The DOL, HHS and IRS have jointly issued amendments to the interim final regulations on internal claims and appeals requirements and external review procedures. Among other things, these regulations offer a transition period to allow time for issuers and plans to make a reasonable transition to implement external review processes. Specifically, under an amendment to the July 2010 regulations being published contemporaneously with this technical guidance, the transition period is modified to extend through Dec. 31, 2011. HHS intends to issue determinations regarding state external review implementation no later than July 31, 2011. The agencies have also issued revised model notices as part of the new technical release guidance on state and federal external review procedures.

Click here to read Technical Release 2011-02.