CMS Reminds Plan Sponsors Of Responsibilities During ERRP Website Shutdown

As announced in the April 23, 2013, Federal Register, in preparation for the Jan. 1, 2014, Early Retiree Reimbursement Program (ERRP) sunset date, the Centers for Medicare and Medicaid Services (CMS) is phasing down the ERRP secure website, so that it can be taken offline the first week of January 2014. Accordingly, the CMS has issued a release reminding authorized representatives, account managers, and designees supporting plan sponsors that they will not be able to access the ERRP website on or after Jan. 1, 2014. The CMS is encouraging plan sponsors to review information available on the website to determine what, if any, information or data should be printed and/or saved before the system is taken offline.

The Patient Protection and Affordable Care Act (ACA) established the ERRP, a temporary reinsurance program to reimburse part of the claims costs for participating employment-based plans that provide health insurance coverage for early retirees ages 55 through 64, and their eligible spouses, surviving spouses, and dependents.

In the release, the CMS also noted that it is important that each participating plan sponsor continue to provide CMS with up-to-date information regarding its organization and key contacts. However, after Dec. 31, 2013, plan sponsors will no longer be required to update information, unless they are the subject of an active audit.

Despite the termination of the ERRP website, the CMS noted that plan sponsors are required to maintain, and furnish to the Department of Health and Human Services upon request, certain ERRP-related records. These records must be maintained for six years after the expiration of the plan year in which the costs were incurred, or longer if otherwise required by law.

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