Wednesday, August 11, 2010

HHS Provides Help For Difficulties In Applying To The Early Retiree Reinsurance Program

The Department of Health and Human Services Plan has provided additional guidance regarding the application the Early Retiree Reinsurance Program (ERRP) to help the sponsors who submitted incorrect or incomplete applications.

In late June, HHS began accepting applications to the program. HHS now has provided three methods of correcting problems:

First, HHS notes in an update to its ERRP information that some plan sponsors may have submitted their Early Retiree Reinsurance Program applications on the official form, but before having had the chance to review the version of the Frequently Asked Questions (FAQs) document that was published on June 29, 2010.

Such sponsors should not submit another application. HHS is developing a process to identify applications that may include an incorrect or incomplete response as a result of the sponsor not having access to the additional FAQs that were posted on June 29, 2010. When such responses are identified, HHS will give sponsors a chance to submit additional information as an attachment to support the original application. The sponsor’s account manager will be contacted via telephone or email in these situations. Sponsors that may have already submitted a second application, after the June 29 FAQs were published, should not contact HHS. HHS is developing a process to respond to those situations.

Second, certain applicants were having difficulty with the on-line application that was posted early the morning of June 29, 2010. A revised copy of the application has been posted that accommodates the entering of numeric sequences that start with zeros in fields requiring numbers (e.g., EIN, phone numbers, etc.). If an applicant had this problem with the early version of the application, HHS will accept what was submitted and contact the sponsor if necessary to ascertain the correct data before making an application determination. Applicants who had completed and submitted the early version of the application but who did not experience a problem entering zeros, do not need to re-complete their application form.

Third, there has been some confusion about how applications should be submitted. Applications should be submitted through the U.S. Postal Service. However, if a sponsor submitted its application in another manner, the application will be accepted for processing, provided the application is otherwise acceptable for processing. However, for operational reasons, HHS prefers sponsors to use the United States Postal Service. If an applicant submitted an application via a carrier other than the United States Postal Service, and it was accepted at the address listed on the official application, do not re-submit the application. Sponsors that may have already submitted a second application, should not contact HHS. HHS is developing a process to respond to such situations.

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


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