The U.S. Department of Labor (“DOL”) recently announced that final regulations updating the process requirements for claims involving disability benefit determinations (the “Final Rule,” 81 Fed. Reg. 92316 (Dec. 19, 2016)) will take effect for claims after April 1, 2018.

The Final Rule attempts to harmonize the rules governing disability claims with the requirements applicable to group health plans under the Patient Protection and Affordable Care Act (“ACA”). DOL previously delayed the applicability date of the Final Rule for 90 days to conduct a review of the potential effects but has now concluded that the agency will not further delay or change the claims regulations. Plan sponsors should carefully review their plans to determine what changes are necessary.


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