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July 26, 2010

HRB 11 - Internal Claims and Appeals, and External Review Process

July 26, 2010 --On July 23, 2010, the Departments of HHS, Labor, and Treasury issued interim final regulations relating to the internal claims and appeal, and external review process provisions of the health reform law (PPACA).  These rules provide for both a standardized internal process, as well as an external process, that individuals can use to appeal decisions made by their health plan.

July 15, 2010

HRB 10 - Preventive Health Services

July 15, 2010 -- On July 14, 2010, the Departments of HHS, Labor, and Treasury issued interim final regulations relating to the preventive care provisions of the health reform law (PPACA).  These rules require health plans to cover certain preventive services, without imposing any cost-sharing requirements (co-pay, co-insurance, or deductible), when such services are delivered by in-network providers. 

July 12, 2010

HRB 9 - New Model Notices Issued

July 12, 2010 -- In response to several notice requirements contained in recently issued regulations implementing the new health reform law, the DOL’s Employee Benefit Security Administration (EBSA) issued four new model notices, as follows:

July 12, 2010

MHPAEA: Welcomed Non-enforcement Guidance

The Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA), enacted on October 3, 2008, expanded the Mental Health Parity law, enacted in 1996.  Since the issuance of the interim final MHPAEA regulations earlier this year, many insurers have expressed concern about the practice of having two different payment standards for outpatient services, specifically, a co-pay, for example, for office visits, and a co-insurance for all other services. 

July 12, 2010

FMLA Broadened for Parents

The Family and Medical Leave Act was enacted in 1993 to provide time off and job protection in the event that an employee has a serious health condition, or to attend to a serious health condition of a family member, defined as a spouse, parent, son or daughter, as well as for the birth or adoption of a child.  The law applies to employers employing 50 or more employees.

June 29, 2010

HRB 8 - Early Retiree Reinsurance Program Application Process Opened

June 29, 2010 -- Today, the Department of Health and Human Services officially opened the Early Retiree Reinsurance Program (ERRP) application process, and will begin accepting ERRP applications immediately.  For information relating to ERRP, please refer to prior CBIZ Health Reform Bulletins:Early Retiree Subsidy – Initial Application Date is Approaching and Early Retiree Reinsurance Program.

June 23, 2010

HRB 7 - Patient’s Bill of Rights

June 23, 2010 -- On June 22, 2010, the Departments of Health and Human Services, Labor and Treasury (“Agencies”) issued another round of interim final regulations, implementing certain aspects of the health care reform law.  The regulations, curiously known as the “Patient’s Bill of Rights,” address such matters as the ban on annual and lifetime limits, preexisting condition exclusions, and rescissions, as well as some consumer protections, such as choice of primary care provider and emergency room access.  Following are highlights from these regulations.

June 16, 2010

HRB 6 - Grandfathered Health Plans Rules

June 16, 2010 -- One of President Obama’s health care reform commitments has been, “If you like your health coverage, you can keep it.”  The “grandfathered” health plan rules, contained in the Patient Protection and Affordable Care Act (PPACA), are ostensibly the mechanism for accomplishing this. 

June 11, 2010

HRB 5 - Early Retiree Subsidy – Initial Application Date is Approaching

June 11, 2010 -- As part of the Affordable Care and Patient Protection Act of 2010, an Early Retiree Reinsurance Program has been established. This temporary program, established by way of the health care reform laws, provides reimbursement of certain expenses to plan sponsors of group health plans that provide retiree coverage to early retirees, and their eligible spouses and dependents. While the Department of Health and Human Services set June 1, 2010, as the new effective date of this program, much is still needed to do in order to qualify for this reinsurance subsidy.  It is important to pursue this quickly if you are interested, as only $5 billion of funds are allocated to this program.  More questions still remain at this point, including the extent to which the employer may benefit from receiving a subsidy.  The clear intent of this program is to have employers pass along the benefits to early retirees currently included in their group plan.  The benefits could occur in the form of reduced contributions for coverage, lower deductibles, lower copayments and other forms of subsidies. 

June 7, 2010

IRS’ Compliance Questionnaire: 401(k) Plans

As part of an IRS compliance project, the agency is sending out approximately 1,200 questionnaires to a randomly selected group of 401(k) plan sponsors.  The goals of the questionnaire are to determine any potential compliance issues or plan operational issues, as well as to determine whether any additional education or guidance from the IRS would be beneficial for improving compliance.  The scope of the questionnaire includes the following topics:

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