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Keytruda denials: what the review data shows

Independent reviewers have decided 17 published cases where an insurer denied Keytruda — and they overturned the insurer 35.3% of the time. A denial for Keytruda is a starting position, not a final answer.

Published decisions
17
2001–2026
Overturned
35.3%
6 denials reversed

What the insurer actually argued

Denials fall into different categories, and they don’t succeed equally — so the reason on your letter changes how you should answer it.
Reason givenDecisionsOverturned
Medical Necessity
The plan said the care wasn’t medically necessary. The most common fight, and the most winnable.
10
30%
Experimental/Investigational
The plan called the treatment unproven. These turn on published evidence, so the appeal is a literature argument.
7
42.9%
Typical time to a decision
5 days
Most land between 2 and 8 days
Handled as urgent
94.1%
Expedited when a delay would cause harm
What the reviewers wrote
Excerpts from the independent reviewers’ published findings — the actual reasoning, quoted, not summarised.

Where the denial was overturned

Findings: The physician reviewer found that Nature of Statutory Criteria/Case Summary: An enrollee has requested authorization and coverage for the medication (Keytruda) regimen including, as needed: diphenhydramine HCL injection, injection famotidine 20 mg, ondansetron HCL injection, dexamethasone sodium phosphate, paclitaxel injection, injection heparin sodium per 10 Units, lidocaine injection, alteplase recombinant, normal saline solution infusion, and injection pembrolizumab (Keytruda). The mainstay of soft tissue sarcoma therapy is surgical resection. There are many diverse subtypes of soft tissue sarcoma, including epithelioid angiosarcoma. There are phase 2 clinical trials evaluating paclitaxel and/or pembrolizumab (Keytruda) in the treatment of patients with advanced sarcoma.
Experimental/Investigational · 2024 · IMR EI24-42897
Nature of Statutory Criteria/Case Summary: An enrollee has requested authorization and coverage for combination therapy with Padcev (enfortumab vedotin) and Keytruda (pembrolizumab). This patient has undergone treatment with a clinical course that is considered the standard care in bladder cancer therapy. The patient now presents with metastatic disease, for which he requires treatment with different systemic therapy. The U.S. Food and Drug Administration (FDA) has approved Padcev for use in locally advanced metastatic, urothelial cancer, in patients who have previously received a PD1 or PDL1 inhibitor and a platinum-containing chemotherapy, as in this patient’s case. Padcev gained FDA approval in 2019 based on multiple studies in patients that were in eligible to receive cisplatin or who had progressed after platinum-based therapy.
Experimental/Investigational · 2023 · IMR EI23-38724

Where the denial was upheld

Worth reading too — these show what an appeal has to overcome.
Nature of Statutory Criteria/Case Summary: An enrollee has requested authorization and coverage for Keytruda immunotherapy.Findings: The physician reviewer found that The records provided for review document that this patient presents with a history of metastatic small cell lung cancer (SCLC) status post suboccipital craniectomy for resection of cerebellar metastases. The provider documented that the patient was treated with topotecan monotherapy due to the findings of progressive disease. The provider has recommended treatment with pembrolizumab (Keytruda). As noted in the peer-reviewed medical literature, Keytruda is supported for the treatment of patients with SCLC that is extensive and staged 1-3. Moreover, the National Comprehensive Cancer Network (NCCN) guidelines endorse Keytruda for use in patients who have metastases, as in this patient’s case.
Experimental/Investigational · 2022 · IMR EI22-38178
Nature of Statutory Criteria/Case Summary: An enrollee has requested authorization and coverage for Keytruda infusions (pembrolizumab). This patient presents with thyroid cancer, for which the standard of care includes dabrafenib and trametinib based on the presence of a BRAF V600E mutation (Subbiah, et al.). The provider recommended the addition of Keytruda in combination with the BRAF targeted therapy. Keytruda is U.S. Food and Drug Administration (FDA) approved for various tumor indications. The National Comprehensive Cancer Network (NCCN) guidelines support treatment with Keytruda for patients with microsatellite instability-high or mismatch repair deficient cancer. This patient underwent testing to assess for BRAF mutations. However, the patient’s tumor mutational burden was not quantified or reported.
Experimental/Investigational · 2021 · IMR EI21-34831

Figures and quotations on this page come from 42,749 published decisions in the California DMHC Independent Medical Review dataset. These are California outcomes — every state runs an equivalent external review, but the rates here are California’s. Excerpts are quoted verbatim from the public record and describe this treatment generally, not any individual case.

How to use this in your appeal

These are outcomes from California’s external review program — an independent physician panel that binds the insurer. Every state has an equivalent process, and internal appeals succeed even more often. Cite the outcome record for Keytrudawhen you appeal: reviewers routinely find that denials like yours didn’t hold up.

SOURCE: CALIFORNIA DMHC INDEPENDENT MEDICAL REVIEW OUTCOMES (CHHS OPEN DATA) · DERIVED AGGREGATE STATISTICS ONLY · METHODOLOGY

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.

Denied Keytruda? 35.3% got it reversed.

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