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Early Retiree Reinsurance Program
The purpose of the reimbursement is to make health benefits more affordable for plan participants
The Department of Health and Human Services is the Federal government's principal agency for protecting the health of all Americans and providing essential human services, especially to those who are least able to help themselves.
Program Accomplishments
Not Applicable.
Uses and Use Restrictions
ERRP regulation specifies that the sponsor must use the proceeds under this program only for the following purposes: (1) To reduce the sponsor s health benefit premiums or health benefit costs, or (2) To reduce health benefit premium contributions, copayments, deductibles, coinsurance, or other out-of-pocket costs, or any combination of these costs, for plan participants, or (3) To reduce any combination of the costs in (1) and (2) Proceeds under this program must not be used as general revenue for the sponsor.
(See the ERRP regulation at 45 C.F.R.
§149.200).
The restrictions include using the funds in a manner other than as follows: (1) To reduce the sponsor s health benefit premiums or health benefit costs, or (2) To reduce health benefit premium contributions, copayments, deductibles, coinsurance, or other out-of-pocket costs, or any combination of these costs, for plan participants, or (3) To reduce any combination of the costs in (1) and (2) Proceeds under this program must not be used as general revenue for the sponsor.
(See the ERRP regulation at 45 C.F.R.
§149.200).
Eligibility Requirements
Applicant Eligibility
In order to be eligible for the ERRP, a plan sponsor must complete and submit an ERRP application to the ERRP Center on or before May 5, 2011.
In summary, the plan sponsor must be an organization that provides health benefits to Early Retirees, have programs and procedures in place that generate cost savings with respect to participants with chronic and high-cost conditions, use eimbursements appropriately, ensure that policies and procedures are in place to protect against fraud, waste and abuse under ERRP, and agree to the Plan Sponsor Agreement included in the ERRP application.
The application will be reviewed and either approved or not approved for acceptance in to the program.
Beneficiary Eligibility
In order to be eligible to receive reimbursements under the ERRP, a plan sponsor must complete and submit an ERRP application to the ERRP Center on or before May 5, 2011. If approved, both the sponsor, and early retirees and their spouses, surviving spouses and their dependents are direct or indirect beneficiaries of the program. In summary, the sponsor must be an organization that provides health benefits to Early Retirees, have programs and procedures in place that generate (or have the potential to generate) cost savings with respect to participants with chronic and high-cost conditions, use reimbursements appropriately, ensure that policies and procedures are in place to protect against fraud, waste and abuse under ERRP, and agree to the Plan Sponsor Agreement included in the ERRP application. The application will be reviewed and either approved or not approved for acceptance in to the program.
Credentials/Documentation
A sponsor must submit an application for the program to the ERRP Center on or before May 5, 2011. After approval into the program, a sponsor must provide the ERRP Center with a list of the Early Retirees and the cost and claims data for which it is requesting in reimbursement. This program is excluded from coverage under OMB Circular No. A-87.
Aplication and Award Process
Preapplication Coordination
Preapplication coordination is not applicable.
Environmental impact information is not required for this program.
This program is excluded from coverage under E.O.
12372.
Application Procedures
This program is excluded from coverage under OMB Circular No. A-102. This program is excluded from coverage under OMB Circular No. A-110.
Award Procedures
Sponsors must complete and submit an application to the ERRP Center on or before May 5, 2011. The application must be approved. An Account Manager and Authorized Representative must then successfully register in the ERRP secure website. Once registration is complete, a sponsor must provide its banking information in the secure website. A sponsor must then provide a list of the Early Retirees and the cost and claims data supporting its reimbursement request. The Authorized Representative is also required to affirm that the sponsor is complying with the program rules. After completing these steps, a sponsor may then actually submit a reimbursement request. The ERRP Center will make a determination of whether the reimbursement is approved or denied. If approved, the reimbursement will be deposited in the bank account chosen by the sponsor. Sponsors may request reimbursement one time, each calendar year quarter, for each plan year.
Deadlines
May 05, 2011 The ERRP program started accepting applications June 30, 2010 and the program ends January 1, 2014, or when there are no more funds available for disbursement. Sponsors wishing to apply to the ERRP must submit an application to the ERRP Center on or before May 5, 2011.
