Skip to main content
Dataset · v1.0 · Released 2026-05-19

The Apellica External Review Index.

How often a U.S. state-licensed Independent Review Organization overturns an insurance denial ranges from 17.0% in West Virginia to 80.0% in Connecticut. Most states do not even publish the number. This is the first comprehensive 2026 public-record dataset, with every cell anchored to a verifiable government source.

56
Jurisdictions covered
14
With measured rate
47
State-run programs
9
HHS-administered

Released by Apellica under CC-BY-4.0. Reuse it. Cite it. Improve it. Open an issue or send corrections to editorial@apellica.com.

What this dataset is

A working map of the data the system does not publish.

The Affordable Care Act gave every American with a fully-insured plan the right to ask a state-licensed Independent Review Organization to re-decide a denial after the insurer's own internal appeal process is exhausted. The reviewer is independent. The decision is binding on the insurer.

How often that reviewer sides with the patient is wildly different depending on which state you live in. And in most states, the regulator does not publicly publish the number at all.

This dataset assembles what each state's Department of Insurance, legislative report, or CMS publication says about their external-review program — in one place, with every number anchored to a verifiable public-record URL. Empty cells are deliberately empty when the underlying state has not published the number. We do not extrapolate.

The single largest finding of the exercise is that transparency itself is the lottery. 42 of 56 jurisdictions do not publish discoverable current external-review statistics. The patient who needs the data to decide whether to appeal has no way to get it.

The dataset

External-review reversal rate by jurisdiction.

Sorted by reversal rate (highest first). Click any row to open the source.
JurisdictionYearReversal rateCasesOverturnedSystemRegulator
Connecticut
CT
2024
80.0%
High reversal
state-runConnecticut Insurance Department / Office of the Healthcare Advocate
Notes

Healthcare Advocate office reports denials resolved/overturned in patient's favor ~80% of cases. Counts include both formal IRO reversals and pre-decision insurer concessions after advocate involvement. CT total denial rate among largest insurers was 14% in 2024.

California
CA
2024
72.7%
High reversal
state-runCalifornia Department of Managed Health Care (DMHC)
Notes

Headline: ~73% of IMR cases end with enrollee receiving requested service (full+partial overturn by IMRO + plan reversals during review). Of cases reaching final IMRO determination, overturn rate of treatment-denial decisions was 12.7% in 2024 (up from 10.2% in 2023). Full open-data trend file: https://data.chhs.ca.gov/dataset/independent-medical-review-imr-determinations-trend

Maryland
MD
2024
66.8%
High reversal
state-runMaryland Insurance Administration (MIA)
Notes

MIA reversed or modified the carrier's grievance decision 66.8% of the time in 2024, per MIA's 2024 Health Care Appeals and Grievance Law Report. Down 2.9 pts from prior year. Note: this is MIA's complaint-handling reversal rate, broader than IRO-only external review. Source PDF identified.

North Carolina
NC
2024
54.3%
High reversal
282153state-runNorth Carolina Department of Insurance (Smart NC)
Notes

Smart NC received 282 external review requests through November 2024 and overturned 153 (~53%). Per Smart NC and NBC News reporting (2025). Annual report: https://www.ncleg.gov/Files/Library/agency/doi13339.pdf

Kansas
KS
2024
54.0%
High reversal
state-runKansas Insurance Department
Notes

~54% overturn rate cited by NBC News (2025) attributing to Kansas Department of Insurance covering data since 2018. Cumulative period rate; not single-year. Department publishes Independent Medical Review program at: https://insurance.ks.gov/documents/department/publications/independent-medical-review.pdf

Pennsylvania
PA
2025
48.4%
Moderate
1,353655state-runPennsylvania Insurance Department (PID)
Notes

PA Independent External Review Program (launched 2024-01) referred 1353 eligible cases to IROs since inception through 2025; 655 overturned (~48%). First-year (2024) rate was 50.1%. Program is one of newest state-run replacements for HHS-administered process.

Colorado
CO
2024
44.0%
Moderate
state-runColorado Division of Insurance (DORA)
Notes

~44% overturn rate cited by Division (per NBC News 2025 coverage attributing to DORA). Statistical report exists but item-level external-review tables not extracted; flag as secondary citation.

