Yet another piece of new guidance on the provisions of the federal health care reform law, the Patient Protection and Affordable Care Act, has been jointly issued by the Departments of Health and Human Services (HHS), Labor (DOL) and the Treasury (75 Fed Reg 43330, July 23 2010). This guidance explains the enhanced claims review and appeal procedures that are required of non-grandfathered plans under PPACA. Under the new rules, which become effective on September 21, 2010 for plan years beginning on or after September 23, 2010, plans must not only adopt specific internal claims and appeal procedures set forth in existing DOL regulations, but they must also make available certain external review procedures, including an external review opportunity to a state or federal agency. A government Fact Sheet explaining these new rules is available from HHS. Questions? Contact your health plan adviser.
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