ERRP Operational Processes To Terminate July 31

In preparation for the Jan. 1, 2014 Early Retiree Reimbursement Program (ERRP) sunset date, the Centers for Medicare and Medicaid Services (CMS) will phase down the ERRP secure website so that it can be taken offline and archived in mid-2014. As part of the phase down, certain operational processes related to the ERRP secure website will be terminated prior to the sunset date.

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.

The last day plan sponsors will be able to submit an ERRP reimbursement request is July 31, 2013. The last day plan sponsors will be required to submit corrections to data inaccuracies is July 31, 2013, i.e., the last day plan sponsors may submit an ERRP reimbursement request. Submitting corrections to data inaccuracies is only required with respect to data inaccuracies that a sponsor knew or should have known of on or before April 30, 2013.

Although CMS set forth termination dates for processes that involve plan sponsors’ reporting and submitting of information in an April 23, 2013 Federal Register notice, plan sponsors are still required, as provided in the ERRP regulations, to maintain and furnish to the HHS Secretary upon request, certain records enumerated in those regulations. For example, ERRP plan sponsor audits are ongoing and audited plan sponsors will be required to supply documentation to the auditors to demonstrate compliance with the rules of program participation.

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