Texas external review
Texas review rights depend on which track your plan is on. TDI-regulated coverage (your insurance card says "TDI" or "DOI") uses the state's Independent Review Organization process — free, fast, filed through your insurer with form LHL009. Most other Texas plans, including self-funded employer coverage, use the federal external review overseen by HHS or the Department of Labor.
Deadlines and decision timelines
- Your filing window: 120 days from the final internal denial.
- Standard review decided in: 20 days for preauthorization, concurrent, and retrospective denials (TDI track)
- Expedited review decided in: 3 days — life-threatening conditions — which also let you skip the internal appeal entirely
- Cost to you: None — the carrier pays the IRO fee
How to file, step by step
- Check your card, read your denial letter. "TDI" or "DOI" on the card means the state IRO track. Otherwise your denial letter carries the federal external review instructions.
- Finish the internal appeal. Required before an IRO review — unless your condition is life-threatening, which lets you go straight to independent review.
- Send form LHL009 to your insurer — not to TDI. This is the step people get wrong. Complete TDI form LHL009 (your insurer must include it with the final denial), sign the records release, and return it to the carrier at the address on your denial letter. The carrier must forward it to TDI within 1 working day.
- TDI assigns an IRO at random. You get the assignment letter, the carrier ships records, and the IRO decides: 3 days for life-threatening cases, 20 days for most others.
Who can use it
- State IRO track: TDI-regulated coverage — check your insurance card for "TDI" or "DOI".
- Not TDI-regulated: self-funded employer (ERISA), government-employee, teacher, and military plans — those use the federal external review route (Department of Labor or HHS).
What to know
- TDI cannot overturn an independent reviewer's decision.
- Questions about the IRO process: 1-866-554-4926, option 2.
- If your plan uses the HHS federal external review: CMS reports that process is temporarily unavailable as of July 1, 2026, with deadline extensions promised — follow your denial letter's instructions and document everything.
Denial data from plans operating in Texas
| Insurer | Contract / plan | Line | Requests | Denied | Appeals overturned |
|---|---|---|---|---|---|
| Centene | 29418 Ambetter | Marketplace | 218,062 | 32.94% | 61.91% |
| Centene | H0174 Wellcare | Medicare Advantage | 192,173 | 19.3% | 94.76% |
| Centene | H4506 Wellcare | Medicare Advantage | 90,924 | 13.23% | 96.74% |
| Centene | 87226 Ambetter | Marketplace | 89,666 | 32.48% | 60.06% |
| Centene | H7323 Wellcare | Medicare Advantage | 14,095 | 19.21% | 98.57% |
| Molina Healthcare | TX-CHIP-PERINATE-RSA-186-TO-200 | Medicaid | — | 33% | — |
| Molina Healthcare | TX-STAR | Medicaid | — | 17% | 54% |
| Molina Healthcare | TX-CHIP | Medicaid | — | 17% | 78% |
| Molina Healthcare | TX-CHIP-RSA | Medicaid | — | 15% | 76% |
| Molina Healthcare | TX-MARKETPLACE | Marketplace | — | 13% | 50% |
| Molina Healthcare | H7678 | Medicare Advantage | — | 11% | 53% |
| Molina Healthcare | H8197 | Medicare Advantage | — | 10% | 44% |
| Elevance Health | TX-Medicaid Wellpoint | Medicaid | — | 8.6% | 31.4% |
| Molina Healthcare | H2715 | Medicare Advantage | — | 6% | — |
| Molina Healthcare | TX-STAR-PLUS | Medicaid | — | 6% | 65% |
| Molina Healthcare | TX-CHIP-PERINATE-RSA-AT-OR-BELOW-185 | Medicaid | — | 5% | 100% |
| Molina Healthcare | TX-CHIP-PERINATE-MHT-AT-OR-BELOW-185 | Medicaid | — | 4% | — |
| Molina Healthcare | TX-CHIP-PERINATE-MHT-186-TO-200 | Medicaid | — | 0% | — |
Texas external review FAQ
Where do I send my Texas IRO request?
To the insurance carrier that denied you — not to TDI. Form LHL009 goes back to the carrier (address on your denial letter), and the carrier must forward it to TDI within one working day. TDI then randomly assigns the review organization.
How fast is an IRO decision?
Life-threatening cases: 3 days. Preauthorization, concurrent, and retrospective denials: 20 days. Life-threatening conditions also skip the internal-appeal prerequisite entirely.
Does it cost me anything?
No. The carrier pays the IRO's fee.
My employer plan isn't TDI-regulated — what then?
Self-funded employer, government-employee, teacher, and military plans use the federal external review route overseen by the Department of Labor or HHS. Your denial letter carries the filing instructions. Note: CMS reports the HHS-administered process is temporarily suspended as of July 1, 2026, with deadline extensions promised for affected consumers.
Can TDI reverse the IRO if I lose?
No — TDI can't overturn an independent reviewer's decision. If you lose the external review, remaining options are legal remedies outside the administrative process.
Primary sources
- TDI — health insurance complaints and appeals
- TDI — IRO frequently asked questions
- TDI form LHL009 — IRO request (with timeframe table)
- CMS — external appeals (federal process status)