Posts Tagged: Claim and appeal

DOL Regulatory Update

in Health Benefits, Welfare Benefits

DOL recently released its 2012 regulatory agenda, with a few interesting items emerging.  The agenda indicates that DOL will propose updates to the internal claim and appeal procedures for plans not covered by the Affordable Care Act (e.g., stand-alone dental and vision, disability and retirement plans).  These regulations were last updated in 2001.  I first heard of these proposed updates during the JCEB health and welfare meeting that I co-chaired a few months ago.  At that time, DOL indicated that it was examining whether any of the enhancements that apply to the internal claims and appeals procedures under the Affordable Care Act,… Continue Reading

Claim and Appeal Rule Amendments

in Affordable Care Act

Last night the Agencies issued amendments to the interim claim and appeal rules under the Affordable Care Act.  A draft publication is linked below, while the official version of the amended interim rules will be published tomorrow in the Federal Register.  We will follow up next week with more information regarding the changes and effective dates in the amended rules.

Additional Claims and Appeals Guidance

in Affordable Care Act

In September 2010, the DOL issued Technical Release 2010-02, which set forth an enforcement grace period until July 1, 2011 for compliance with some but not all of the new provisions of the claims and appeals procedures until July 1, 2011.  DOL has now issued, Technical Release 2011-01, which modifies and extends the enforcement grace period.   Subject to certain exceptions, the grace period is extended to January 1, 2012 for calendar year plans.  A copy of the release can be found at the following website:

IROs – Relief or Confusion?

in Affordable Care Act

Late Tuesday, DOL released FAQs regarding various miscellaneous ACA issues.  DOL also released additional guidance on the claims and appeals procedures in Technical Release 2010-02.   THe FAQs can be seen here: The FAQs are a strange aggregation of items.  One of the FAQs states that with respect to IRO contracts that the earlier DOL guidance never required a contract between a plan and an IRO.  This is in direct contradiction with Technical Release 2010-01 which specifically states that a contract between a plan and an IRO must contain specific language as set forth in the release.  If a contract… Continue Reading

The Next Generation of Appeal Procedures

in Affordable Care Act

On Monday, the DOL released additional rules with respect to the Federal external appeal procedures.  These procedures apply to non-grandfathered self-insured health plans.  The procedures include a number of issues for plans and plan sponsors, and unfortunately there is little time to manage them. Calendar year plans will have until January 1, 2011 to accomplish the following – The rules require the plan to process external appeals, send notices to participants and send the appeal to an appropriate IRO. Presumably, a plan can contract with their existing TPAs to perform these actions, but TPAs will need to be contacted, procedures will… Continue Reading