TMS denials: 56.7% overturned by independent reviewers
In 321 California IMR decisions from 2010 to 2025, reviewers overturned the plan 182 times (56.7%). In the last five years: 80.4% of 51. Denials reach IMR only when a member appeals all the way; read the caveats below before generalising.
By diagnosis
| Diagnosis category | Decisions | Overturned | Last 5 years |
|---|---|---|---|
| Mental Disorder | 314 | 56.7% | 80.0% of 50 |
By year (last five)
| Year | Decisions | Overturned |
|---|---|---|
| 2021 | 13 | 69.2% |
| 2022 | 13 | 84.6% |
| 2023 | 8 | 62.5% |
| 2024 | 9 | 100.0% |
| 2025 | 8 | 87.5% |
What the findings mention
| What the findings mention | Decisions | Overturned | All decisions here |
|---|---|---|---|
| Published evidence citedThe findings refer to peer-reviewed or published evidence. | 184 | 60.9% | 56.7% |
| Prior therapies failedThe findings mention treatments that were tried without adequate response. | 73 | 67.1% | 56.7% |
| Records did not supportThe findings say the documentation did not show what was needed (usually an upheld denial). | 46 | 2.2% | 56.7% |
| FDA approval or off-label use discussedThe findings discuss the FDA label status of the treatment. | 25 | 76.0% | 56.7% |
| Experimental or investigationalThe findings discuss whether the treatment is experimental. | 24 | 33.3% | 56.7% |
| Guidelines or criteria citedThe findings cite guidelines, criteria or a standard of care. | 15 | 46.7% | 56.7% |
| Alternatives contraindicatedThe findings mention a contraindication to the plan's preferred option. | 8 | 62.5% | 56.7% |
| Step therapy or fail-firstThe findings mention a fail-first requirement. | 5 | 40.0% | 56.7% |
Keyword matches on the reviewer’s findings, not causes. A tag that appears mostly in overturned decisions is worth documenting in an appeal; it is not a guarantee.
From recent overturned decisions
“The physician reviewer found that Nature of Statutory Criteria/Case Summary: A patient has requested authorization and coverage for 20 sessions of transcranial magnetic stimulation services. Per the medical records, the patient has major depressive disorder and has failed psychotherapy and multiple antidepressant medications and augmentation agents. In this patient’s case, 20 sessions of transcranial magnetic stimulation services are in accordance …”
“The physician reviewer found that a patient has requested authorization and coverage for transcranial magnetic stimulation (TMS) treatment. In this case, the record establishes that the patient has been diagnosed with treatment-resistant depression, which has been occurring for a significant duration of the patient’s life. In addition, the patient has a history of substance abuse, suicidal ideation (SI), and multiple …”
“The physician reviewer found that a patient has requested reimbursement for transcranial magnetic stimulation (TMS) treatment. In this case, the record establishes that the patient has treatment-resistant depression (TRD). Further, the patient has failed to respond to at least two adequate pharmacologic trials and psychotherapy. The consensus in the medical literature and clinical guidelines supports TMS as a medically appropriate …”
- California only: these are decisions by independent reviewers under California's IMR program (plans regulated by the Department of Managed Health Care). Other states and self-funded employer plans use different reviewers and rules.
- Selection: only denials that a member took all the way to IMR appear. Most denials are never appealed, and the ones that reach an external reviewer are not a random sample.
- Overturned means the reviewer disagreed with the plan; it does not mean the treatment worked or that a similar request will be approved.
- Argument tags are keyword matches on the reviewer's findings. They describe what the findings mention, not why the case was decided.
- Categories are DMHC's own labels (treatment sub-category and diagnosis category); 'Other' is a catch-all and is excluded from rankings.
Source: California Department of Managed Health Care, Independent Medical Review (IMR) Determinations, Trend (CHHS Open Data). Public California government data; Apellica's aggregates and tags are CC BY 4.0.
Questions
How often were TMS denials overturned?
In 321 California IMR decisions from 2010 to 2025, reviewers overturned the plan 182 times (56.7%). In the last five years: 80.4% of 51.
What did the reviewers' findings mention in overturned cases?
The table on this page counts keyword matches in the findings: prior therapies tried, contraindications, guidelines cited, published evidence, whether the records supported the request. They describe what the findings say, not why the case was decided.
Does a California IMR result apply to my plan?
Only California plans regulated by the Department of Managed Health Care go to IMR. Other states and self-funded employer plans use different reviewers, but the reasoning is the same kind: criteria, documentation and alternatives. Use the findings as a guide to what to document.
Related: California appeal rights · California external-review reversal rate · The levers library · CSV
Independent reviewers reverse plans when the record answers the criteria. Upload the denial letter; a senior reviewer reads it within 24 hours and tells you in writing whether it can be appealed and how. $0 upfront, 10% of what is recovered, nothing if we do not recover. Not a law firm.