Florida external review
Florida has no state-run external review — most Florida plans use the federally administered process run by HHS through its contractor. The review is free, decided within 45 days (72 hours expedited), and the insurer is required by law to accept the reviewer's decision. Important right now: CMS reports the HHS-administered process is temporarily unavailable as of July 1, 2026, with deadline extensions promised.
Deadlines and decision timelines
- Your filing window: 120 days from the final internal denial.
- Standard review decided in: 45 days from receipt
- Expedited review decided in: 72 hours or less — medical urgency — waiting would jeopardize your life or health
- Cost to you: None under the HHS process (issuer-contracted reviews capped at $25)
How to file, step by step
- Finish your internal appeal. The federal external review follows your plan's final internal denial. You have 4 months from that notice to file.
- Read your denial letter's external-review instructions. With the HHS portal temporarily suspended (as of July 1, 2026), the denial letter is the operative source: some issuers contract directly with accredited independent review organizations, which continue operating.
- When the HHS process is operating, file there. Online at externalappeal.cms.gov, by fax to (888) 866-6190, or by mail to the HHS contractor; expedited requests by phone at (888) 866-6205.
- Document everything meanwhile. HHS has said it will provide information about extending deadlines for eligible people. Keep your final denial, proof of dates, and your assembled evidence ready to file.
Who can use it
- Non-grandfathered fully-insured Florida plans, for denials involving medical judgment, experimental/investigational determinations, and rescissions.
- Self-funded employer (ERISA) plans also use the federal route — never a state process — with plan-contracted review organizations under Department of Labor oversight.
What to know
- Florida's DFS Insurance Helpline (1-877-693-5236) is a real human resource for navigating the federal process.
- The insurer is required by law to accept the external reviewer's decision.
- Florida's old Statewide Subscriber Assistance Program statute no longer appears in current Florida Statutes — the federal process is the operative route.
Denial data from plans operating in Florida
| Insurer | Contract / plan | Line | Requests | Denied | Appeals overturned |
|---|---|---|---|---|---|
| Centene | 49004 Ambetter | Marketplace | 419,452 | 21% | 58.23% |
| Centene | H1032 Wellcare | Medicare Advantage | 171,190 | 19.54% | 84.38% |
| Centene | 86382 Ambetter | Marketplace | 6,402 | 18.28% | 64.15% |
| Elevance Health | FL-CHIP Simply | Medicaid | — | 24.5% | 18.6% |
| Molina Healthcare | FL-MARKETPLACE | Marketplace | — | 13% | 50% |
| Elevance Health | FL-Medicaid Simply | Medicaid | — | 12% | 35.7% |
| Florida Blue | H1035 | Medicare Advantage | — | 9% | 55% |
| Florida Blue | H5434 | Medicare Advantage | — | 8% | 56% |
| Florida Blue | 16842 | Marketplace | — | 5% | 28% |
| Florida Blue | 30252 | Marketplace | — | 1% | 30% |
Florida external review FAQ
Why doesn't Florida have its own external review?
CMS lists Florida among the states whose external review arrangements rely on the HHS-administered federal process rather than a state-run program meeting ACA standards. The practical effect: Florida consumers file federally, not with a state agency.
What's the current status of the federal review process?
As of July 1, 2026, CMS reports the HHS-administered federal external review process is temporarily unavailable and says HHS will provide information about extending deadlines for eligible people. Issuers that contract directly with accredited review organizations continue operating — your denial letter says which applies to you.
What should I do while the portal is down?
Don't sit on it. Keep your final denial letter and proof of its date, assemble your medical evidence, call the Florida DFS helpline (1-877-693-5236) for guidance, ask your insurer whether it uses a contracted independent review organization, and watch the CMS external appeals page for the deadline-extension announcement.
How long does federal external review take when operating?
A standard review is decided no later than 45 days from receipt. Expedited reviews for medically urgent cases are decided within 72 hours or less.
Is the decision binding?
Yes — your insurer is required by law to accept the external reviewer's decision.
Primary sources
- HealthCare.gov — external review (with current status notice)
- CMS — external appeals (state process list)
- FLOIR — consumer resources