Guest Article

(From the September 7, 2010 issue of Deloitte's Washington Bulletin, a periodic update of legal and regulatory developments relating to Employee Benefits.)

ERRP Update: DHHS Announces Approved Applicants and Secure Web Site

As applications to participate in the Early Retiree Reinsurance Program (ERRP) continue to be submitted and reviewed, the Department of Health and Human Services (DHHS) announced that nearly 2,000 applicants have been approved so far. According to the DHHS, the approved applicants will be able to submit claims starting sometime in September and will begin to receive reinsurance payments on those claims starting in October. A separate secure Web site was established to facilitate the ERRP.

The ERRP is a temporary program created by the Patient Protection and Affordable Care Act under which participating health plan sponsors can obtain reimbursement of a portion of their early retiree health benefit costs for claims that are incurred on and after June 1, 2010. The reimbursements must generally be used to provide premium or other health care cost relief to plan participants. The ERRP is set to expire with the opening of the Exchanges on January 1, 2014, although it will expire before then if its allotted $5 billion in funding is exhausted.

Approved Applicants

On August 31, 2010 the DHHS released an Announcement and List of nearly 2,000 applicants who were approved in the first round of applications that were submitted to participate in the ERRP. It reported that applications were received from more than 50 percent of the Fortune 500 companies, all the major unions, and government entities in all the states. The DHHS is continuing to accept and review applications to participate in the program. It reports that approved applicants will be able to submit eligible claims (going back to June 1, 2010) beginning in September 2010, and will receive reinsurance payments for those claims from the ERRP beginning in October 2010. The Announcement and List may be found at: http://www.healthcare.gov/.

New Secure Web site

A new secure web site was opened for the ERRP at http://errp.gov. The account manager and authorized representative of plans approved to participate in the ERRP will receive an email from the site inviting them to register. Via the site they will be able to view and change certain application information, designate the persons who are responsible for submitting information on behalf of the sponsor, submit data, and make reimbursement requests.

The information in this Washington Bulletin is general in nature only and not intended to provide advice or guidance for specific situations. If you have any questions or need additional information about articles appearing in this or previous versions of Washington Bulletin, please contact: Robert Davis 202.879.3094, Elizabeth Drigotas 202.879.4985, Mary Jones 202.378.5067, Stephen LaGarde 202.879-5608, Bart Massey 202.220.2104, Tom Pevarnik 202.879.5314, Sandra Rolitsky 202.220.2025, Deborah Walker 202.879.4955. Copyright 2010, Deloitte.