# Agency Information Collection Activities; Comment on Affordable Care Act Internal Claims and Appeals and External Review Disclosures
**AGENCY:**
Internal Revenue Service (IRS), Treasury.
**ACTION:**
Notice and request for comments.
**SUMMARY:**
In accordance with the Paperwork Reduction Act of 1995, the IRS is inviting comments on the information collection request outlined in this notice.
**DATES:**
Written comments should be received on or before May 4, 2026 to be assured of consideration.
**ADDRESSES:**
Direct all written comments to Andres Garcia, Internal Revenue Service, Room 6526, 1111 Constitution Avenue, Washington, DC 20224, or by email to *[email protected].* Include “OMB Number: 1545-2182” in the subject line of the message.
**FOR FURTHER INFORMATION CONTACT:**
Requests for additional information or copies of this collection should be directed to LaNita Van Dyke, at (202) 317-6009.
**SUPPLEMENTARY INFORMATION:**
The IRS, in accordance with the Paperwork Reduction Act of 1995 (PRA) (44 U.S.C. 3506(c)(2)(A)), provides the general public and Federal agencies with an opportunity to comment on proposed, revised, and continuing collections of information. This helps the IRS assess the impact and minimize the burden of its information collection requirements. Comments submitted in response to this notice will be summarized and/or included in the request for OMB approval. All comments will become a matter of public record, and viewable on relevant websites. For this reason, please do not include in your comments information of a confidential nature, such as sensitive personal information. Comments are invited on: (a) Whether the collection of information is necessary for the proper performance of the functions of the agency, including whether the information shall have practical utility; (b) the accuracy of the agency's estimate of the burden of the collection of information; (c) ways to enhance the quality, utility, and clarity of the information to be collected; (d) ways to minimize the burden of the collection of information on respondents, including through the use of automated collection techniques or other forms of information technology; and (e) estimates of capital or start-up costs and costs of operation, maintenance, and purchase of services to provide information
*Title:* Affordable Care Act Internal Claims and Appeals and External review Disclosures.
*OMB Number:* 1545-2182.
*Regulation Number:* T.D. 9494 and T.D. 9955.
*Abstract:* This collection of information request includes the information collection and third- party notice and disclosure requirements that a plan must satisfy under final regulations implementing provisions of the Affordable Care Act pertaining to internal claims and appeals, and the external review process. The No Surprise Act extends the balance billing protections related to external reviews to grandfathered plans. The definitions of group health plan and health insurance issuer that are cited in section 110 of the No Surprises Act include both grandfathered and non-grandfathered plans and coverage. Accordingly, the practical effect of section 110 of the No Surprises Act is that grandfathered health plans must provide external review for adverse benefit determinations involving benefits subject to these surprise billing protections. Grandfathered and non-grandfathered plans must provide claimants, free of charge, any new or additional evidence considered, relied upon, or generated by the plan or issuer in connection with the claim, and the requirement to comply either with a State external review process or a Federal review process. The disclosure requirements of the Federal external review process require (1) a preliminary review by plans of requests for external appeals; (2) Independent Review Organizations (IROs) to notify claimants of eligibility and acceptance for external review; (3) the plan or issuer to provide IROs with documentation and other information considered in making adverse benefit determination; (4) the IRO to forward to the plan or issuer any information submitted by the claimant; (5) plans to notify the claimant and IRO if it reverses its decision; (6) the IRO to notify the claimant and plan of the result of the final external appeal; (7) the IRO to maintain records for six years.
*Current Actions* : There is a change to the paperwork burden previously approved by OMB. Adjustments to the burden estimates result from updated estimates on the number of ERISA-covered plans and policyholders. These changes result in 713,149 fewer respondents, a decrease of 202,973 responses, a decline of the hour burden by 677 hours,
*Total Estimated Number of Respondents:* 1,294,150.
*Total Estimated Number of Responses:* 187,601.
*Total Estimated Annual Burden Hours:* 18,370 hours.
Approved: March 2, 2026.
LaNita Van Dyke,
Tax Analyst.