Topics Covered

Here’s some of what was covered:

• What health plans are affected (including exceptions for grandfathered plans and “excepted benefits,” like limited-scope vision and dental plans, and most health FSAs).
• Now that the scope of review has been narrowed by the amended regulations, what types of claims are subject to external review? What open issues remain?
• The amended regulations also impose a new “culturally and linguistically appropriate” standard, based on county-by-county language statistics from the census bureau: Which employer plans are affected, and what new administrative requirements may be created?
• How do the enforcement grace periods work: Which requirements are effective later and which ones must be followed now?
• What are the biggest challenges for complying with the external review rules (including notices, performing the preliminary review, and contracting with IROs)?
• How to create a checklist of notice content requirements.
• How do the amended regulations change the strict compliance rule, and what are the consequences of noncompliance?

Note: This seminar will focus on the rules for self-funded employer plans. The rules that apply to insurers for insured employer plans will not be addressed.