Molina physical therapy denied: how to appeal

Quick answer

If Molina Healthcare denied your physical therapy, you can appeal, and the plan must give you its file and the criteria it used. Filing windows by plan type: 60 days from the notice (Medicaid managed care); at least 180 days (insured and Marketplace plans); 65 days from the notice (Medicare Advantage). The date printed on your denial notice controls; it can only be later than these floors, never earlier.

Why Molina Healthcare denies physical therapy

Molina Healthcare is concentrated in Medicaid managed care, with smaller marketplace and Medicare Advantage footprints. Appeal pathways depend heavily on the underlying line of business and the state Medicaid agency that contracts with Molina.

For physical therapy specifically: Physical, occupational, and speech therapy are denied after a visit cap, when the plan decides progress has stopped, or when it labels care 'maintenance'. Denials are small per visit and large in total, and the maintenance argument is often wrong.

The law that controls this appeal

For Medicare, therapy is covered when it requires the skills of a therapist, including maintenance therapy where skilled care is needed to maintain function or prevent deterioration (Jimmo v. Sebelius settlement; Medicare Benefit Policy Manual, Chapter 15). Medicare has no hard visit cap; claims above a threshold require the KX modifier attesting medical necessity. ACA-compliant individual and small-group plans must cover rehabilitative and habilitative services as an essential health benefit (45 CFR 156.115), and mental-health parity rules limit non-quantitative treatment limits. Plan visit limits and criteria must be disclosed on request.

At a glance

Molina Healthcare appeals: the rule, the deadline and the next level, by plan type

Which row applies depends on the plan you hold, not on Molina Healthcare's brand. Your ID card, the Summary Plan Description and the denial letter say which.

Plan type	Rule that governs	File your appeal within	The plan must answer	If the plan says no again
Medicaid managed care plan A Medicaid plan run by the carrier under a state contract. The card says Medicaid, Medi-Cal, STAR, HealthChoice or your state's programme name.	42 CFR Part 438, Subpart F (plan appeals) and 42 CFR Part 431, Subpart E (state fair hearings).	60 calendar days from the date on the notice of adverse benefit determination to request the plan's appeal (42 CFR 438.402(c)(2)(ii)). State fair hearing: within 120 calendar days of the plan's appeal decision (§ 438.408(f)(2)).	Standard appeal: 30 calendar days. Expedited: 72 hours (42 CFR 438.408(b)).	A state fair hearing after the plan's single level of appeal (§ 438.402(b)); some states add an external medical review. Benefits continue during the appeal if you ask within 10 calendar days of the notice (§ 438.420).
Fully insured employer, individual or Marketplace plan The carrier holds the risk and is licensed in your state. Small employers and almost all individual and HealthCare.gov plans.	45 CFR 147.136 (Public Health Service Act § 2719), which applies the 29 CFR 2560.503-1 procedures and adds state external review; state insurance law on top.	At least 180 days from the denial (45 CFR 147.136(b); 29 CFR 2560.503-1(h)(3)(i)).	Urgent care: 72 hours. Pre-service: 30 days. Post-service: 60 days. Prior-authorization decisions by Marketplace issuers from 2026: 72 hours expedited, 7 calendar days standard (CMS-0057-F).	External review through your state's process, or the federal process where the state has none, generally within 4 months of the final internal denial (45 CFR 147.136(c), (d)). The state insurance department and its Consumer Assistance Program take complaints.
Medicare Advantage (Part C) A private plan that replaces Original Medicare. The card says Medicare Advantage, HMO, PPO or PFFS.	42 CFR Part 422, Subpart M (§§ 422.560 to 422.634). Coverage decisions must follow Original Medicare rules (42 CFR 422.101).	65 calendar days from the date on the denial notice to request the plan's reconsideration (42 CFR 422.582, as amended effective 1 January 2025).	Expedited: 72 hours. Standard pre-service: 30 days (7 days for Part B drugs). Payment: 60 days (42 CFR 422.590).	If the plan does not fully reverse itself it must send the case to the Independent Review Entity on its own (42 CFR 422.592); then an ALJ hearing when the amount in controversy meets the annual threshold, the Medicare Appeals Council and federal court. State external review does not apply.

Medicaid managed care plan

What you can demand. Free copies of the case file, medical records and the criteria used, before and during the appeal (42 CFR 438.406(b)(5)). Children under 21 have EPSDT rights to medically necessary care (42 U.S.C. 1396d(r)(5)).

