ReedGroup informed you in December of changes to the Employee Retirement Income Security Act’s (ERISA’s) regulations impacting disability benefits. On July 20th, the Trump administration announced that these regulations are part of the Spring 2017 Unified Agenda of Federal Regulatory and Deregulatory Actions. These regulations are now on review for “law and policy” to determine if they should be amended, delayed, or withdrawn. Details can be found here.  For background on ERISA’s regulatory changes, you can reference our blog article here and our webinar here.

These ERISA regulations will undergo another notice of proposed rulemaking and public comment period, slated for September this year. As it did during the last public comment period, ReedGroup anticipates submitting comments.

What this delay means:

  • retain the final regulations and proceed with the new disability claims procedures either with:
    – the current January 1, 2018 effective date; or
    – with a delay implementation date;
  • amend the regulations; or
  • revert to the regulations in effect prior to the changes made in the December 2016 final regulations.

What Employers and claims administrators should do:
During this regulatory delay and pending more information from the DOL, employers should consider how far along they are in implementing the December 2016 final regulations. Employers and claims administrators can either:

  • proceed with their changes; or
  • consider holding off on implementing any such changes until the DOL’s strategy with respect to these rules becomes clear.

ReedGroup is assessing its options as a disability third party claims administrator and will notify clients shortly of its chosen course of action. In the meantime, if you are a current client and have questions, please contact ReedGroup.

ReedGroup’s Vice President of Compliance, Megan Holstein, is discussing the impact of this regulatory delay tomorrow, Tuesday, August 1, at DMEC’s Annual Conference. If you are there, please join her and Jackson Lewis attorney, Rene Thorne, at 4:15 for more exciting updates!

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