carrier's two internal appeals: free, and decided inside 45 days.
- NMNew MexicoState programThe provider is a named grievant, the plan pays the reviewer, and the answer comes in 20 days.
- NYNew YorkState programThe state assigns the reviewer, decides in 30 days, and refunds a provider's fee on a win.
- NCNorth CarolinaState programState-run review through Smart NC — free, 120 days from receipt, and the reviewer comes off a statutory alphabetical rotation.
- NDNorth DakotaState programWhich reviewer hears the case depends on how old the policy is — and a new prior-auth law lands in 2026.
- OHOhioState programState-run review under ORC Chapter 3922 — 180 days, filed with the insurer, and the reviewer drawn at random by the state.
- OKOklahomaState programThe form goes to the Department itself — not through the insurer that issued the denial.
- OROregonState program180 days, a reviewer drawn at random, and four years of published results.
- PAPennsylvaniaState programThe country's newest state program — Act 146 external review, filed with the Insurance Department; free, about half overturned.
- RIRhode IslandState programA $25 fee that comes back if you win, and a reviewer taken in strict rotation.
- SCSouth CarolinaState programSixty days on the standard track — and only 15 on the expedited one, which stage-four cancer imaging is routed to.
- SDSouth DakotaState programFour months to file — then almost every deadline that follows belongs to the insurer.
- TNTennesseeState programA state process filed with the carrier, which also assigns the reviewer — six months to file, no cost, and the provider can file in its own name.
- TXTexasFederal HHSFederal HHS process for most plans — alongside the country's oldest state IRO statute and its first gold-carding law.
- UTUtahState program180 days from the payment — and the fast track closes once the care has been delivered.
- VTVermontState programThe longer of 120 days or four months — and a free advocate who can do the filing.
- VAVirginiaState programState-run external review through the SCC Bureau of Insurance — 120 days, no fee, and the request form lets a provider be the filer.
- WAWashingtonState programYou file with the carrier, but the Commissioner controls the reviewer rotation — 180 days, no cost, every decision since 2016 public.
- WVWest VirginiaState programA 90% approval record can take a procedure out of prior authorization altogether.
- WIWisconsinFederal HHSThe one state where the insured picks the reviewer — from the commissioner's certified list.
- WYWyomingState programMedical necessity only — and the request goes to the carrier, not the Department.
Filing windows differ more than most summaries admit — Maine allows 12 months, Hawaii 130 days, and New York gives a provider 60. Each guide states its own deadline against that state's source, and we don't list a filing URL or a day count we haven't verified.
Before external review
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.
