A Big Sioux Benefits advisor reviewing a Medicare prior authorization denial letter and appeal documents at his desk in Sioux Falls

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Medicare Prior Authorization Denied? Your Step-by-Step Appeal Guide for 2026

Most denials that get appealed get overturned. Most never get appealed at all.

The bottom line

  • Medicare Advantage insurers denied about 4.1 million of 52.8 million prior authorization requests in 2024 — a 7.7% denial rate.
  • Only 11.5% of denials get appealed, yet 80.7% of appeals are overturned in whole or in part.
  • A Medicare appeal has five levels, starting with your plan and ending, if needed, in federal court.
  • New 2026 rules require a decision within 72 hours (expedited) or 7 days (standard) for most prior authorization requests.
  • Appealing costs you nothing — and free local help exists through SHIINE and a licensed agent.

If your Medicare Advantage plan just denied a prior authorization request, the single most useful fact to know is this: when people actually appeal, they win more than eight times out of ten. The catch is that barely one in nine denials ever gets appealed. This guide walks through what prior authorization means, exactly how a Medicare appeal works in 2026, and how Sioux Falls-area beneficiaries can build one that has a real shot at succeeding.

Every figure below comes from a public federal or nonpartisan source — KFF's analysis of 2024 CMS prior authorization data, the HHS Office of Inspector General's findings on denial-rate variation, and Medicare.gov's official appeals process. No invented numbers, no "call for details."

What "prior authorization" actually means

Prior authorization is your plan's requirement that it approve a service, test, drug, or piece of equipment before it happens — not after. Your doctor can order an MRI, prescribe a specialty drug, or refer you to inpatient rehabilitation, and your Medicare Advantage plan can still say no before you ever receive the care. That approval sits between your doctor's medical judgment and your plan's payment, and it applies to a genuinely long list of services: advanced imaging, many drugs given by injection or infusion in a clinic, durable medical equipment, inpatient rehabilitation facility stays, skilled nursing facility admissions, and some surgeries.

Most Medicare Advantage plans do not review these requests in-house. They contract with a specialized utilization-management vendor — a company whose entire business is applying clinical criteria to prior authorization requests at scale — and that vendor's own medical policy, not just your doctor's judgment, becomes the standard your request is measured against. CMS's stated rationale for allowing this is straightforward: prior authorization is meant to confirm a service is medically necessary and delivered in the right setting before money changes hands, which in theory protects both the beneficiary and the Medicare Trust Fund from unnecessary care. In practice, the volume of denials that get reversed on appeal is what has drawn regulatory scrutiny — a process meant to filter out unnecessary care is also, demonstrably, filtering out a meaningful amount of necessary care too.

Original Medicare works differently

Original Medicare (Parts A and B) requires prior authorization for only a short, CMS-published list of services — a handful of outpatient procedures and DME categories. Medicare Advantage plans, which are run by private insurers under contract with CMS, use it far more broadly. That gap is one of the real, quantifiable trade-offs between the two paths through Medicare — see our Medigap vs. Medicare Advantage comparison.

How often denials actually happen

Prior authorization denials are common enough that you should assume they can happen to you, and rare enough that most people are caught off guard the first time. Medicare Advantage insurers submitted 52.8 million prior authorization requests in 2024 — about 1.7 per enrollee — and denied roughly 4.1 million of them, a 7.7% denial rate, up from 6.4% the year before. About 73% of those denials were full denials; the rest were partial.

52.8M

MA prior authorization requests, 2024

7.7%

Share denied

11.5%

Denials that get appealed

80.7%

Appeals overturned

Source: KFF — Medicare Advantage Prior Authorization Determinations (2024 data).

The variation across insurers is where it gets more striking. An HHS Office of Inspector General review of long-term acute care and inpatient rehabilitation facility prior authorizations found denial rates ranging from about 8% to 80% depending on the company — with UnitedHealthcare, Aetna (CVS Health), and Humana flagged for rates exceeding 70% on some of these stays. Nearly 20 million Medicare Advantage enrollees are covered by the three highest-denying insurers in that review. And when those specific denials were appealed, 95% were overturned.

