Hunton Employment & Labor Perspectives

On July 19, 2010, the United States Departments of Health and Human Services, Labor and Treasury issued interim final regulations covering the mandates under the Patient Protection and Affordable Care Act, as amended (the “Health Care Reform Act”), relating to the internal and external claims review process. These requirements, which do not apply to grandfathered group health plans, substantially expand the claims review and appeals processes that group health plans must follow in administering claims. Because the new requirements apply as of the beginning of the first plan year on or after September 23, 2010, all group health plans, especially self-funded plans that administer claims internally, must begin taking action now to update their claims review processes and plan documentation to comply with the new rules.