Reviewed Aug 17, 2026 · FERP status checked Aug 17 · Method and sources
Appeals · 2026
External review routing aid by location and plan type.
Your location and plan type help narrow the possibilities, but neither one
determines the filing destination by itself. Start here, then follow the instructions and
deadline in your Explanation of Benefits or final denial notice.
This is a routing aid, not a deadline table. HealthCare.gov says an eligible
external review request generally must be filed within four months after receiving the denial
notice or final determination. Your notice identifies the reviewer, address, and deadline to use.
Coverage boundary. The selector lists all 50 states, Washington, D.C., American
Samoa, Guam, the Northern Mariana Islands, Puerto Rico, and the U.S. Virgin Islands. It provides
a general routing prompt, not state- or territory-specific legal instructions. It does not cover
jurisdictions outside that list, determine where a claim belongs, or establish eligibility for
internal or external review.
HHS-administered FERP reopened effective July 31, 2026. CMS says some people whose
deadline to request external review fell between July 1 and August 3, 2026 may be eligible for an
extension. If eligible, they have until October 2, 2026 to request review. This is conditional: the
plan must use the HHS-administered FERP, and this tool cannot determine eligibility. People who
submitted before July 1 and have not yet received a decision do not need to resubmit or add
information now. The extension does not apply after a final FERP decision. Follow the denial notice
and confirm the current route with the plan.
The three tracks
Under federal rules, external review runs one of three ways. Your state may operate its own
process if it meets or exceeds the national model standards. If it does not, the federal
Department of Health and Human Services oversees a process instead. And where a plan participates
in neither, it must contract with accredited independent review organizations.
Many self-funded employer plans are governed primarily by federal ERISA procedures, but funding
status alone does not identify where a particular external review request must be sent. Confirm the
process in the plan documents and final denial notice.
How to tell which kind of plan you have
- Read your Summary Plan Description. Self-funded plans typically say so directly.
- Ask HR a single question: does the insurer pay claims, or does the company?
- The insurer name on your card tells you nothing — a carrier often just administers a
self-funded plan.
Sending a request to the wrong place can consume valuable time. Use the address and instructions
in the final denial notice, and contact the plan or regulator promptly if they are unclear.
Sources
Verified 2026-08-17 · recheck before relying on a deadline.
Continue with your own notice. After identifying the likely route, enter only the
received date and filing window printed in your documents in the
appeal deadline calculator.
Funding status is only a clue; use the
plan-funding guide
before selecting a regulator or external-review path.
Related
Estimate from the deadline stated in your notice
Calculator
Confirm whether funding status changes the route
Guide
Identify the denial reason before preparing an appeal
Guide