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Group health plans (other than those that are "grandfathered") must comply with a number of internal claims and appeals procedures that go beyond those previously required under ERISA. As explained in our November 2010 article, last year’s Affordable Care Act (ACA) restricted the ability of employer health plans, including flexible spending arrangements (FSAs) and health reimbursement arrangements (HRAs), to reimburse expenses incurr… With the exception of insulin, expenses for OTC medications may now be reimbursed only if the medications are prescribed by a physician. On April 1, 2011, the Centers for Medicare and Medicaid Services (CMS) issued revised Medicare Part D creditable and non-creditable coverage notices to reflect an amendment made to the Social Security Act by the Affordable Care Act (ACA). The final legislation achieves this offset by requiring larger repayments of excess "federal assistance credits" received by individuals who purchase health coverage through one of the ACA’s state-wide "Exchanges." As a part of the recent compromise allowing for passage of a federal budget for the fiscal year ending September 30, 2011, congressional Republicans succeeded in repealing a significant provision of last year’s Affordable Care Act (ACA).Changes to PPACA Internal, External Review Processes
June 30 Deadline for FSA Amendments
June 30 Deadline for FSA Amendments
CMS Revises Medicare Part D Notices
Expanded 1099 Reporting Requirements Are Repealed
Budget Compromise Eliminates Free-Choice Vouchers