How to open the appeal. Cite 42 CFR 438.402 and 438.406(b)(5): request the case file and the criteria, ask for continued benefits within 10 days, and reserve the state fair hearing.

Fully insured employer, individual or Marketplace plan

What you can demand. The plan must give you the claim file, the criteria it applied and any new evidence or rationale before the final decision, free of charge (45 CFR 147.136(b)(2)(ii)(C); 29 CFR 2560.503-1(h)(2)(iii)).

How to open the appeal. Cite 45 CFR 147.136 and 29 CFR 2560.503-1: request the claim file and the criteria, note the decision clocks, and name the state external-review right.

Medicare Advantage (Part C)

What you can demand. The plan may not apply internal criteria that are more restrictive than Medicare's national and local coverage determinations, and must decide medical necessity on your individual circumstances (42 CFR 422.101(b), (c)). You can ask for the case file and the criteria used.

How to open the appeal. Cite 42 CFR 422.582 and 422.101(c): the plan must decide on your individual circumstances under Medicare coverage rules, and must forward an unfavorable reconsideration to the IRE itself.

Reported denial rates

In the CMS Transparency in Coverage data for plan year 2026 (2024 claims), the 9 Molina Healthcare-family Marketplace issuer filings across 9 states reported in-network claim denial rates from 20.8% to 34.9% (median 22.9%). Issuer-level, self-reported, HealthCare.gov plans only; a denial includes duplicate and administrative denials.

Molina Healthcare denial rate: every state, three years →

Primary sources for this table

Windows are federal floors or the rule as written; the denial notice controls. Reviewed 13 September 2026. General information, not legal advice; Apellica is not a law firm.

What Molina Healthcare denies for physical therapy

The physical therapy services most often denied:

Visits beyond a plan's annual limit
Continued therapy after the plan decides the patient has plateaued
Habilitative therapy for children with developmental conditions
Therapy after surgery when the plan's protocol allows fewer visits
Speech therapy for stroke, brain injury, or developmental delay

Why physical therapy claims get denied

A typical Molina Healthcare physical therapy denial almost always cites one of these reasons. Each one maps to a specific rebuttal in the appeal:

Plan says the patient has reached 'maximum medical improvement'
Care labeled 'maintenance' or 'could be done as a home program'
Progress notes lack measurable functional goals
Visit limit reached under the plan's benefit design
Referral or plan of care not signed or renewed

The Molina Healthcare appeal process

Appeal levels: Plan internal appeal, then state Medicaid fair hearing for Medicaid lines. Marketplace: internal then federal external review. Medicare Advantage: federal 5-level ladder.

Carrier timing: Medicaid filing windows are state-specific, commonly 60-120 days from the action notice. Continuation-of-benefits typically requires filing within 10 days. Marketplace: 180 days internal, 4 months external.

Physical therapy timing: Internal appeal: at least 180 days to file for commercial and employer plans; pre-service decisions within 30 days, post-service within 60 (29 CFR 2560.503-1). Medicare Advantage: 65 days to request reconsideration. Ongoing therapy after surgery or stroke may qualify as urgent (72-hour decision).

What we know about Molina Healthcare: Molina appeals are most often won at the state fair-hearing stage. We preserve continuation-of-benefits where the timing permits and brief the case to the state's administrative law judge.

Common Molina Healthcare denial patterns for physical therapy

State Medicaid fair-hearing escalation. Molina Medicaid denials must first run through the plan's internal grievance and appeal process. After plan-level denial, the member has the right to a state Medicaid fair hearing, a separate administrative track that frequently overturns prior-auth and medical-necessity denials.
Continuity-of-care protections. Medicaid rules generally require continuation of previously authorized services pending the outcome of a timely-filed appeal. Members who file within the state's continuation window (often 10 days from the action notice) preserve services during the appeal.
EPSDT-based denials in pediatric cases. For Molina members under 21, federal EPSDT (Early and Periodic Screening, Diagnostic, and Treatment) requirements broaden coverage beyond the adult benefit. Many pediatric denials reverse on appeal once the EPSDT framework is cited.