Authorization
Patient Protection and Affordability Act, Section 1102.
Range of Approval/Disapproval Time
From 1 to 15 days. Applications are generally processed within 2 weeks. If additional information is required, then the ERRP Center will send communication to the sponsor.
Appeals
Sponsors may not appeal an application determination, but may appeal an adverse reimbursement determination.
Renewals
Not Applicable.
Assistance Considerations
Formula and Matching Requirements
Statutory Formula: Title Patient Protection and Affordability Care Act, Part 1102, Subpart c. The statute at section 1102(c) of the Affordable Care Act requires the Secretary, upon receipt of a valid claim for health benefits, to make reimbursement in an amount of 80 percent of the portion of the health benefit costs (net of negotiated price concessions) attributable to the claims that exceed $15,000, but are below $90,000, during a plan year for a given early retiree or early retiree s spouse, surviving spouse, or dependent. The payment thresholds may be adjusted in the future, based on changes in the medical care component of the Consumer Price Index.
Matching Requirements: This program has maintenance of contribution requirements, to ensure that the prohibition against using ERRP funds as general revenue, is complied with. A sponsor may demonstrate that it is maintaining its level of contribution in a number of ways: using aggregate spending trends, per-capita spending trends, or other methods subject to Secretarial approval. These options are set forth in a publicly posted Common Question.
MOE requirements are not applicable to this program.
Length and Time Phasing of Assistance
The reimbursement will be available until January 01, 2014 or until the program no longer has funds available for disbursement. ERRP reimbursement may be requested once per calendar year quarter per each plan year. See the following for information on how assistance is awarded/released: After (1) the Account Manager and Authorized Representative successfully register via the ERRP secure website; (2) the sponsor provides banking information in the website; and (3) the sponsor provides a list of Early Retirees and the cost and claims data supporting reimbursement requests, the sponsor may submit a reimbursement request (after the authorized representative also affirms sponsor is complying with program rules). The ERRP Center will make a determination of whether the reimbursement is approved or denied. If approved, the reimbursement will be deposited in the bank account chosen by the sponsor. Sponsors may request reimbursement one time, each calendar year quarter, for each plan year.
Post Assistance Requirements
Reports
No reports are required.
Audits
This program is excluded from coverage under OMB Circular No. A-133. Audits of sponsors will be conducted to ensure sponsors are in compliance with ERRP requirements.
Records
The ERRP does not require specific progress, expenditure, cash reports, or performance monitoring at set intervals. However, the sponsors must comply with record maintenance requirements and provide records upon request in connection with audit or other ERRP integrity related activities. The Sponsors must maintain records for 6 years after the expiration of the plan year in which the costs were incurred, or longer if otherwise required by law. The records that must be retained are as follows- (1) All documentation, data, and other information related to the regulations, and (2) Any other records specified by the Secretary. The Secretary may issue additional guidance addressing ecordkeeping requirements, including (but not limited to) the use of electronic media. The sponsor must require its health insurance issuer or employment based plan, as applicable, to maintain and produce records upon request.
Financial Information
Account Identification
75-0114-0-1-551.
Obigations
(Direct Payments for Specified Use) FY 12 $1,930,747,000; FY 13 est $116,000,000; and FY 14 est $0 - There is appropriated to the Secretary, out of any moneys in the Treasury not otherwise appropriated, $5,000,000,000 to carry out the program under this section. Such funds shall be available without fiscal year limitation. Program ends January 1, 2014, or when there are no more funds available for disbursement.
Range and Average of Financial Assistance
Smallest: $165.58; Largest: $64,993,651.44; Average: $1,446,135.05 (All data as of 1/9/11).
Regulations, Guidelines, and Literature
Regulations are available at 45 CFR Part 149. Guidance, Common Questions, and additional literature is posted on the ERRP website: www.errp.gov.
Information Contacts
Regional or Local Office
None.
Headquarters Office
Michelle Feagins 200 Independence Avenue, SW
, Washington, District of Columbia 20201. Email: michelle.feagins@hhs.gov Phone: 301-492-4312.
Criteria for Selecting Proposals
Not Applicable.
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