Early Retiree Program Issues New Reminders and Tips

The Center for Consumer Information and Insurance Oversight (CCIIO) has published a series of reminders and tips regarding the Early Retiree Reimbursement Program (ERRP), which includes the following information for resolving the most common early retiree list questions:

Submitting the Early Retiree List

Including Eligible Records. When preparing an early retiree list, plan sponsors should ensure that the list includes only early retirees who meet or exceed the $15,000 cost threshold. In addition, plan sponsors should verify that each member record has a corresponding subscriber record, even if the subscriber is no longer eligible for reimbursement under the ERRP.

Adding Early Retirees. If a plan sponsor submits an early retiree list and then finds that additional early retirees need to be added to the list, it may do so by submitting another complete early retiree list. Each early retiree list submission is a full replacement of the previously submitted list.

Reviewing The Early Retiree List Response File

Using the Correct Response File. Each time a plan sponsor submits an early retiree list, the ERRP Center produces an early retiree list response file. If a plan sponsor submits multiple early retiree lists, it should ensure that the correct early retiree list response file is being used to research the data elements identified as errors in the corresponding early retiree list. Plan sponsors should consider saving each response file with a different name to keep multiple response files in order.

Understanding the Early Retiree List Response File Reason Codes. Reason codes are numerical codes that correspond to a specific message about a record in an early retiree list response file. Reason codes advise when an ERRP effective and/or termination date returned by the ERRP Center varies from the plan coverage dates originally submitted by the plan sponsor. The reason code will explain the ERRP effective and/or termination dates provided by the ERRP Center. ERRP coverage periods could be adjusted to a shortened coverage period, or no coverage period at all depending on the following scenarios:

• No ERRP coverage period; and
• The ERRP Center will return a reason code and no ERRP coverage period (zeroes in ERRP effective and termination dates) if one or more selected fields are invalid (e.g., last name, first name, eate of birth, coverage effective date, coverage termination date, member ID, member group ID, etc.).

Additionally, the ERRP Center will return a reason code and no ERRP coverage period (zeroes in ERRP effective and termination dates) if one or more of the following can not be confirmed in the ERRP SWS system: plan year start date, application number, ERL submission method, corresponding subscriber record, member ID, and member group ID combination.

Finally, the ERRP Center will return a reason code and a shortened ERRP coverage period (modified ERRP effective and termination dates—not zeroes) and a reason code as applicable, in the following scenarios:

• The plan coverage effective and/or termination dates submitted by the plan sponsor are outside the plan year.
• The subscriber is eligible for Medicare during some portion of or all of the plan sponsor submitted coverage period (this also could result in no ERRP coverage period).
• Subscriber is deceased (this also could result in no ERRP coverage period).
• Ineligible member coverage dates (this also could result in no ERRP coverage period).
• Adjusted subscriber coverage dates (this also could result in no ERRP coverage period).
• Adjusted spouse and/or dependent coverage dates (this also could result in no ERRP coverage period).

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