Health care reform communications going to every other week
Going forward, we will issue health care reform communications to brokers every other week instead of weekly. As the frequency and amount of information we receive decreases, this will allow us more time to deal with business decisions to implement the health care reform regulations.
The next health care reform communications to brokers will be April 15.
Additional grace period issued for appeals implementation
Just after we sent the update about our implementation approach for some appeals provision regulations, the Department of Labor (DOL) issued Technical Release 2011-01 . This document does not change the current guidance provided in last year's interim final rules. However, it provides health insurers a longer implementation time period for some of the key elements within the 2010 interim final rules.
Based on this guidance from DOL, health insurers and group health plans have until plan years beginning on or after January 1, 2012, to implement the new requirements related to:
- Including diagnosis and procedure codes on denial notices;
- Providing notices to consumers in languages other than English;
- Shortening the time period for prior approval of an urgent care claim; and
- Giving claimants the right to bypass internal appeals and go to external appeal or litigation if the insurer or plan fails to "strictly comply" with the rule.
Previous guidance from DOL required compliance with all of these requirements on July 1, 2011.
During this new implementation time frame, health insurers and group health plans are not required to implement these provisions. This new time frame is designed to provide the agencies with more time to issue an amended interim final rule, and we anticipate its release in the near future, and this may impact our implementation.
This technical release does not impact existing interim final rules that require adverse benefit determinations (for example, denial notices, explanation of benefit forms, etc.) to include the amount and date of the claim, service provider and reason for denial. And, health insurers are still required to include the enhanced description of internal/external appeals process and state-specific contact information, if applicable, for the state's office of health insurance consumer assistance. All of these requirements, as defined in the interim final rules, will still apply for plan years beginning on or after July 1, 2011.
Thank you for your patience and understanding as our implementation teams continue to assess and act on the latest regulatory guidance.