Interim Final Rules for Internal Claims and Appeals and External Review Processes under the Patient Protection and Affordable Care Act

The Departments of Health and Human Services, Labor and Treasury recently issued an interim final regulation (IFR) regarding the requirement that group health plans and health insurance issuers implement an effective internal claims and appeal process, as well as an effective external review process. The IFR builds upon and enhances existing ERISA claims procedures applicable to group health plans and adds some new requirements.