Minnesota
MN
2024
43.0%
Moderate
state-runMinnesota Department of Commerce
Notes

43% of external reviews resulted in coverage denials being overturned in 2024, per Department of Commerce (cited via KSTP News). Filing fee dropped 2024-08-01 to increase access.

South Carolina
SC
2024
43.0%
Moderate
state-runSouth Carolina Department of Insurance
Notes

~43% of cases reversed in 2024 per NBC News attribution to SCDOI. SC DOI does not publish dedicated annual external-review report online; flag as secondary citation.

Massachusetts
MA
2023
40.0%
Moderate
state-runMassachusetts Office of Patient Protection (OPP) at Health Policy Commission
Notes

~40% of OPP external reviews resolved in patient's favor per OPP 2023 Annual Report referenced by MA HPC. 2024 report not yet located; flag as most-recent-published is 2023.

Oregon
OR
2025
38.9%
Moderate
278108state-runOregon Division of Financial Regulation (DFR)
Notes

Oregon DFR IRO Case Detail Report (current through 2025-06-30): 352 cases received, 278 completed full review, 108 overturned or partially overturned (39%), 170 upheld. Excel-format quarterly updates.

Washington
WA
2024
25.0%
Low reversal
state-runWashington Office of the Insurance Commissioner (OIC)
Notes

~25% overturn rate in 2024 per NBC News attribution to WA OIC. 2024 WA OIC Annual Report identified.

Arizona
AZ
2014
21.0%
Low reversal
state-runArizona Department of Insurance and Financial Institutions (DIFI)
Notes

Historic KFF-cited figure (21%). DIFI does not publish a current external-review annual report; flagged as stale.

West Virginia
WV
2024
17.0%
Low reversal
state-runWest Virginia Offices of the Insurance Commissioner
Notes

~17% overturn rate over the last 5 years (through 2024) per NBC News attribution to WV OIC. Cumulative period rate; not single-year. Significantly below national average.

Alabama
AL
2024
HHS-administered
HHS-administeredHHS-Administered Federal External Review (MAXIMUS Federal Services)
Notes

Data gap: HHS-administered process; CMS does not publish state-level case totals. Alabama has no state-run external review system.

Alaska
AK
Data gap
state-runAlaska Division of Insurance
Notes

Data gap: Division publishes annual reports but does not publicly itemize IRO external-review case totals or overturn rates.

American Samoa
AS
HHS-administered
HHS-administeredHHS-Administered Federal External Review (MAXIMUS Federal Services)
Notes

U.S. territory using HHS-administered federal process. CMS does not publish jurisdiction-level case totals.

Arkansas
AR
Data gap
state-runArkansas Insurance Department
Notes

Data gap: Arkansas Insurance Department does not publish a public external-review annual statistics report.

Delaware
DE
Data gap
state-runDelaware Department of Insurance
Notes

Data gap: Delaware's Independent Health Care Appeals Program (IHCAP) does not publicly post external-review tabular statistics.

District of Columbia
DC
Data gap
state-runDC Department of Insurance Securities and Banking (DISB)
Notes

Data gap: DISB does not publish a dedicated external-review annual statistics document.

Florida
FL
2024
HHS-administered
HHS-administeredHHS-Administered Federal External Review (MAXIMUS Federal Services)
Notes

Florida participates in HHS-administered federal external review (no compliant state-run process for federally regulated plans). FL OIR does not publish corresponding overturn statistics. Data gap on state-level totals.

Georgia
GA
2024
HHS-administered
HHS-administeredHHS-Administered Federal External Review (MAXIMUS Federal Services)
Notes

Georgia uses HHS-administered federal external review process per CMS classification (KFF 2024 listing). OCI took over Patient Rights to Independent Review Act duties from DCH on 2022-07-01 but does not publish overturn statistics.

Guam
GU
HHS-administered
HHS-administeredHHS-Administered Federal External Review (MAXIMUS Federal Services)
Notes

U.S. territory using HHS-administered federal process. CMS does not publish jurisdiction-level case totals.

Hawaii
HI
2023
Data gap
state-runHawaii Insurance Division (DCCA)
Notes

Data gap on count fields: Hawaii does publish an Annual External Review Report (2023 most recent located). Underlying PDF binary not parseable in our pipeline; cite the report URL directly.

Idaho
ID
Data gap
state-runIdaho Department of Insurance
Notes

Data gap: Idaho DOI does not publish public external-review statistics.

