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

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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Health Reform Provisions

Employers providing health coverage to early retirees should be aware of the new retiree reinsurance program under health care reform that goes into effect June 1, 2010.  Recent guidance issued by the U.S. Department of Health and Human Services specifies the qualifications for eligibility, the steps plan sponsors must take in the application process and the requirements for reimbursement.  The program is scheduled to begin on June 1, 2010, and will end on January 1, 2014, or until the $5 billion in funding allocated to the program is exhausted.

Eligibility to participate in the program is not automatic.  A plan sponsor is eligible to participate in the program if the plan sponsor submits a timely application for certification to the secretary, or the secretary’s designee, containing the necessary information.  Applications will be processed in the order received. Incomplete applications will be returned, and any revised applications will be processed based on the date the revised submission is received, not based on the date of the original, returned submission.  Due to the limited duration and budget for this program, it is important for plan sponsors interested in the program to become certified as quickly as possible.

Your Next Moves

Employers providing health coverage to early retirees should analyze their current benefit plan design and cost structure to determine whether they will apply to the program. 

Click here to view the full article.

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