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Update on State External Review Processes

Technical release 2011-02, issued by the U.S. Department of Labor on June 22, 2011, offered guidance on external review for group health plans, health insurance issuers, as well as guidance for states on state external review processes.  In this technical release the Department of Labor explained that the transition period for State external review process implementation had been extended to January 1, 2012.  Though many states met the implementation deadline of January 1, 2012, many did not, and CCIIO continues to approve state external review processes as they are submitted.  To keep track of the status of state external review processes as they relate to the ACA requirements, the CMS Center for Consumer Information and Insurance Oversight (CCIIO) has published a list indicating which states meet requirements that are parallel or similar to the language in the NAIC Uniform Health Carrier External Review Model Act, and which states must follow the HHS Administered or Independent Review Organization process.  The list is updated periodically and is available at

MRIoA monitors the list published by CCIIO regularly and has established contacts with states in order to remain current on all regulations and licensure requirements.  We have been working hard to acquire licensure and/or certification in those states that have been deemed by CCIIO to have NAIC-parallel or NAIC-similar processes.

If at any time you have questions or comments about state or federal external review processes please feel free to contact me at (800) 654-2422 ext 6475 or

Aja Ogzewalla, Director of Regulatory Compliance