What is an internal appeal?
An internal appeal asks the health plan to reconsider an adverse benefit determination—when the plan denies PA, reduces payment, or says care is not medically necessary, experimental, or not a covered benefit.
This is different from external review, where ODI assigns an independent review organization (IRO) or the superintendent reviews pure contractual disputes after internal review is complete.
General walkthrough: Appeals roadmap.
Ohio appeal timelines
Chapter 3922 (health plan issuers)
Ohio's Chapter 3922 implements federal internal appeal standards for ODI-regulated health plans. Key points:
- File an internal appeal within 180 days of the adverse benefit determination in most cases (integrated with 29 C.F.R. § 2560.503-1)
- Pre-service appeals: written decision within 30 days
- Post-service appeals: within 60 days
- Urgent care appeals: as soon as the medical condition requires, often within 72 hours
- If the plan misses required deadlines or fails to follow appeal procedures, you may be deemed to have exhausted internal review and proceed to external review (§ 3922.04, § 3922.19)
Final adverse benefit determination
A final adverse benefit determination is the decision after internal appeal is complete—or when the plan fails to decide within the required timeframe. Your final denial notice must explain how to request external review within 180 days (§ 3922.19(E)).
Simultaneous expedited external review
If your treating physician certifies that the internal appeal timeframe would seriously jeopardize life or health, you may file for expedited external review at the same time as an expedited internal appeal (§ 3922.19).
Retrospective review
For retrospective utilization review denials, Ohio generally requires you to complete internal appeal before external review (§ 3922.04(D)).
How to file
- Read the denial for appeal instructions and deadlines.
- Submit in writing when possible—or orally if your plan allows (Ohio permits oral appeals in many cases).
- Request expedited review if delay would cause serious harm.
- Keep copies of everything sent and the date sent.
ODI model appeal forms: Internal appeal & external review model notices.
Carrier links: Ohio prior auth & internal appeals links.
Evidence that helps
- Treating clinician letter on medical necessity
- Insurer's published clinical criteria
- Peer-reviewed literature for experimental/investigational disputes
Medicaid appeals
Medicaid managed care requires an MCO appeal before a state fair hearing in most cases:
- MCO appeal: 60 calendar days from the notice of action (OAC 5160-26-08.4)
- MCO must resolve within applicable federal and state timeframes; failure to meet notice rules may let you skip to a state hearing
- State fair hearing: request to ODJFS Bureau of State Hearings within 90 calendar days of the MCO appeal resolution (OAC 5101:6-3-02) · 866-635-3748
After internal appeal
If you receive a final denial, request external review in writing to your health plan issuer within 180 days (ODI — health coverage external review).
Next: Ohio external review.