Technical Bulletin – 2016 Issue 3 – DOL Proposes New Claim and Appeal Rules for Disability Benefits

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In late 2015, the DOL issued proposed disability claim regulations which, if finalized, will have a significant impact on claims administration procedures for plans subject to ERISA. Disability benefits under the DOL’s regulation would include benefits such as short-term and long-term disability income benefits and waiver of premium claims under a life insurance contract. The proposed regulations would not apply to uninsured and unfunded sick pay plans that qualify as a “payroll practice.”