Phia Group Russo & Minchoff

PPACA, HIPAA and Federal Health Benefit Mandates: Practical

cmonfils | September 16, 2011

The Self-Insurer                               August 2011

By Carolyn Smith, Esq. and John Hickman, Esq., Alston & Bird, LLP

New Claim Review Regulations Ease Compliance Burdens For Group Health Plans

                On June 24, 2011, the U.S. Department of Treasury, Labor (DOL) and Health and Human Services (HHS) (collectively, the “Agencies”) jointly issued new interim final regulations (“Final Regulations”) and related guidance regarding the internal appeals and external claim review procedures (“Claims Review Rules”) for fully insured and self-funded group health plans and insurance policies issued in the individual market. These new requirements were added by the Affordable Care Act (ACA). The Claims Review Rules apply only to non-grandfathered group health plans otherwise subject to the health insurance reforms added by ACA. (more…)

PPACA, HIPAA and Federal Health Benefit Mandates: Practical

cmonfils | August 22, 2011

The Self-Insurer                August 2011 

By Carolyn Smith, Esq. and John Hickman, Esq., Alston & Bird, LLP

New Claim Review Regulations Ease Compliance Burdens For Group Health Plans

          On June 24, 2011, the U.S. Department of Treasury, Labor (DOL) and Health and Human Services (HHS) (collectively, the “Agencies”) jointly issued new interim final regulations (“Final Regulations”) and related guidance regarding the internal appeals and external claim review procedures (“Claims Review Rules”) for fully insured and self-funded group health plans and insurance policies issued in the individual market. These new requirements were added by the Affordable Care Act (ACA). The Claims Review Rules apply only to non-grandfathered group health plans otherwise subject to the health insurance reforms added by ACA. (more…)

Claims Appeal and Review Obligations Lessened to Relief of Plans, Insurers

cmonfils | August 4, 2011

Claims Appeal and Review Obligations Lessened to Relief of Plans, Insurers
July, 2011
Thompson Publishing Group

Plans and insurers will have an easier time complying with health reform’s internal appeals and external review rules, under rules the U.S. Departments of Labor, Treasury and Health and Human Services issued June 24.

The changes, such as dropping the requirement for plans to display diagnosis and treatment codes on initial and final notifications of adverse determinations, should ease burdens for employer-sponsored plans. Another change lengthened the time allowed to review urgent care claims from “no more than 24 hours” to “as soon as possible but no more than 72 hours.” (more…)

Health Care Reform Update: New Guidance and Transitional Relief for PPACA Claims and External Review Procedures

cmonfils | July 15, 2011

www.pillsburylaw.com    Lori Partrick     7/7/11

The Departments of Labor, Treasury and Health and Human Services have amended the interim final rule issued in July 2010 regarding internal claims and appeals and external review requirements under the Patient Protection and Affordable Care Act (“PPACA”).1 The Department of Labor has also published a related technical release providing additional guidance and revised model determination notices. These amendments may require updates to the claims procedures included in summary plan descriptions of affected plans. (more…)

Health Care Reform Appeals Process Update

cmonfils | July 11, 2011

www.ftwilliam.com            7/7/2011

On June 24, 2011 the IRS (Internal Revenue Service), DOL (Department of Labor) and DHHS (Department of Health and Human Services) jointly published an amendment to the interim final rules on rules relating to internal claims and appeals and external review processes. Along with the new rules (on June 22) the departments also issued Technical Release No. 2011-02 and revised model notices (Revised Model Notice of Adverse Benefit Determination, Revised Model Notice of Final Internal Adverse Benefit Determination, Revised Model Notice of Final External Review Decision). The new guidance and new notices came just one week before the benefit denial notice requirements are no longer under an enforcement grace period (scheduled to end the first plan year beginning on or after July 1, 2011). (more…)

PPACA Internal Claims Procedures for Group Health Plans Are Simplified

cmonfils | July 11, 2011

www.benefitslink.com   (From the June 27, 2011 issue of Deloitte’s Washington Bulletin, a periodic update of legal and regulatory developments relating to Employee Benefits.)

Those portions of the new internal claims review procedures that are required of group health plans and issuers under the Patient Protection and Affordable Care Act (PPACA) — and for which an “enforcement grace period” was granted until 2012 — are being simplified by the enforcement agencies in response to public comment. (more…)

Extension of Claims Regulations Enforcement Grace Period

cmonfils | April 1, 2011

www.healthplanlaw.com   Roy Harmon III

March 23, 2011

Section 2719 of the Public Health Services  Act sets forth standards for plans and issuers that are not grandfathered health plans regarding internal claims and appeals and external review. These rules are aimed at bolstering ERISA’s “due process” requirements by amplifying the old claims regulation released back in 2000, namely, 29 CFR 2560.503-1. (more…)

Administration Delaying Some Rules For Appealing Health Insurance Denials

cmonfils | April 1, 2011

www.kaiserhealthnews.com

By Susan Jaffe   Mar 25, 2011

The Obama administration is delaying until next January its enforcement of some new rules designed to protect patients who appeal insurers’ decisions to deny or reduce health care benefits.

In the meantime, the Labor Department said in a posting on its website that it will revise the requirements to deal with objections raised by insurers. These rules were mandated by the health care law, and federal officials had earlier said they would start enforcing them in July. (more…)

Extension of Non-Enforcement Period Relating to Certain Interim Procedures for Internal Claims and Appeals under the Patient Protection and Affordable Care Act

cmonfils | March 18, 2011

www.dol.gov

March 18, 2011

Introduction

The Departments of Labor, Health and Human Services (HHS), and the Treasury (the Departments) have been issuing regulations in several phases to implement the revised Public Health Service Act (PHS Act) sections 2701 through 2719A and related provisions of the Patient Protection and Affordable Care Act (Affordable Care Act). Section 2719 of the PHS Act sets forth standards for plans and issuers that are not grandfathered health plans regarding internal claims and appeals and external review. The Departments published interim final regulations implementing PHS Act section 2719 on July 23, 2010, at 75 FR 43330 (the 2010 interim final regulations). (more…)

External Claim Reviews Recommended for Self-Funded Plans; Not Required by PPACA

cmonfils | January 3, 2011

MyHealthGuide Newsletter 1/3/2011

*Spencer’s Benefits Reports / CCH® BENEFITS via Passion for Subro, The Health Insurance Blog of Attorney Adam V. Russo, 12/23/2010

*US DHHS EBSA: www.dol.gov/ebsa/regs/cmt-1210-28876.html

The Business Roundtable provided the following information about external review of medical claims for large, self-funded plans:

“Although there is no requirement to do so, many self-insured plans already voluntarily provide for an external review of denied medical claims.Though we know of no broad statistical data on this subject, it is our belief that as many as 30% to 40% of large employers with self-insured group health plans provide some form of external review for certain medical claims. Just as one finds variation among states in their requirements for independent external review for insured health plans, similarly there is considerable variation among self-insured plans in the procedures they use for external review.” (more…)