As with most things government, regulation marches on. The US Department of Labor Employee Benefits Security Administration has made some more information available regarding PPACA (health care reform). They should be reviewed as part of your overall compliance process.

The first is a release of "FAQs on ACA Implementation", available at http://www.dol.gov/ebsa/faqs/faq-aca.html. It addresses a number of question, particularly relevant to grandfathereing and to multiemployer plans.

Technical Release 2010-02, "Interim Procedures for Internal Claims and Appeals", is available at http://www.dol.gov/ebsa/newsroom/tr10-02.html. This technical bulletin gives additional information about what appeal notices must contain and also timing of the issuance of notices for appeal rights to apply.

Finally, in conjunction with Release 2010-02, there is a "Revised Model Notice of Adverse Benefit Determination", available at http://www.dol.gov/ebsa/IABDModelNotice2.doc. It is important to note that this model notice does not only apply to "external appeals." It also does not define the external appeals process. It looks like this is the new standard for benefit denials and plan administrators should definitely review it with sponsors and plan professionals to determine its suitability for plan use.