Authored by Dannae L. Delano
Oct 16, 2017
Last week, the Department of Labor (DOL) proposed a 90-day delay of the new rules that require amending ERISA-covered employee benefit plan claims procedures with regard to disability claims filed on or after Jan. 1, 2018. The proposed delay would make the rules effective for claims filed on or after April 1, 2018. Further, the DOL also requests input regarding the costs associated with the implementation of the new rules.
You already know that the new ERISA claims requirements for disability benefits, which were to take effect and apply to disability claims filed on or after Jan. 1, 2018, applied to all disability claims and not just short-term and long-term disability programs. Some of the changes include:
What this means to you is a delayed effective date for the new rules governing how disability claims must be handled, which gives you additional time to consider and implement necessary amendments to your disability, qualified retirement and non-qualified deferred compensation plans that provide for disability benefits. In addition, you should consider that the DOL may be reconsidering the future implementation of the rules based on the impact of the rules’ expected costs.
If you have any questions about these compliance issues or any other employee benefits matter, please do not hesitate to contact Dannae Delano or any of the members of Lowenbaum Law’s benefits team.