PPACA requires employers to revise their internal group health plan claims procedures and to adopt external review procedures. Employers have been granted an additional enforcement grace period to bring nongrandfathered health plans into compliance with internal claims and appeals rules under PPACA. Interim final regulations were issued in July 2010, and the Department of Labor ("DOL") had initially offered an enforcement grace period for compliance with some of the additional standards until July 1, 2011. However, because the DOL intends to revise the interim final regulations, the DOL has extended the enforcement grace period until January 1, 2012, with respect to the following standards:

  • shortening the timeframe for responding to urgent care claims from 72 hours to 24 hours;
  • providing notices in a culturally and linguistically appropriate manner;
  • requiring broader content and specificity in notices;

requiring substantial compliance with the claims procedures rules. See http://www.dol.gov/ebsa/pdf/tr11-01.pdf for the full text of DOL Technical Release 2011-01.