"A plan sponsor must continue to satisfy the 'maintenance of contribution' requirement as long as it retains ERRP funds. It is therefore important that a plan sponsor document the use of ERRP funds as soon as practical.... "It is important that plan sponsors who received ERRP reimbursements correct in a timely manner any data inaccuracies in pending payment requests that were for the same plan year. Data inaccuracies include prescription drug rebates that were estimated in an initial submission, but later were finalized.

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