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ACA / Marketplace Plans: your appeal rights

ACA plans owe you 180 days to appeal, continued coverage during the fight, and a binding outside review at the end of it.

Is this you? You bought your plan on healthcare.gov or a state exchange, or you have an individual (non-employer) plan regulated by the Affordable Care Act.

The escalation ladder

Step 1 — Internal appeal
180 days to file. Plan decides in 30 days (pre-service) or 60 days (post-service); 72 hours if urgent.
Step 2 — External review
State or federal HHS process depending on your state. Independent, binding, 4 months to file.
In parallel — state insurance department complaint
Your state DOI takes consumer complaints and can pressure insurers on process violations.

Your specific rights

ACA internal appeal rights

Marketplace and other ACA-regulated plans must give you 180 days to appeal, tell you exactly why you were denied, and keep covering an ongoing treatment while your appeal is pending.

180 days from denialFile internal appeal
30 daysPre-service decision
60 daysPost-service decision
72 hoursUrgent claims
45 CFR § 147.136
ACA external review

After the internal appeal — or at the same time, for urgent cases — you can demand review by an independent organization with no ties to your insurer. Their decision binds the plan. Depending on your state this runs through the state insurance department or the federal HHS process.

4 months from final internal denialRequest external review
45 daysStandard decision
72 hoursExpedited decision
45 CFR § 147.136(d); state external review statutes
Right to the denial's clinical rationale

Under the 2026 prior-authorization rules, impacted payers must give a specific reason for a prior-auth denial — not boilerplate. Ask for the exact criteria used, the guideline relied on, and the credentials of the reviewer. Vague denials are appealable on process alone.

CMS Interoperability and Prior Authorization Final Rule (CMS-0057-F)
Emergency care: prudent layperson standard

Insurers must cover emergency care based on your symptoms at the time — not the final diagnosis. If a reasonable person would have thought it was an emergency, it must be covered as one, in or out of network, with no prior authorization required.

42 U.S.C. § 300gg-19a(b); No Surprises Act
No Surprises Act protections

For emergency care and for out-of-network providers working at in-network facilities, you can only be billed your in-network cost sharing. Balance bills in those situations are illegal — dispute them rather than paying.

Consolidated Appropriations Act 2021, Div. BB; 45 CFR Part 149

What to include in your appeal

Not legal or medical advice. Coverage Rights is a self-help tool that helps you prepare your own appeal. For advice about your specific situation, talk to a licensed attorney or your doctor.

Deadlines are the whole game. Start free— we’ll find yours.

Explain my denial