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Health Care Reform's Claims and Appeals Rules Amended
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Action Memo
Employee Benefits Law
September 2011
Section 2719 of the Patient Protection and Affordable Care Act, as amended by the Health Care and Education Reconciliation Act ("PPACA"), requires non-grandfathered insured and self-insured group health plans (and insurers) to amend their claims and appeals procedures. The procedures mandated by PPACA incorporate existing claims procedure rules under the Employee Retirement Income Security Act and require plans to conform to agency standards. In July 2010, the Departments of Health and Human Services ("HHS"), Labor ("DOL"), and Treasury ("IRS") (collectively, the "Departments") issued interim final regulations providing such standards. The July 2010 interim final regulations were significantly amended in June 2011. The DOL has also issued several related technical releases. Plans should welcome the latest guidance, as it generally delays compliance deadlines and relaxes and clarifies the July 2010 regulations.
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New NLRB Rule Requires Posting of Notice Regarding Employee Rights
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Information Memo
Labor and Employment Law
August 2011
In December 2010, the National Labor Relations Board (NLRB) used its long dormant rulemaking power and proposed a rule that would require private sector employers to post a notice advising employees of their right to join a union under the National Labor Relations Act (NLRA). After receiving over 7,000 comments, on August 25 the NLRB adopted the Final Rule by a 3 to 1 vote, with Member Hayes dissenting. The Final Rule was published in the Federal Register on August 30 and will go into effect 75 days from that date on November 14, 2011. The Final Rule applies to all private sector employers that are subject to the NLRB’s jurisdiction.
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