Compass
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Bates & Company, Inc.
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AimPoint Pension
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Regional Vice President of Sales The Retirement Plan Company
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Loan & Distribution Specialist AimPoint Pension
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Defined Benefit Combo Cash Balance Compliance Consultant Loren D. Stark Company (LDSCO)
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Guest Article
(From the September 27, 2010 issue of Deloitte's Washington Bulletin, a periodic update of legal and regulatory developments relating to Employee Benefits.)
Recently released "Frequently Asked Questions" by the Department of Labor shed light and provide new information on how certain Patient Protection and Affordable Care Act (PPACA) requirements are to be implemented. In a set of sixteen questions, the Department addresses particular concerns regarding grandfathered plans, claims procedures, dependent coverage of children, and out-of network emergency services. Among other worthwhile guidance, the Department clarifies the following:
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The FAQs also provide a useful overview of the new claims review requirements, outlining the transitional relief available for non-grandfathered plans. The FAQs recognize that a self-insured plan may not be contracting directly with an independent review organization (IRO), but rather the plan's third-party administrator may be doing so. The Department advises that such arrangements may satisfy the requirements, but notes that the plan fiduciaries would, nonetheless. have a duty under ERISA to monitor the IRO and the other plan service providers. Q&A-9.
The information in this Washington Bulletin is general in nature only and not intended to provide advice or guidance for specific situations.
If you have any questions or need additional information about articles appearing in this or previous versions of Washington Bulletin, please contact: Robert Davis 202.879.3094, Elizabeth Drigotas 202.879.4985, Mary Jones 202.378.5067, Stephen LaGarde 202.879-5608, Bart Massey 202.220.2104, Tom Pevarnik 202.879.5314, Sandra Rolitsky 202.220.2025, Deborah Walker 202.879.4955. Copyright 2010, Deloitte. |
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