Early Retiree Reimbursement Program

The Affordable Care Act (ACA) launched a new initiative, the Early Retiree Reinsurance Program. ERRP provides $5 billion in financial assistance to employers, unions and state and local governments to help them maintain coverage for early retirees age 55 and older who are not yet eligible for Medicare. The program started in June 2010 and was slated to continue until January 1, 2014 when early retirees will be able to choose from the additional coverage options that will be available in the health insurance exchanges or until the funds for the program are depleted. Due to depletion of funds, the program was closed to new applicants on May 5, 2011 and ceased reimbursement of claims incurred after December 31, 2011.

Government Sources
 Analysis

Government Resources

Website for the Early Retiree Reinsurance Program (ERRP)  

HHS released a notice to establish a timeframe by which plan sponsors participating in the Early Retiree Reinsurance Program (ERRP) are expected to use ERRP reimbursement funds. Sponsors are expected to use such funds as soon as possible, but not later than December 31, 2014. This notice is effective March 16, 2012. 3/21/12 (New) 

Update on ERRP Payment Processing, 2/17/12

Early Retiree Reinsurance Program: Program Status Update, February 2012, 2/17/12 

Based on the projected availability of funding, the U.S. Centers for Medicare & Medicaid (CMS) have released a notice announcing that they will cease reimbursement of claims for the Early Retiree Reinsurance Program (ERRP) that are incurred after December 31, 2011. 12/13/11  

Press Release: Update on ERRP Payment Processing and Announcement of End Date for Newly Incurred Claims, CMS, 12/9/11  

The HHS released a notice concerning its intent to conduct a survey of the Early Retiree Reinsurance Program. The survey will ask plan sponsors that have received ERRP funds about the program, including how and when plan sponsors have used, or intend to use, ERRP funds. 11/16/11  

Explanation of the Processes for Reporting Early Retiree and Claims Data Inaccuracies, and for Reopening, 10/3/11  

Explanation of the Appeals Process for the Early Retiree Reinsurance Program, 10/3/11

ERRP Claim List Response File Functionality Now Available, 10/1/11  

Private Health Insurance: Implementation of the Early Retiree Reinsurance Program, Governmental Accountability Office (GAO), 9/30/11

The Centers for Medicare & Medicaid Services (CMS) is announcing changes that will improve and streamline the process of submitting claims data for ERRP reimbursement requests. A new, fully-automated review system will give detailed feedback on Claims Lists, helping plan sponsors submit error free Claim Lists starting October 3, 2011. CMS is also introducing new flexibility in the permitted layouts for Claims Lists, and CMS has extended the deadline for submitting detailed Claims Lists for prior reimbursements. 9/12/11  

Guidance on Complying with the Prohibition on Using Early Retiree Reinsurance Program Reimbursements as General Revenue, CMS, 7/20/11    

New program guidance has been released concerning the allocation of post-point of sale negotiated price concessions to individual retirees uner the ERRP program.

The Centers for Medicare & Medicaid Services (CMS) has posted the ERRP Reimbursement Training: Claim List Online Training Module. Starting April 2011, plan sponsors will be required to submit Claim Lists in order to request reimbursement. 4/1/11  

The CMS released a report announcing that the Early Retiree Reinsurance Program (ERRP) has provided more than 1,300 employers across all 50 states with nearly $1.8 billion in reimbursements. CMS also announced that, due to the overwhelming response, the ERRP program will no longer be accepting applications after May 5, 2011, consistent with the law’s guidance based on the availability of funding. 

 
Impending Exhaustion of Funding for Early Retiree Reinsurance Program, House Energy and Commerce, 3/23/11  

HHS has announced that Plan Sponsors with an approved application are now able to Report Costs and Request Reimbursement in the Early Retiree Reinsurance Program (ERRP) Secure Website (SWS). Plan Sponsors must report costs before requesting reimbursement. 10/23/10

HHS has announced an additional 1,000 applicants accepted into the Early Retiree Insurance Program. These applicants are in addition to the 2,000 applicants accepted in August. HHS has provided a full alphabetical list of participants and an interactive map displaying participants by state online. Going forward, this list will be updated every Friday. 10/4/2010

HHS has issued more guidance clarifying which claims are eligible for reimbursement under the ERRP. 

  
HHS issued additional information on how to identify early retirees on September 24, 2010.

On September 17, 2010, HHS released new guidance on two key ERRP reimbursement preparation steps including accessing the ERRP Secure Website system and identifying the source(s) that will send the early retiree data required to receive ERRP reimbursements.    

Also, the HHS has announced the creation of a new Web site that brings together all the relevant information on the Early Retiree Reinsurance Program.

The HHS Office of Consumer Information and Insurance Oversight (OCIIO), announced that applications will be accepted starting June 29, 2010. Also, the OCIIO has posted the official version of the application and its instructions.  

HHS published an interim final rule with comment period that implements the Early Retiree Reinsurance Program. Congress appropriated funding of $5 billion for the temporary program. The program is scheduled to begin in June 2010 and ends no later than January 1, 2014. It provides reimbursement to participating employment-based plans for a portion of the cost of health benefits for early retirees and their spouses, surviving spouses and dependents. 5/4/10 

Analysis