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ARTICLE · 06 OCTOBER 2010

Extended Grace Period Available

Venable LLP
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On September 20, 2010, the Department of Labor ("DOL") issued Technical Release 2010-02, which provides an extended grace period for some of the modifications to the internal claims and review process required by the interim final regulations issued earlier this summer.

United StatesEmployment and HR
Thora Johnson
Thora Johnson
Martha Wagner
Martha Wagner
Jessica Kuester
Jessica Kuester

What's happened now?

On September 20, 2010, the Department of Labor ("DOL") issued Technical Release 2010-02, which provides an extended grace period for some of the modifications to the internal claims and review process required by the interim final regulations issued earlier this summer.1 Before this technical release was issued, all of the changes required by the regulations were effective January 1, 2011 for calendar year non-grandfathered group health plans.2

What's the grace period mean?

Under the extended grace period, enforcement actions will not be taken by the DOL or the Internal Revenue Service against a non-grandfathered group health plan before July 1, 2011, so long as the group health plan is making a good-faith effort to implement (even though not yet in place) the affected regulatory requirements outlined below.

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