The Washington Report
March 21, 2018
UHC’s Drug Rebate Program—Impact on Employers
In December 2016, the U.S. Department of Labor (DOL) issued new claims procedure rules for disability benefits under pension or welfare benefit plans that are subject to Title I (provisions governing the protection of employee benefit rights) of the Employee Retirement Income Security Act of 1974, as amended (ERISA). Those rules originally were scheduled to apply to any disability claim filed after December 31, 2017. However, after reconsideration, the DOL delayed the applicability date; the new rules now generally apply to any disability benefit claim filed after April 1, 2018 (regardless of when the disability was incurred).
Employers sponsoring any employee benefit plan that is subject to Title I of ERISA (or that otherwise voluntarily follows ERISA’s claims procedure rules) and conditions benefits upon a showing of disability should review their plan documents to determine if any amendments are necessary to address the new disability claims procedure rules. Any amendments to qualified pension (including defined benefit or defined contribution) plans should be timely adopted in accordance with guidance established by the Internal Revenue Service. Applicable welfare plans (in addition to pension plans) also may require updating. In addition, plan fiduciaries should ensure that the plan operationally complies with the new rules when they become effective.
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