Employment, Labor & Benefits Advisory: DOL, HHS and IRS Issue Amendments to Rules Relating to Internal Claims and Appeals and External Review Processes under the Affordable Care Act
7/19/2011
On July 23, 2010, the Departments of Health and Human Services, Labor, and the Treasury (the Departments) issued interim final regulations implementing claims procedure rules for the Health Care and Education Reconciliation Act of 2010 (together, the Act). Guidance was issued that elaborated on these requirements and selectively extended some enforcement dates. Most recently, in response to a large volume of public comments, and mindful of the need to work in conjunction with state insurance regulators, the Departments issued an amendment to the interim final regulations as well as a technical release providing additional guidance.
This client advisory explains these two new developments relating to the Act’s claims procedure requirements.
