On September 21st, the U.S. Department of Labor (the “Department”) issued a series of questions and answers(Q&As) clarifying a handful of issues arising under the Affordable Care Act.1 Topics covered includegrandfathered plans, internal and external claims procedures, dependent coverage, out-of-network emergency services, and what constitutes a “highly compensated employee” for purposes of the Act’s insurance non-discrimination rules. In the first of these Q&As, the Department endeavored to establish that the Departments of Treasury, Labor, and Health and Human Services are taking a collaborative approach to enforcement, asserting that the agencies are:

“working together with employers, issuers, States, providers and other stakeholders to help them come into compliance with the new law and are working with families and individuals to help them understand the new law and benefit from it, as intended.”