The new year brings new claims and appeals obligations for non-grandfathered group health plan sponsors, as the enforcement grace periods established over the past two years begin to expire. Let’s start 2012 with a refresher on what’s new and what’s ahead. Internal Claims and Appeals—Plan Years Beginning …
Language-Assistance Requirements Under the ‘Culturally and Linguistically Appropriate’ Standard
September 26, 2011 Leave a Comment
We previously discussed when group health plans may have to provide participant communications in non-English languages. The latest guidance on internal claims and appeals and external review has refined the “culturally and linguistically appropriate” standard and added a new oral assistance requirement. In …
Enforcement Grace Period Extended for New Internal Claims and Appeals Requirements
March 25, 2011 Leave a Comment
The Department of Labor has further delayed enforcement of the new requirements for internal claims and appeals that apply to non-grandfathered plans. Technical Release 2011-01 extends and slightly modifies the enforcement grace period that was set to expire on July 1, 2011 under Technical Release 2010-01. The …
Information Collections & Claims Procedures
March 10, 2011 Leave a Comment
The DOL is requesting comments on the “information collections” that are imposed on non-grandfathered group health plans by the claims and appeal regulations under health care reform. The request, published on March 1, notes that these information collections are part of the “reasonable procedures that an …
Top 5 Health Care Reform Issues Employers Should Focus on Today
March 3, 2011 Leave a Comment
It has now been almost a year since health care reform was first enacted. The first year involved many compliance challenges, not the least of which was keeping up with the many pieces of guidance issued by the Department of Labor, Internal Revenue Service and Health and Human Services. But now that the first …
Annual Enrollment Materials and Welfare Notices
September 30, 2010 Leave a Comment
You may be preparing materials and notices for an upcoming annual enrollment period. Health care reform and other recent laws have added or changed several notices that are required before the next plan year starts (1/1/2011 for calendar-year plans). The agencies have provided several model notices to assist with …