Internal Claims, Appeals and External Review: A Refresher for 2012

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 …

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Language-Assistance Requirements Under the ‘Culturally and Linguistically Appropriate’ Standard

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 …

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Enforcement Grace Period Extended for New Internal Claims and Appeals Requirements

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 …

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