Illinois
IL
2024
Data gap
state-runIllinois Department of Insurance (IDOI)
Notes

Data gap on count fields: IDOI Annual Report to the Governor 2024 references external-review program but tabular case counts not extracted from binary PDF in our pipeline. Hotline: 877-850-4740.

Indiana
IN
Data gap
state-runIndiana Department of Insurance
Notes

Data gap: IROs must file annual reports with IDOI but the Department does not publish a consolidated public external-review statistics document.

Iowa
IA
Data gap
state-runIowa Insurance Division
Notes

Data gap: Iowa Insurance Division publishes annual reports but does not specifically itemize external-review overturn statistics in a discoverable form.

Kentucky
KY
Data gap
state-runKentucky Department of Insurance
Notes

Data gap: Kentucky DOI does not publish public external-review statistics.

Louisiana
LA
Data gap
state-runLouisiana Department of Insurance
Notes

Data gap: LDOI does not publish public external-review overturn statistics.

Maine
ME
2023
Data gap
state-runMaine Bureau of Insurance (Consumer Health Care Division)
Notes

Maine's Consumer Health Care Division publishes annual external review report incorporated into Superintendent's 2023 Annual Report. Specific case counts not extracted from binary PDF in our pipeline; cite source URL directly.

Michigan
MI
2024
Data gap
state-runMichigan Department of Insurance and Financial Services (DIFS)
Notes

Data gap on count fields: DIFS publishes PRIRA (Patient's Right to Independent Review Act) decisions individually on its site but does not publish consolidated overturn statistics in a discoverable form. 2024 DIFS Annual Report identified.

Mississippi
MS
2024
HHS-administered
HHS-administeredHHS-Administered Federal External Review (MAXIMUS Federal Services)
Notes

Mississippi historically classified as relying on HHS-administered federal process. Note KFF 2024 state list only flags 5 states (AL/FL/GA/TX/WI); MS may have shifted classification. Flag for re-verification.

Missouri
MO
Data gap
state-runMissouri Department of Commerce and Insurance
Notes

Data gap: Missouri DCI does not publish public external-review overturn statistics.

Montana
MT
Data gap
state-runMontana Commissioner of Securities and Insurance
Notes

Data gap: CSI Montana does not publish public external-review statistics.

Nebraska
NE
Data gap
state-runNebraska Department of Insurance
Notes

Data gap: Nebraska DOI does not publish public external-review statistics. Note: NE was previously HHS-administered; KFF 2024 list shows state-run, flag for verification.

Nevada
NV
Data gap
state-runNevada Division of Insurance
Notes

Data gap: Nevada Division of Insurance does not publish a discoverable external-review statistics report.

New Hampshire
NH
Data gap
state-runNew Hampshire Insurance Department
Notes

Data gap: NHID 2025 Annual Report identified but specific external-review counts not extracted.

New Jersey
NJ
Data gap
state-runNew Jersey Department of Banking and Insurance (DOBI) IHCAP
Notes

Data gap on count fields: DOBI's Independent Health Care Appeals Program (IHCAP) publishes periodic reports (48th IHCAP report identified) but case-level statistics not extracted from binary PDF in our pipeline. KFF 1998-era data cited Connecticut + NJ in 50-72% historic range.

New Mexico
NM
Data gap
state-runNew Mexico Office of Superintendent of Insurance (OSI)
Notes

Data gap: NM OSI does not publish public external-review overturn statistics.

New York
NY
2024
Data gap
state-runNew York Department of Financial Services (DFS)
Notes

NY DFS publishes the most extensive external-appeal database in the US (searchable: https://www.dfs.ny.gov/public-appeal/search). Aggregate 2024 counts referenced in DFS 2024 Annual Report; specific tables not extracted from binary PDF in our pipeline. Independent dashboard at https://appeal-explorer.persius.org

North Dakota
ND
Data gap
state-runNorth Dakota Insurance Department
Notes

Data gap: ND Insurance Department does not publish public external-review statistics.

Northern Mariana Islands
MP
HHS-administered
HHS-administeredHHS-Administered Federal External Review (MAXIMUS Federal Services)
Notes

U.S. territory using HHS-administered federal process. CMS does not publish jurisdiction-level case totals.

Ohio
OH
2019
Data gap
state-runOhio Department of Insurance
Notes

Data gap on count fields: Most recent publicly posted Annual Health Claims External Review Report is 2019. Ohio law requires annual publication but current-year reports not published online; flag as significant transparency gap.

