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Authorized Representatives – Fresh Look at an Old Rule

Earlier this year, the Department of Labor issued an information letter explaining ERISA’s authorized representative requirement.  Below are some of the takeaways employers may want to consider. 1.     The Authorized Representative Requirement Under ERISA ERISA’s claims procedure regulations expressly give participants and beneficiaries the right to appoint authorized representatives to act on their behalf in […]

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The New Disability Claims Regulations: They Don’t Only Apply to Disability Plans

Introduction The Department of Labor (“DOL”) issued regulations that revise the ERISA claims procedure regulations for employee benefit plans that provide disability benefits (the “New Disability Claims Regulations” or “New Regulations”).  They are based on the Affordable Care Act’s (the “ACA”) enhanced claims and appeals regulations for group health plans (the “ACA Enhanced Regulations”).  The […]