On August 23, 2010, the Departments of Labor (DOL), Health and Human Services (HHS), and Treasury (collectively, the “Agencies”) jointly released model notices that non-grandfathered plans and health insurance issuers may use to satisfy new requirements under the Patient Protection and Affordable Care Act (PPACA) regarding adverse benefit determinations and appeals of adverse benefit determinations. Additionally, the Agencies released interim guidance establishing procedures for the “Federal external review process” established by PPACA, which contains a limited enforcement safe-harbor for self-funded group health plans. Please see the attached memo for further information.


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