Safe Harbor (Of Sorts) on Federal External Review Procedures for Self-Insured Plans

Plans need to be prepared to act quickly on, among other things, updating notices and administrative procedures, amending existing claims procedures, adopting new external review procedures, selecting 3 independent review organizations (IROs) to perform external reviews, and preparing service agreements to govern the plan / IRO relationship.  Along with the Technical Release, the DOL issued 3 Model Notices for use with the external review procedures: (1) a model notice of adverse benefit determination, (2) a model notice of final internal adverse benefit determination, and (3) a model notice of final external review decision.  

Please see Littler's ASAP, New Health Care Claims and Appeal Rules Will Include a Tax Bite, for more detailed information.   

Russell Chapman authored this entry.

Information contained in this publication is intended for informational purposes only and does not constitute legal advice or opinion, nor is it a substitute for the professional judgment of an attorney.