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DOL Audit Letters Requesting Proof of Compliance with Health Care Reform Requirements
McDermott Will & Emery
[Guidance Overview] Feb. 19, 2013
"The [DOL] recently expanded its health plan audit letter to request documents demonstrating compliance with the [ACA]. [Items requested include:] [S]amples of the written notice describing enrollment opportunities related to dependent coverage of children up to age 26; A list of any individuals whose coverage has been rescinded, the reasons for the rescissions and copies of the written notices of rescission that were provided.... Records documenting the terms of the plan in effect on March 23, 2010, and any other documents necessary to verify, explain or clarify status as a grandfathered health plan ... Samples of adverse benefit determinations and external review decision notices utilized by the plan on or after September 23, 2010 [in the case of non-grandfathered plans]."
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