Oklahoma
OK
Data gap
state-runOklahoma Insurance Department
Notes

Data gap: OID does not publish public external-review statistics.

Puerto Rico
PR
Data gap
state-runPuerto Rico Office of the Insurance Commissioner
Notes

KFF 2024 classifies Puerto Rico as operating an NAIC-parallel state-run external-review process; OCS does not publish public overturn statistics.

Rhode Island
RI
Data gap
state-runRhode Island Office of the Health Insurance Commissioner (OHIC)
Notes

Data gap: OHIC does not publish a discoverable external-review statistics document.

South Dakota
SD
Data gap
state-runSouth Dakota Division of Insurance
Notes

Data gap: SD Division of Insurance publishes IRO process documentation but no overturn statistics.

Tennessee
TN
Data gap
state-runTennessee Department of Commerce and Insurance (TDCI)
Notes

Data gap: TDCI returned $17.54M to consumers via mediation in 2024 but does not break out external-review overturn statistics.

Texas
TX
Data gap
state-runTexas Department of Insurance (TDI)
Notes

Data gap on count fields: TDI publishes IRO decisions individually but does not publish consolidated overturn statistics. Note: KFF 2024 lists TX as HHS-administered; TDI operates state-level IRO process for workers' compensation and certifies IROs. Methodology divergence: TX IRO data structure differs materially from CA DMHC IMR; not directly comparable.

U.S. Virgin Islands
VI
HHS-administered
HHS-administeredHHS-Administered Federal External Review (MAXIMUS Federal Services)
Notes

U.S. territory using HHS-administered federal process. CMS does not publish jurisdiction-level case totals.

Utah
UT
Data gap
state-runUtah Insurance Department
Notes

Data gap: Utah Insurance Department does not publish public external-review statistics.

Vermont
VT
Data gap
state-runVermont Department of Financial Regulation (DFR)
Notes

Data gap: Vermont DFR publishes Health Insurers Annual Reports with claims/appeals data but does not specifically itemize external-review overturn rates in a public summary.

Virginia
VA
Data gap
state-runVirginia Bureau of Insurance (State Corporation Commission)
Notes

Data gap: VA Bureau of Insurance does not publish a discoverable external-review statistics report.

Wisconsin
WI
2024
HHS-administered
HHS-administeredHHS-Administered Federal External Review (MAXIMUS Federal Services) / Wisconsin OCI
Notes

Wisconsin operates partial state external-review framework but classified by KFF (2024) as relying on HHS-administered process for the full external-review pathway. WI OCI 2024 Wisconsin Insurance Report identified at https://oci.wi.gov/Documents/AboutOCI/2024_WIR.pdf

Wyoming
WY
Data gap
state-runWyoming Department of Insurance
Notes

Data gap: WY DOI does not publish public external-review statistics.

Reading note. Denominators are not comparable across jurisdictions. Some states count cases received; some count cases completed; some count completed-and-eligible. California and Maryland publish a complaint-process reversal rate that is broader than the strict IRO-only overturn. See the methodology document for the per-row caveats.

Methodology summary

How we built it. What we did not do.

What we did

  • Surveyed all 50 state Departments of Insurance plus DC and the 5 U.S. territories.
  • Cross-checked KFF's 2024 ACA marketplace data, CMS external-appeals factsheet, and NBC News' 2025 multi-state reporting.
  • Anchored every numeric cell to a single primary source URL.
  • Flagged five categories of caveat: HHS-administered, cumulative-period, broader-than-IRO, methodology divergence, and data gap.

What we did not do

  • Invent numbers for states that do not publish them.
  • Roll up a single national average. Denominators are not comparable.
  • Split out cancer / oncology subsets. This is the general external-review universe.
  • Include Medicare Advantage IRE data — that is a separate federal regime with materially different overturn dynamics.
  • Include workers' compensation IMR data.
Citation

Apellica (2026). The Apellica External Review Index: U.S. State External-Review Reversal Rates 2026. v1.0. Released 2026-05-19. CC-BY-4.0. https://apellica.com/external-review-index

Press contact: press@apellica.com. Editorial corrections: editorial@apellica.com.

Got a denial? You are in the 99%.

The lottery is not just where you live. It is whether you appeal at all. A senior reviewer reads your file within one business day.

Start Free Case Review