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ACA Facelift to Disability Claims Process Could Affect All Plans
Benefits Bryan Cave Link to more items from this source
[Guidance Overview]
Dec. 20, 2016

"For insured disability plans, plan sponsors need to engage their insurance carriers in a discussion about how these procedures will apply to them and what changes are needed to the insurance contracts. Some insurers may be slow to adopt these new procedures, which could put plan sponsors in a difficult position. For self-funded disability plans, plan documents will need to be updated, and procedures put in place. For retirement plans, there are some decisions to make. Recall that the procedures only apply if a disability determination is required. One way to avoid this is to amend the definition of disability so that it relies on a determination by the Social Security Administration or the employer's long-term disability carrier. For defined contribution plans, this is likely to be the most expedient approach."

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