Department of Labor claim procedure rule
On November 21, 2001, the U. S. Department of Labor (DOL) issued regulations establishing minimum claims procedure requirements for employee benefit plans covered under the Employee Retirement Income Security Act of 1974 (ERISA). In general, the final rule establishes:

• Maximum timeframes for making claims determinations.
• Minimum information disclosure requirements to claimants in the event of an adverse benefit determination.
• Procedural requirements for 1) initiating claims, and 2) appeals of adverse benefit determinations.

The original compliance date was for all claims filed on and after January 1, 2002. The compliance date was delayed because of the rule's complexity and the difficulty of implementing needed changes to systems and business processes. The new compliance date is January 2003 or the first day of the first plan year beginning after July 1, 2002, whichever is later.

In addition, the DOL felt the delay was warranted due to their belief that federal Patient Bill of Rights legislation will likely be enacted before or shortly after January 1, 2002. The final Patient Bill of Rights may address many of the same procedural requirements addressed in the final rules. Therefore, the delay will allow those subject to the ERISA rules and an imminent Patient Bill of Rights law to avoid costly rework and additional changes to computer systems and business processes.

While we welcome the additional time to complete our implementation activities, we were on track to be in compliance prior to January 1, 2002. We will continue to monitor information released by the DOL and the progress of Patient Bill of Rights legislation in Congress and adjust our compliance implementation activities accordingly.

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