Health Care Reform Blog : Health Care Law Reform : McDermott Will & Emery Law Firm

Assemble your Early Retiree Reinsurance claims!  The U.S. Department of Health and Human Services (HHS) will hold an event on August 31 to release the list of 1,300 employers that have qualified for the Early Retiree Reinsurance Program under Section 1102 of the Patient Protection and Affordable Care Act.  Under the program, these entities, comprising both public and private employers, will be certified to file for reimbursement of early retiree health care expenses.  HHS has already begun sending formal notification today to the employers approved for the program.

• The notice includes a description of the electronic certifications the plan sponsor will have to make.
• The notice states that a notice to plan participants will be required, however form notices will be provided by the government in September.
• Reimbursement will only be made for claims that are Medicare eligible (guidance as to this will be released in September).
• Payments from the government are anticipated to begin in October.

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Today the Early Retiree Reinsurance Program (ERRP) Application was posted on the Health and Human Services (HHS) website.  Applications are being accepted as of today, June 29, 2010. The ERRP will stop accepting applications once it appears that the $5 billion appropriated for the program will be exhausted; therefore, it is imperative that employers interested in participating in the ERRP submit their application as soon as possible.  The link to the application and instructions are as follows:

http://www.hhs.gov/ociio/Documents/application.pdf

http://www.hhs.gov/ociio/Documents/application_instructions.pdf

In addition, HHS published some Dos and Don’ts with respect to your submission of the application, the link is as follows:

http://www.hhs.gov/ociio/Documents/errp_dos_donts.pdf

For more details, please click here. 

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On May 6, 2010, McDermott Will & Emery reported on the Patient Protection and Affordable Care Act’s new Early Retiree Reinsurance Program (the Program) interim final regulations.  The Program went into effect on June 1, 2010.  A prerequisite for participation in the Program is for a plan sponsor to submit a timely application for certification to the Secretary, or the Secretary’s designee. 

On June 1, 2010, a draft application and set of instructions for the Program was posted to the website of the Office of Management and Budget.  A final application will be available at a later date in June, prior to the date on which the U.S. Department of Health and Human Services (HHS) will begin accepting applications, and will be posted on the HHS Office of Consumer Information and Insurance Oversight’s website.  McDermott will keep you informed when this final application is posted.

In the meantime, if you have any written comments on the interim final regulations, the Firm can forward your input to HHS on an anonymous basis.  The comment deadline is June 4, 2010. 

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