Will the Wrap documents be revised to include the new disability claims procedures?

The U.S. Department of Labor (DOL) issued a regulation in late 2016 to require group health plans providing disability benefits to comply with additional procedural requirements for disability benefit claims. The regulation, which was to apply to disability claims filed on or after January 1, 2018, would have brought disability claims procedures more in line with the procedures that currently apply to claims for group health benefits under the Affordable Care Act.

However, the DOL recently proposed a 90-day delay of the new disability claims procedures. If the proposal is finalized, the new disability benefit claims procedures would become applicable to claims for disability benefits that are filed after April 1, 2018, rather than January 1, 2018. As a result, changes to the Wrap templates would be premature at this time, and the current rules outlined in the Wrap documents will continue to govern.

A proposed Summary of Material Modifications (SMM) template, reflecting the changes to the disability claims procedures that could potentially take effect, is now available in the "SMM Document" section of Wrap360. Note that the proposed SMM should be used for general reference purposes only until the final rule becomes effective. 

Wrap360 will continue to follow this issue closely and will send an email alert to our clients if any updates are required.