When people appeal, most win

Denials that get appealed11.5%
Overall MA appeals overturned80.7%
DME appeals overturned63.9%
LTCH / rehab appeals overturned (OIG)95%

Source: KFF — Medicare Advantage Prior Authorization Determinations (2024 data) & HHS Office of Inspector General findings, via NBC News.

The overturn rate has stayed above eight in ten for years running — a pattern the HHS Inspector General has called a systemic signal, not an occasional mistake.

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The five levels of a Medicare appeal

Every Medicare denial — Original Medicare, Medicare Advantage, or Part D — moves through the same basic ladder, though the names shift slightly by program. Here is the structure that applies to a Medicare Advantage prior authorization denial:

LevelWho decidesYour deadline to actHow long it takes
1. Plan reconsideration Your Medicare Advantage plan (or the MAC for Original Medicare) 65 days from the denial notice (MA); the date on your Medicare Summary Notice for Original Medicare 60 days (standard) or 72 hours / 24 hours (expedited)
2. Independent review An outside Independent Review Entity (Maximus Federal Services) or the QIC Automatic if your plan upholds the denial — no separate filing needed 60 days (standard); faster for expedited cases
3. ALJ hearing An Administrative Law Judge at the Office of Medicare Hearings and Appeals (OMHA) 60 days from the Level 2 decision; disputed amount must be at least $200 in 2026 OMHA's backlog commonly runs 12 to 24 months
4. Medicare Appeals Council The Departmental Appeals Board 60 days from the ALJ decision Varies; no fixed statutory timeline
5. Federal district court A U.S. District Court judge 60 days from the Council's decision; disputed amount must be at least $1,960 in 2026 Standard federal civil litigation timelines

Source: Medicare.gov — Appeals in Original Medicare.

In practice, almost every case that gets resolved favorably resolves at Level 1 or Level 2. Level 3 — a hearing before an Administrative Law Judge at the Office of Medicare Hearings and Appeals — is real, and it is available once the disputed dollar amount clears a CMS-set threshold ($200 for 2026), but OMHA's backlog commonly runs 12 to 24 months. That backlog is exactly why the fight to win early, with strong documentation, matters more than the theoretical right to escalate later.

You do not have to navigate any of this alone. You, your doctor, or someone you formally appoint as your representative (using Medicare's Appointment of Representative form) can file at every level. Level 1 requests can often be started by phone with the plan directly, though CMS recommends following up in writing so there is a dated record. Level 2 requires no action from you at all if your plan denies the Level 1 reconsideration — federal regulation requires the plan to forward the case automatically to the independent reviewer. That single rule is worth remembering: if a plan upholds its own denial, you should never have to re-file from scratch to get an outside, disinterested look at the same facts.

Ask for "expedited" if waiting could harm you

If your doctor believes waiting for a standard decision could seriously jeopardize your life, health, or ability to regain maximum function, you or your prescriber can request an expedited review at any level. It compresses the plan's decision window from days down to hours.

The 2026 decision deadlines that changed

CMS's Interoperability and Prior Authorization Final Rule (CMS-0057-F), finalized in January 2024, put new operational requirements into force on January 1, 2026 for Medicare Advantage plans and several other regulated payers. The headline change: plans must issue a standard prior authorization decision within 7 calendar days and an expedited one within 72 hours — timelines that did not exist in a standardized form before. By January 1, 2027, those same plans must also run a live Prior Authorization API so a provider's office can check requirements and submit a request electronically, part of a broader push toward machine-readable, auditable prior authorization decisions.

Request typeStandard decisionExpedited decision
Standard medical service (MA prior authorization) 7 calendar days 72 hours
Part D drug coverage determination / exception 72 hours 24 hours
Part D payment-only request (already received the drug) 14 calendar days Not applicable

Source: CMS Interoperability and Prior Authorization Final Rule (CMS-0057-F) & CMS — Part D Coverage Determinations.

The rule also requires plans to give a specific reason for every denial, not a form letter, and to publish their prior authorization approval and denial rates by category. That transparency requirement is precisely the data KFF and the HHS Inspector General have been using to document how much denial rates vary by insurer.

