Round-up of Recent Guidance on Health Care Reform

In the last several weeks, the agencies1 charged with issuing guidance under the Patient Protection and Affordable Care Act (PPACA) have issued a number of additional items to clarify previously issued rules or to implement further procedures or rules under PPACA. The new items, which are described in further detail below, include:

FAQs – providing three sets of Frequently Asked Questions relating to PPACA implementation for group health plans, which were released on September 20, October 8, and October 13; DOL Technical Release 2010-02 – providing a grace period for implementing new claims and appeals procedures for non-grandfathered plans; IRS Notice 2010-63 – explaining the penalties that apply to a discriminatory fully-insured health plan...