22 Jul 2025
Benefit Check: Mastering ERISA Claims Procedures from Filing to Final Review
The Section 503-1 ERISA regulation sets forth minimum requirements for employee benefit plan procedures pertaining to claims for benefits by participants and beneficiaries (also referred to as claimants). The claim procedure regulation applies to every type of ERISA plan (as described in ERISA § 4(a)), including almost all employer-sponsored (or employee organization-sponsored) retirement plans, health plans, and other welfare and fringe benefit plans. The regulation does not cover plans that are exempt from ERISA under ERISA § 4(b) (i.e., governmental plans, non-electing church plans, statutorily mandated workers' compensation and disability insurance plans, non-U.S. plans maintained primarily for the benefit of nonresident aliens, and excess benefit plans). Learn more about the minimum requirements
Related Content
- Claims Procedure ERISA Requirements Checklist (General Rules)
Review this checklist describing the minimum timing and notice standards for a benefit plan's internal claims procedure under ERISA. The ERISA rules essentially require covered plans to establish and maintain an internal process reasonably designed to ensure a full and fair review of benefit claims and a claimant’s appeal of an adverse determination. - Claims Procedure ERISA Requirements Checklist (Group Health Plans)
Refer to this checklist for the enhanced standards required for a group health plan's benefit claims procedure under ERISA and under the Patient Protection and Affordable Care Act (ACA). Any adverse determination regarding a group health plan claim for benefits must be in writing (except a decision on an urgent care claim may be provided orally if followed up by a written notice within three days) and contain prescribed information, as set forth in this checklist.
Practical Guidance Updates
Featuring the latest updates from your Practical Guidance account.
- Employee Benefits & Executive Compensation Key Legal Developments Tracker (Current)
Stay informed on new developments.- Retirement Plans. U.S. Department of Labor's EBSA Division rescinds its 2022 compliance releasethat discouraged fiduciaries from including cryptocurrency options in 401(k) retirement plans. DOL, News Release.
- Retirement Plans. President Trump signs the One Big Beautiful Bill Act (OBBBA) on July 4. Among its employee benefits changes, OBBBA permanently extends the safe harbor that permits HDHPs to cover telehealth services before the plan’s deductible is met. The new law permanently allows employers to provide tax-free student loan repayment assistance under I.R.C. § 127 educational assistance programs and it increases the annual tax-free limit for dependent care assistance programs under I.R.C. § 129, like dependent care FSAs, from $5,000 to $7,500. L. No. 119-21.
- Health and Welfare Plans. HHS rescinds informal guidance interpreting sex-based discrimination, including its 2021 interpretation of Section 1557 of the Affordable Care Act, in response to executive orders and directives aimed at deregulating the executive branch. 90 Fed. Reg. 20393 (May 14, 2025); Presidential Executive Actions Tracker.
- Health and Welfare Plans. In a 6-3 decision, U.S. Supreme Court upholds the U.S. Preventive Services Task Force continuing to determine which services will be available free of cost (as preventive care) to individuals covered by the Affordable Care Act. Kennedy v. Braidwood Mgmt., Inc., 2025 U.S. LEXIS 2499 (June 27, 2025).
- Health and Welfare Plans. S. District Court for the Northern District of Texas vacates the 2024 HIPAA Privacy Rule amendments that had been designed to enhance privacy protections for reproductive health information. Purl v. United States HHS, 2025 U.S. Dist. LEXIS 116234 (N.D. Tex. June 18, 2025).
- Document alerts allow you to stay current on legal developments that affect your practice. Find out how to set up your document alerts.
- Review the Chevron Reversal Impact Resource Kit for analysis related to the Supreme Court’s decision to overturn four decades of deference to federal agency interpretations of ambiguous statutes.
- What’s New in Practical Guidance
Discover the newest Practical Guidance content and resources in this update. This guide is designed to help you find the tools and insights you need to work more efficiently and effectively. - Keep current on Trump administration developments by referencing the Presidential Executive Actions Tracker, Legal Challenges to 2025 Presidential Executive Orders and Actions Tracker, Executive Orders, EEOC Letters, and Other Actions Concerning Law Firms Tracker, and Trump Transition Resource Kit.
- Generative Artificial Intelligence (AI) Resource Kit is a frequently updated collection of current Practical Guidance materials on generative AI, ChatGPT, and similar tools.
- New! Practical Guidance Journal, 2025 Second Edition features guidance for regulating AI in the workplace in 2025, Intellectual Property issues related to deepfakes, the emergence of AI in mergers and acquisitions, and a checklist to help when evaluating AI technology risks.
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- Legal Developments provide the latest updates and analyses of emerging topics impacting your practice area. Visit the Legal Developments page to see the latest topics, which also include breaking legal news and related Practical Guidance content.
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