The numbers describe a market that has stopped fighting. Across HealthCare.gov plans in 2023, insurers denied 86 million in-network claims; consumers appealed 376,508 of them — an appeal rate below 1%.1 On the provider side, the industry's own estimate is that up to 65% of denied claims are never resubmitted at all.2 The claims simply die, written off as the cost of participating in American billing.
The usual reading is fatigue, or ignorance of the appeal right. The record suggests something less flattering to the system and more flattering to the practices: the math. When providers do fight, they win more often than they lose — Premier's survey found 54.3% of private-payer denials ultimately overturned and paid.3 A majority-win game that almost nobody plays is not evidence of apathy. It is evidence that the entry fee exceeds the pot.
<1%1
of denied in-network marketplace claims are ever appealed (2023)
65%2
of denied claims never resubmitted, per the industry's own upper estimate
54.3%3
of private-payer denials ultimately overturned when someone does fight
Both sides of the ledger
The cost side is measured, repeatedly and consistently. MGMA puts the cost of reworking one denied claim at $25.20 at the practice level.4 Premier, surveying providers on full claims adjudication, measured $43.84 per claim in 2022 and $57.23 in 2023.5 For formal appeals in hospital settings, the figure MGMA cites runs to an average of $118 per denied claim.6 These measure different depths of the same fight — see the methodology — but they bracket the entry fee: roughly $25 to $118 of staff time per denial.
The revenue side, for the visits that fill a small practice's day, is public. Medicare's 2026 physician fee schedule pays a national non-facility rate of $95.19 for a 99213 office visit7 and $135.61 for a 99214.8 Put the two ledgers on one scale and the problem is visible before any algebra:
Sources 4–8. Cost figures measure different units of work (rework vs. adjudication vs. formal appeal); revenue figures are 2026 national non-facility Medicare rates before locality adjustment.
The break-even, computed in the open
Take a staff cost of $50 per appeal — a round figure inside Premier's measured $43.84–$57.23 range. If winning were guaranteed, any claim above $50 would be worth fighting. It is not guaranteed: at the 54.3% overturn rate, the expected recovery on a claim worth V is 0.543 × V, and the expected-value break-even rises to $50 ÷ 0.543 ≈ $92. A 99213 — the workhorse visit of American primary care — clears that threshold by about three dollars of claim value, which is to say: appealing the most common denial a small practice sees returns less than $2 of expected profit.
| Claim value | Appeal cost | Net if the appeal wins | Expected net (54.3% win rate) | Verdict |
|---|---|---|---|---|
| $50 — small claim (illustrative) | $50 | $0 | −$22.85 | Never pays; even a guaranteed win only breaks even |
| $95.19 — 99213 visit7 | $50 | +$45.19 | +$1.69 | A coin flip for pocket change |
| $135.61 — 99214 visit8 | $50 | +$85.61 | +$23.64 | Marginal — pays less than the hour it consumes |
| $400 — procedure (illustrative) | $50 | +$350.00 | +$167.20 | Pays |
| $1,000 — imaging / surgery (illustrative) | $50 | +$950.00 | +$493.00 | Pays decisively |
Assumptions: $50 staff cost per appeal (inside Premier's measured range, sources 3 and 5); 54.3% overturn rate (source 3). The $50, $400, and $1,000 claim values are illustrative; the E/M rates are Medicare 2026 national non-facility amounts (sources 7–8). Expected net = 0.543 × claim value − $50.
The table locates exactly where the giving-up concentrates: not on the expensive imaging study or the surgical claim, where the fight funds itself several times over, but on the low-hundreds E/M visits that make up most of a primary-care practice's revenue. A practice whose denied claims are mostly 99213s is not failing to defend its revenue when it writes them off. It is defending its payroll. And the threshold moves with the cost: at the $118 formal-appeal figure, the expected-value break-even climbs to about $217 — a level at which even a 99214 loses money in expectation, win rate and all.
This is the mechanism behind the opening statistics. A 54.3% win rate coexists with a sub-1% appeal rate because the winnable fights are not worth having at the prevailing price of fighting. Payers do not need denials to survive review; they need them to cost more to contest than the claim is worth. On claims under roughly $92, at current costs, that condition holds automatically.
What would have to change in the math
The break-even has only two inputs: cost and win rate. The win rate is the weaker lever. It is already above half, it cannot exceed one, and even a perfect 100% win rate at $50 of cost still abandons every claim under $50 — which excludes a large share of the lab work, imaging components, and brief visits that get denied in volume.
The cost lever scales the threshold linearly, all the way down. At $25 of cost per appeal, the expected-value break-even falls to about $46 — below the 99213, which flips the largest single category of small-practice denials from write-off to worth fighting. At $10, the threshold is about $18. At $5, about $9, and nearly every denied claim in the practice becomes rational to contest. Nothing else in the system has to move: not the payer's behavior, not the win rate, not the fee schedule. The economics of giving up are an equation with one dominant variable, and the equation is indifferent to how that variable falls — cheaper staff time, better tooling, batching, delegation. What it is not indifferent to is whether it falls. Until it does, a sub-1% appeal rate is not a failure of nerve. It is arithmetic, done correctly, by people who cannot afford to do it wrong.
Sources
- 1KFF — Claims denials and appeals in ACA marketplace plans (86M in-network denials; 376,508 appeals; rate under 1%) · 2023 data
- 2HFMA — Success in proactive denials management and prevention (up to 65% of denied claims never resubmitted) · series
- 3Premier — Trend Alert: private payers retain profits by refusing or delaying legitimate claims (54.3% of denials ultimately overturned; $43.84/claim) · Mar 2024 (2022 activity)
- 4MGMA — 6 keys to addressing denials in your medical practice's revenue cycle (average cost to rework a claim: $25.20) · series
- 5Premier — Claims adjudication costs providers $25.7B ($43.84/claim in 2022 to $57.23 in 2023) · 2024–2025 (2023 activity)
- 6MGMA — 4 keys to driving down denials (average $118 per denied claim to appeal; 63% recoverable) · series
- 7MedFeeSchedule — CPT 99213, 2026 Medicare national non-facility rate $95.19 (per CMS physician fee schedule) · 2026 PFS
- 8MedFeeSchedule — CPT 99214, 2026 Medicare national non-facility rate $135.61 (per CMS physician fee schedule) · 2026 PFS
