Benefits Law Update

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HHS Launches New Early Retiree Reinsurance Program Website, Publishes List of Applicants Approved Thus Far

HHS has launched a new ERRP website, http://errp.gov. This new website appears to be central source of information about ERRP, but perhaps more importantly it will be the mechanism through which approved applicants will submit reimbursement requests.

A plan sponsor whose application has been approved will be able to use the new site's secure area to view and change application information, submit claims, and request reimbursement, among other things. Once an application has been approved the Account Manager and Authorized Representative indicated on the application will receive a registration e-mail and instructions from HHS. HHS will begin accepting claims in this month and expects to deposit first reimbursements for approved applicants in October.

HHS has apparently been busy approving ERRP applicants. Another new website announces that HHS has approved a first round of nearly 2,000 applications. The approved applicants are all listed, by state and in a single list. This large number of initial approvals suggests that ERRP funds will be spread widely but thinly and will be exhausted far in advance of ERRP's 2014 end date.

As we mentioned in earlier posts, here and here, HHS is reviewing applications in the order received and reimbursements will be made on a first-come first-served basis. HHS has made clear that they are continuing to review applications, so if your employer applied to participate in ERRP and has not yet heard from HHS it may be that its application is somewhere in the queue awaiting review. This also means that your employer still has time to submit an ERRP application if it has not already done so (and it should, as discussed in this previous post). Once approved, it will be important for employers to submit reimbursement requests as soon as possible.

Topics: Health and Welfare Plans