Wednesday, November 3, 2010

Early Retiree Reinsurance Program Chugging Along

Despite the well-publicized discontent with health reform among employers, those few companies that continue to sponsor pre-65 retiree health care plans have moved quickly to cash in on the Early Retiree Reinsurance Program established by the Patient Protection and Affordable Care Act.

The Department of Health and Human Services (HHS) on October 28 released a list of additional employers and unions accepted into the EERP. Nearly 700 additional large and small businesses, state and local governments, educational institutions, nonprofit organizations, and unions have been accepted into the program i the last month, which reimburses employers for a portion of the cost of health benefits for early retirees' and their families. This brings the total number of organizations participating in the program to nearly 3,600 (click here for earlier accounts of ERRP’s popularity).

In 2009, only 28% of all employers with 500 or more employees even offered retiree health care to pre-65 retirees, so the numbers in the program are even more impressive.

A total of $5 billion has been allocated to ERRP, and when that money is exhausted, so is ERRP.  A complete list of approved applicants and other information is available here.

In addition, HHS has just published a revised application for the ERRP, along with corresponding revised instructions for completing the application. HHS also published a revised "Dos and Don'ts" document for completing and submitting the revised application.

HHS notes the following for those who already have completed an application, those who are in the process of completion, and those who will not finish until after November 9:

  • Sponsors that have already submitted an application, using a version that was appropriate as of the date of submission, should not submit another application for the plan referenced in that submitted application.

  • Sponsors that have started to complete the most recent prior version of the application that had been posted on the ERRP website on Aug. 9, 2010 (see News, Aug. 12, 2010, HHS Provides Relief For Incomplete Applications To The Early Retiree Reinsurance Program), but have not yet submitted the application, may submit that version of the application if postmarked by Tuesday, Nov. 9, 2010. A sponsor completing that version of the application should also use the most recent prior versions of the application instructions (posted August 24, 2010) and "Dos and Don'ts" (posted August 9, 2010). Sponsors can contact HHS' ERRP Center if they need copies of those two documents.

  • Sponsors submitting an application postmarked after Tuesday, November 9, 2010, must use the revised versions of the application, application instructions, and "Dos and Don'ts", all of which were posted on November 2, 2010.

The revised application, application instructions, and "Dos and Don'ts" are posted on the How to Apply for the Program page on the ERRP website.

For a comprehensive analysis of the Patient Protection and Affordable Care Act, including the full text of the law and additional information on health reform and other recent developments in employee benefits, just click here.

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