On March 18, 2011, the Department of Labor (“DOL”) issued Technical Release 2011-01 (“TR 2011-01”), extending the enforcement grace period for four provisions of the interim final claims and appeals regulation. These provisions, which are applicable only to non-grandfathered group health plans, (1) mandate faster responses to urgent care claims, (2) require notices to be provided in a non-English language in certain cases, (3) apply a new strict compliance standard, and (4) expand the required content for adverse benefit determinations. Prior to the issuance of TR 2011-01, these four provisions were scheduled to become enforceable July 1, 2011. Now, for calendar year plans, the provisions will not become enforceable until January 1, 2012. To take advantage of this extension, employers sponsoring non-grandfathered health plans should coordinate with their third party administrators and carriers and review the description of their claims procedures.
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