On June 24, 2011, the Department of Health and Human Services (HHS), the Internal Revenue Service, and the Employee Benefits Security Administration published an amendment to their July 23, 2010 interim final rule on internal claims and appeals and external review processes for group health plans and health insurance coverage in the group and individual markets under the Affordable Care Act (ACA).  The amendment is intended to provide additional flexibility to states in implementing ACA consumer protections. Among other things, the revised rules extend the transition period for state external review processes to January 1, 2012, and provide additional guidance for plans and issuers regarding temporary external review requirements. The amendment is effective July 22, 2011, although the agencies will accept comments on the amendment until July 25, 2011. Separate technical guidance has been issued by the Departments that addresses both state- and federally-administered external review processes and update model notices issued in connection with the July 2010 regulations.  HHS also has issued separate guidance outlining how a state may operate until January 1, 2014 an external review process under federal standards similar to the required consumer protections in the July 23, 2010 rule.