Step therapy and Part D formulary exceptions

Step therapy is prior authorization's cousin on the drug side. Your Part D plan can require you to try — and fail on, or show is medically unsuitable — a lower-cost drug before it will cover the one your doctor actually prescribed. CMS treats a step therapy waiver request the same way it treats a formulary exception: your prescriber submits a supporting statement explaining why the required alternative has been, or is likely to be, less effective for you or would cause adverse effects.

The clock on that request does not start until your plan actually receives the prescriber's supporting statement — so a request that seems to be moving slowly may simply be waiting on paperwork from the clinic, not sitting in the plan's queue. Once the plan has what it needs, it must decide within 72 hours for a standard exception request or 24 hours for an expedited one, whether your life or health could be at risk by waiting.

A formulary tier move can trigger step therapy without warning

A drug moving to a higher tier at the start of a new plan year can quietly add a step therapy requirement that was not there the year before. This is one of the reasons an annual plan review matters — see our eight-point annual review checklist and our full breakdown of how Part D formulary tiers work.

Building an appeal that actually wins

The 80.7% overturn rate is not luck — it reflects the fact that most denials that get appealed were genuinely appealable, and most appeals that succeed were built the same way. The strongest appeals do one thing consistently: they answer the plan's stated denial reason directly, in the plan's own clinical language, rather than restating why the patient needs the care in general terms. If a denial cites a specific coverage policy or medical criterion, your appeal should reference that exact policy and explain, point by point, why your situation meets it. Here is what to gather before you file:

The denial letter itself

It states the specific reason for the denial and the plan's own coverage criteria — you have to answer that exact reason, not a general one.

Your medical records

Chart notes, imaging results, and lab values that support medical necessity for your specific situation.

A letter from your doctor

A short, specific statement of medical necessity carries far more weight than a general request to "please reconsider."

A peer-to-peer review request

Ask your doctor's office to request a direct conversation between your physician and the plan's medical reviewer — this resolves many denials before a formal appeal is even needed.

Your Medicare number and dates

Every appeal needs your Medicare number, the specific service or item, and the date of service clearly stated.

A copy for your own file

Keep everything you send — appeals can take months, and you may need it again at the next level.

Success rates differ by service type, which is itself useful information: KFF's data shows 63.9% of appealed durable medical equipment denials succeed, versus 26.3% for ambulance transport and 22.2% for certain hospital outpatient services. A lower success rate for a category does not mean an appeal is not worth filing — it means the documentation needs to work harder.

Original Medicare vs. Medicare Advantage: does switching help?

This is a fair question to ask after a bad prior authorization experience, and the honest answer is that it depends on timing and cost, not just frustration. Original Medicare requires prior authorization for a much shorter list of services, which genuinely reduces this specific friction. But Original Medicare alone leaves a $1,632 Part A deductible per benefit period and an uncapped 20% Part B coinsurance with no annual ceiling unless you pair it with a Medigap supplement — which, outside your one-time guaranteed-issue window, may require medical underwriting in South Dakota. Medicare Advantage plans carry more prior authorization but also carry a built-in annual out-of-pocket maximum that Original Medicare alone does not have.

There is no universal answer, and the tradeoff is exactly why this decision deserves a real comparison rather than a reaction to one bad denial. A single frustrating prior authorization experience is a legitimate reason to review your options at the next enrollment window — it is not, on its own, a reason to assume the opposite path through Medicare would leave you better off financially. Someone managing a chronic condition with frequent imaging or infusion needs may find that a Medigap plan's near-total absence of prior authorization is worth a higher monthly premium. Someone in good health who rarely uses specialty care may find a Medicare Advantage plan's out-of-pocket cap and $0-premium options the better financial trade, prior authorization included. Our full breakdown is in Medigap vs. Medicare Advantage in Sioux Falls.

What this looks like locally: the Sanford & Avera angle

Sioux Falls' Medicare Advantage market runs through five standard PPOs, and every one of them uses prior authorization for at least some imaging, DME, and specialty drug categories — that is a standard feature of Medicare Advantage plan design, not a flaw unique to any single carrier here. What differs locally is which hospital system a denial dispute tends to run through: Sanford USD Medical Center holds a 5-star CMS quality rating and Avera McKennan a 4-star rating, and Sanford's own Align plans naturally route referrals and prior authorization requests through the Sanford network first.

