Health care reform requires nongrandfathered group health plans, both insured and self-insured, to change their internal claims procedures and external review procedures. Even as plans work to implement these rules, the Internal Revenue Service, the Department of Labor, and the Department of Health and Human Services have jointly released amended interim final regulations in response to comments on the interim final regulations issued last July (discussed in a previous advisory). The agencies also issued technical guidance1 and revised model notices.2

In this advisory we compare the amended provisions of the interim final regulations with those proposed last July that are applicable to group health plans. Although the amendments are effective July 22, 2011, previously announced grace periods continue to apply.