Client Alerts

DOL Grants Certain Group Health Plans Relief By Extending Non-Enforcement Period for Internal Claims and Appeals Requirements

April 04, 2011

Eric Keller, Stephen Harris & Andrea Gehman

The Department of Labor extended its non-enforcement period, until plan years beginning after December 31, 2011, for certain internal claims and appeals requirements under the Patient Protection and Affordable Care Act (PPACA) that apply to non-grandfathered group health plans. The internal claims and appeals requirements are among PPACAs most significant and controversial changes. If a non-grandfathered plan fails to comply with these requirements in any respect no matter how insignificant claimants will be deemed to have exhausted their administrative remedies and may go directly to court. The extension of the non-enforcement period for some of these requirements is welcome news for employers; however, because this extension is likely the final delay, employers should be working diligently to comply with them.

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