PlanCarrierPremiumDrug deductibleStars
Aetna Medicare Signature (PPO) Aetna / CVS $0 $615 3.5★
Align ChoicePlus (PPO) Sanford Health $0 $350 3.5★
Aetna Medicare Enhanced Extra (PPO) Aetna / CVS $52.00 $615 3.5★
Align ChoiceElite (PPO) Sanford Health $66.00 $300 3.5★
Blue Medicare Advantage Enhanced (PPO) Wellmark / BCBS $80.00 $300 3.5★

Source: CMS Medicare Advantage / Part D Landscape (PY2026), Minnehaha County.

This matters for prior authorization specifically because a plan's utilization-management vendor usually reviews requests against its own clinical criteria, not against which hospital you prefer — so confirming your doctor is in-network is step one, and understanding that plan's specific prior-authorization list for your ongoing conditions is step two. Minnehaha County's CDC-tracked chronic-condition rates make that second step especially relevant: 22.9% of adults have arthritis (driving imaging and injection requests), 10% have diagnosed diabetes (driving CGM and supply requests), and 5.6% have COPD (driving home oxygen and nebulizer requests) — all categories where prior authorization shows up routinely. We break each of those down fully in our durable medical equipment guide and our chronic conditions coverage guide.

Source: CDC PLACES: Local Data for Better Health, County 2023 (2023) & CMS Hospital Compare — Overall Star Ratings.

A worked example: rehab after a hip replacement

Here is how this plays out in a real, common scenario. Someone in Sioux Falls has a hip replacement — a procedure covered under Part A, discussed fully in our hip and knee replacement guide — and their surgeon recommends a short stay at an inpatient rehabilitation facility (IRF) rather than going straight home. The HHS Inspector General's review found some insurers deny IRF prior authorization requests more than 70% of the time, even though the average IRF stay runs about $24,000. If that request is denied and the family simply accepts it, they either pay privately or the patient goes home without the rehabilitation the surgeon recommended.

Accepting the denial

What usually happens

  • Denial letter goes unanswered
  • Family pays privately or skips recommended rehab
  • No peer-to-peer review requested
  • No documentation gathered

0%Chance of a result changing on its own

Filing the appeal

What the data shows instead

  • Surgeon's letter of medical necessity attached
  • Peer-to-peer review requested
  • Level 1 reconsideration filed within days
  • Appeal decided within the new 2026 timelines

95%Of appealed LTCH/IRF denials were overturned (OIG)

Source: HHS Office of Inspector General findings, via NBC News.

The math is not subtle: a stay that costs roughly $24,000 if paid privately, against an appeal that costs nothing but time and paperwork and wins 95% of the time in this specific category, is one of the clearest arguments for appealing that exists anywhere in Medicare.

Free help exists — use it

You do not have to build an appeal alone, and none of the help below costs you anything. South Dakota's Senior Health Information and Insurance Education program, SHIINE — the state's federally funded State Health Insurance Assistance Program — offers free, unbiased Medicare counseling, including help understanding a denial letter and preparing an appeal. Reach SHIINE at (866) 854-5465 toll-free or (605) 773-3656 locally.

Important

We do not offer every plan available in your area. Any information we provide is limited to those plans we do offer in your area. Please contact Medicare.gov, 1-800-MEDICARE, or SHIINE, South Dakota's State Health Insurance Program (SHIP), to get information on all of your options.

Big Sioux Benefits can also walk you through how the plans we offer handle prior authorization for your specific drugs and conditions, at no cost — licensed agents are paid by carriers, never by you.

What to watch heading into the 2026 Annual Enrollment Period

  1. Check your plan's prior authorization list against your actual ongoing drugs and services before you re-enroll, not after a denial arrives.
  2. Read every denial letter fully — the specific reason stated is what your appeal has to answer.
  3. Ask for a peer-to-peer review before filing a formal appeal; many denials resolve there.
  4. File within the deadline — 65 days for a Medicare Advantage Level 1 reconsideration.
  5. Request "expedited" review whenever a delay could genuinely harm your health.
  6. Call SHIINE or a licensed local agent before assuming a denial is final — it usually is not.