How to win your Molina Healthcare physical therapy appeal

Strategy for physical therapy: The decisive question is whether the denial says you stopped improving or says you ran out of visits, because they are different arguments. If the letter uses the language of plateau, maintenance, maximum medical improvement, or says the work could be done as a home programme, that is the improvement standard, and for Medicare it is not a lawful basis on its own. The Jimmo v. Sebelius settlement confirmed that skilled therapy is covered where the skill of a therapist is needed to maintain function or to slow deterioration, even when no further improvement is expected. Making that argument concrete is what wins: the notes have to show why a licensed therapist is required rather than a carer or a handout, which usually means documenting the clinical judgement being exercised, the safety risk being managed, the adjustments made session to session, and what specifically would deteriorate without skilled input. Measurable functional goals expressed in daily activity, such as transfers, stair negotiation, gait distance or fall incidents, carry far more weight than range-of-motion numbers alone. If instead the plan has applied a hard visit cap, the argument is different: check whether the cap is a true plan exclusion or a soft limit that medical necessity can exceed, and for Medicare note that the therapy threshold is not a cap at all but a point at which additional documentation is required, which the provider can supply. For children denied habilitative therapy, the mental health and substance use parity rules and many state habilitative-services mandates are additional routes, because habilitative care is a required benefit category in most plans rather than an optional one.

Filed against Molina Healthcare, that strategy rides on this procedural spine:

Procedural-rights anchor. Cite 42 CFR 438.402 and 438.406(b)(5): request the case file and the criteria, ask for continued benefits within 10 days, and reserve the state fair hearing. If your Molina Healthcare coverage is a different plan type (Fully insured employer, individual or Marketplace plan, Medicare Advantage), use that row of the table above instead; the rule and the deadline change with the plan, not the carrier.
Criteria-disclosure demand. Molina Healthcare frequently denies on "not medically necessary" without disclosing the clinical criteria applied. Once disclosed, those criteria become the rebuttal map.
Controlling-standard citation. For Medicare, therapy is covered when it requires the skills of a therapist, including maintenance therapy where skilled care is needed to maintain function or prevent deterioration (Jimmo v. Sebelius settlement; Medicare Benefit Policy Manual, Chapter 15). Medicare has no hard visit cap; claims above a threshold require the KX modifier attesting medical necessity. ACA-compliant individual and small-group plans must cover rehabilitative and habilitative services as an essential health benefit (45 CFR 156.115), and mental-health parity rules limit non-quantitative treatment limits. Plan visit limits and criteria must be disclosed on request.
Treating-provider attestation. A letter from the treating physician addressing each criterion in Molina Healthcare's own policy language. This is the single strongest evidentiary element.
Requested action. A specific demand to reverse the physical therapy denial and approve the service, not a general "please reconsider."

Documents you'll need for your Molina Healthcare physical therapy appeal

The denial letter and the plan's visit-limit or criteria language
Physician referral and signed plan of care
Therapy evaluation and progress notes with functional measures
Surgical or hospital records where therapy follows an event
Any prior authorization approvals and their dates

What a physical therapy appeal can recover

Typical recovery for physical therapy cases runs Individual visits are modest, but a denied course of therapy over months adds up to a meaningful sum; the amount at stake is the plan's allowed amount times the denied visits.. The exact figure depends on the specific service and your plan's contracted rates.

Molina Healthcare physical therapy appeals: frequently asked questions

Molina Healthcare says I have 'plateaued'. Does that end coverage?

Not by itself. For Medicare and Medicare Advantage, skilled therapy that maintains function or prevents decline is covered when it requires a therapist's skills. For commercial plans, the answer depends on the plan's criteria, which you can request.

I used all my visits. Can I appeal a Molina Healthcare visit limit?

You can ask whether the limit was applied correctly, whether the plan has an exception process, and whether a state mandate or the essential-health-benefit rule applies to your plan type. A benefit-limit denial is different from a medical-necessity denial.

My child's therapy was denied as 'developmental'. What now?

Habilitative services are an essential health benefit for ACA-compliant individual and small-group plans, and many states mandate coverage for specific conditions. The appeal should name the benefit category and the plan language.

How do I show therapy is still medically necessary to Molina Healthcare?

Measurable goals and measurable progress or a documented need for skilled maintenance. Ask the therapist to record functional scores at each re-evaluation and to state why a home program is not sufficient.

What Apellica does for Molina Healthcare physical therapy appeals

We file appeals against Molina Healthcare specifically configured to its internal review process. Every physical therapy appeal embeds the criteria-disclosure demand, the procedural-rights anchor, the controlling-standard citation above, treating-provider attestation language, and the peer-reviewed evidence relevant to the denied service.

Cost: $0 upfront. We work on contingency for Molina Healthcare appeals, if the appeal succeeds, we collect a percentage of the recovered claim value. If it fails, you owe nothing.

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Molina Healthcare denied your physical therapy? Here is what to do next