Legal Alert: Non-Enforcement Grace Period Extended for Certain Internal Claims and Appeals Standards

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On March 18, 2011, the Department of Labor ("DOL") Technical Release 2011-01 which provides for an extension of the enforcement grace period regarding certain standards for the internal claims and appeals procedures under the Patient Protection and Affordable Care Act (Affordable Care Act). Extension of the enforcement grace period was prompted by comments received from interested stake holders indicating that more time would be needed to implement the standards and the DOL's desire to avoid enforcement of standards scheduled to be modified in the near future.

The interim final regulations published on July 23, 2010 outline standards, in addition to existing DOL claims procedures, which must be followed when deciding internal claims and appeals for group health plans. The internal claims and appeals standards under the interim final regulations were set to become effective for non-grandfathered plans with plan years beginning on or after September 23, 2010. However, DOL Technical Release 2010-02 provided an enforcement grace period until July 1, 2011 with respect to Standard No. 2 (regarding the time frame for making urgent care claims decisions); Standard No. 5 (regarding providing notices in a culturally and linguistically appropriate manner); Standard No. 6 (regarding broader content and specificity in notices); and Standard No. 7 (regarding substantial compliance). The enforcement grace period under Technical Release 2010-02 was effective so long as the plans were working in good faith to implement standards 2, 5, 6 and 7.

Please see full alert below for more information.

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