How we know all this: Big Sioux Benefits runs every article through a data desk that cross-references KFF's national prior authorization research, HHS Office of Inspector General findings, CMS's official appeals-process rules and 2026 dollar thresholds, the CMS-0057-F final rule, and the Minnehaha County CMS plan landscape — built by Strategic AI Architects. Every figure here is sourced; nothing is invented. This is education, not legal or medical advice — confirm your own appeal rights and deadlines with your plan, Medicare.gov, or SHIINE. We take no payment from any carrier to feature a plan.

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Frequently asked questions

What does it mean when Medicare Advantage says a service needs prior authorization?

It means your plan requires its own approval, in advance, before it will pay for a specific service, test, drug, or piece of equipment — even though a doctor already ordered it. Original Medicare requires this for very few services; most Medicare Advantage plans require it for a much longer list, including advanced imaging, many drugs administered in a clinic, durable medical equipment, and inpatient rehabilitation or skilled nursing stays. If the plan does not approve the request first, it can refuse to pay even when the care turns out to be medically necessary.

How often do Medicare Advantage plans deny prior authorization requests?

Insurers made about 52.8 million prior authorization determinations for Medicare Advantage enrollees in 2024 and denied roughly 4.1 million of them, a 7.7% denial rate. An HHS Office of Inspector General review found the rate varies enormously by company — from about 8% up to 80% for long-term acute care and inpatient rehabilitation stays specifically. Only Big Sioux Benefits can tell you which plans we offer handle prior authorization the way that fits your situation; we do not offer every plan available in your area.

What are the five levels of a Medicare Advantage appeal?

Level 1 is a reconsideration by your own plan. Level 2 is an automatic, independent review by an outside entity if your plan upholds the denial. Level 3 is a hearing before an Administrative Law Judge, available once the disputed amount clears a CMS-set dollar threshold. Level 4 is a review by the Medicare Appeals Council. Level 5 is a case in federal district court, available once the disputed amount clears a second, higher threshold. Most disputes resolve at Level 1 or Level 2.

How long does a Medicare Advantage appeal take in 2026?

A Level 1 reconsideration must be decided within 72 hours if it is expedited or 7 calendar days if it is standard, under rules that took effect January 1, 2026. Level 2 independent review typically adds up to 60 more days. If a case reaches Level 3, the Office of Medicare Hearings and Appeals has a well-documented backlog that commonly runs 12 to 24 months, which is exactly why winning at Level 1 or Level 2 matters so much.

Does Original Medicare require prior authorization too?

Rarely, and only for a short, CMS-published list of services — certain outpatient department procedures such as some cosmetic-adjacent surgeries, and a handful of durable medical equipment categories. The vast majority of Original Medicare-covered care does not require advance approval. That is one of the real trade-offs between Original Medicare with a Medigap supplement and a Medicare Advantage plan, and it is worth weighing alongside premium and network questions.

What is step therapy, and how do I get an exception?

Step therapy means your Part D plan requires you to try a lower-cost drug first and show it did not work, or is unsuitable for you, before it will cover the drug your doctor actually prescribed. You or your prescriber can request a formulary exception at any time — your prescriber submits a supporting statement explaining why the required alternative was, or is likely to be, less effective or would cause adverse effects. Once your plan receives that statement, it must decide within 72 hours for a standard request or 24 hours for an expedited one.

Does appealing a Medicare denial cost anything?

No. Filing an appeal at any level costs you nothing in fees, and a licensed local agent's help reviewing your denial letter and plan documents is also free — carriers, not clients, pay agents. The only real cost is time, which is exactly why gathering strong documentation before you file the first appeal matters so much.

Who can help me file a Medicare appeal for free in Sioux Falls?

South Dakota's State Health Insurance Assistance Program, SHIINE, offers free, unbiased Medicare counseling, including help understanding a denial and preparing an appeal, at (866) 854-5465 toll-free or (605) 773-3656 locally. Big Sioux Benefits can also walk you through the plans we offer and how their prior authorization and appeals processes actually work — at no cost to you.

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