ERISA plans that include disability benefits must comply with new procedural protections for claims that are submitted after April 1, 2018. The final rule includes the following requirements for the processing of claims and appeals for disability benefits:

• Improvement to Basic Disclosure Requirements
• Right to Claim File and Internal Protocols
• Right to Review and Respond to New Information Before Final Decision
• Avoiding Conflicts of Interest
• Deemed Exhaustion of Claims and Appeal Processes
• Certain Coverage Rescissions Are Adverse Benefit Determinations Subject to the Claims Procedure Protections
• Notices Written in a Culturally and Linguistically Appropriate Manner

Entities that administer disability benefit claims, including issuers and third-party administrators, will need to revise their claims procedures to comply with the final rule. Refer to the below compliance bulletin for details and contact your NEEBCo representative with questions.

New Rules for Disability Claims Will Take Effect on April 1, 2018