On August 26, 2010, the Internal Revenue Service, Employee Benefits Security Administration (EBSA), and the HHS Office of Consumer Information and Insurance Oversight published a notice announcing the availability of guidance detailing interim procedures for the federal external review process and model notices both for internal claims and appeals and for external review processes under the Patient Protection and Affordable Care (Affordable Care Act or ACA). Among other things, the guidance (EBSA Technical Release No. 2010-01) provides an interim enforcement safe harbor for non-grandfathered self-insured group health plans not subject to a state external review process, and therefore subject to the federal external review process.