On May 6, 2010, McDermott Will & Emery reported on the Patient Protection and Affordable Care Act’s new Early Retiree Reinsurance Program (the Program) interim final regulations. The Program went into effect on June 1, 2010. A prerequisite for participation in the Program is for a plan sponsor to submit a timely application for certification to the Secretary, or the Secretary’s designee.
On June 1, 2010, a draft application and set of instructions for the Program was posted to the website of the Office of Management and Budget. A final application will be available at a later date in June, prior to the date on which the U.S. Department of Health and Human Services (HHS) will begin accepting applications, and will be posted on the HHS Office of Consumer Information and Insurance Oversight’s website. McDermott will keep you informed when this final application is posted.
In the meantime, if you have any written comments on the interim final regulations, the Firm can forward your input to HHS on an anonymous basis. The comment deadline is June 4, 2010.
If you have any questions or would like additional information, please contact your regular McDermott lawyer or either of the contacts on the right.
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