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
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On July 20, 2026, New Jersey Governor Mikie Sherrill signed the Forbidding the Algorithmic Inflation of Rent (FAIR) Act into law, making New Jersey the fourth state to regulate algorithmic rent-setting practices. Three days later, on July 23, 2026, Governor Sherrill signed the Fair Price Protection Act, which targets “surveillance pricing”—the practice of using or collecting personal data about a user and using an algorithm or artificial intelligence to charge different consumers different prices for the same products. Together, these laws represent a significant expansion of New Jersey's consumer protection framework in the algorithmic pricing context.
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The Pipe, Not the Posts: How Section 230’s Protections Extend to Generative AI Platforms
