1. Home
  2. |Insights
  3. |Partial Delay in New ERISA Claims Review and Appeal Regulations

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 | 2 min read | 12.29.25

FYI – GAO Finds Key Person “Available” Despite Accepting Employment with a Different Company

GAO’s key personnel rule is well-known—and often a source of frustration— amongst government contractors.  Proposed key personnel who become “unavailable” prior to contract award—especially where they have accepted employment with a different company—may doom an offeror’s proposal by rendering it noncompliant with solicitation requirements.  But GAO’s recent decision in FYI – For Your Information, Inc., B-423774, B-423774.2 (Dec. 19, 2025) provides some potential relief from that rule. ...