Health Care Reform Advisory: Department of Labor Issues Q&As Regarding Selected Provisions of the Affordable Care Act
10/13/2010
On September 21st, the U.S. Department of Labor (the “Department”) issued a series of questions and answers (Q&As) clarifying a handful of issues arising under the Affordable Care Act. Topics covered include grandfathered plans, internal and external claims procedures, dependent coverage, out-of-network emergency services, and what constitutes a “highly compensated employee” for purposes of the Act’s insurance non-discrimination rules. In the first of these Q&As, the Department endeavored to establish that the Departments of Treasury, Labor, and Health and Human Services are taking a collaborative approach to enforcement, asserting that the agencies are:
