Jenner & Block

Client Advisory: Department of Labor Extends Non-Enforcement Period for Certain Internal Claims and Appeals Procedures under the Patient Protection and Affordable Care Act

In this advisory, Partners S. Tony Ling and Matthew J. Renaud, and Associate Sarah E. Haddy discuss the Department of Labor’s extension of the non-enforcement period for certain internal claims and appeals procedures under the Patient Protection and Affordable Care Act (PPACA).  The authors note that while no enforcement action will be taken until January 1, 2012, for calendar year plans, health plans should work in good faith toward compliance.