Partial Delay in New ERISA Claims Review and Appeal Regulations
Client Alert | 1 min read | 07.10.01
On July 9th, the Department of Labor announced a delay (66 Fed. Reg. 35886) in the implementation date of the new ERISA claims review and appeals regulations issued November 21, 2000. Previously, the new ERISA regulations were going to be effective for all group health claims filed on or after January 1, 2002. Per the July 9th regulatory change, the new ERISA regulations will apply to group health claims filed on or after the first day of the first plan year beginning on or after July 1, 2002, but in no event, later than January 1, 2003. Consequently, for ERISA group plans with a renewal date between July 1, 2002 and December 31, 2002, the appeals process for those groups must be implemented by their renewal date. For all other groups (i.e., groups with a renewal date between January 1, 2002 and June 30, 2002), health plans must have the appeals process implemented by January 1, 2003.
Insights
Client Alert | 5 min read | 04.01.26
OPO Hospital Waiver Litigation: Trends and Takeaways
Despite facing existential challenges in several federal courts, the performance metrics established by the Centers for Medicare and Medicaid Services’ (CMS) 2020 Final Rule for organ procurement organizations (OPO) appear to be, at least for now, withstanding scrutiny in litigation proceedings.
Client Alert | 7 min read | 04.01.26
Client Alert | 5 min read | 03.31.26
Washington State Bans and Voids Most Noncompetes, Narrows Nonsolicits
Client Alert | 5 min read | 03.30.26
Déjà Vu? New Executive Order Outlines Restrictions on Contractor and Subcontractor DEI Activity
