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Internal vs. external review: the two levels of appeal

Appealing a denial is a ladder. You climb the internal appeal first; if that fails, an independent reviewer gets the final, binding word.

Internal appealExternal review
Who decidesThe insurerIndependent third party (IRO)
WhenRequired first stepAfter internal appeal is denied
Binding?No — it's the insurer's own callYes — binding on the insurer
CostFreeFree or nominal (e.g., up to $25 in some states, often refunded)
Overturn rate~44%~50%

Step 1 — Internal appeal

You ask the insurer to reconsider, in writing, with evidence. Federal rules generally require at least one level of internal appeal and a decision within set timeframes (faster for pre-service and urgent cases). This is where most denials are actually overturned — see the full step-by-step.

Step 2 — External review

If the internal appeal fails, you can request an external review by an independent organization with no stake in the outcome. Its decision is binding — if it sides with you, the insurer must cover the care. Depending on your plan, this runs through a state process or the federal (HHS-administered) process; your state page shows which applies to you.

How many times can I appeal?

Typically: one (sometimes two) internal levels, then one external review. Urgent situations can be expedited — and in some cases you can request external review at the same time as an urgent internal appeal. Watch your deadlines at every step.

Does my plan type change this?

Yes. Self-funded employer plans follow federal ERISA rules; individual, marketplace, and small-group plans usually follow state rules, which can offer stronger protections. CareCost determines which framework applies from your plan details.

Whichever level you're on, we generate the right letter — internal appeal, or an external-review request.

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Sources: HealthCare.gov, external review; 45 CFR §147.136 (internal claims and appeals and external review). General information, not legal advice — see our methodology.