One of the many provisions of the Patient Protection and Affordable Care Act of 2010 (“PPAC”) is a requirement that group health plans and health insurance issuers have an effective internal claims and appeals process. As is the case for a number of the PPAC provisions, this requirement becomes effective for plan years beginning on or after September 23, 2010. For a number of health plans, this will mean January 1, 2011.To give group health plans and insurance issuers more time to comply with these claims and appeals regulations, on September 20, 2010, the Departments of Labor, Treasury and Health and Human Services implemented an enforcement grace period until July 1, 2011. This means that, during the grace period, the Government will not take enforcement action against a group health plan that is working in good faith to implement the required standards. As a result, plans and insurance issuers will have more time to make necessary changes to computer systems and to implement other procedures needed to comply with these rules. If you have any questions concerning this issue or any other issues involving employee benefit matters, please feel free to contact us.