The U.S. Department of Health and Human Services (HHS) recently released new guidance regarding the Early Retiree Reinsurance Program (ERRP) created by the Patient Protection and Affordable Care Act. Most notably:
Identifying Early Retirees and other Preparations for ERRP Reimbursement
The guidance encourages plan sponsors with approved ERRP applications to begin preparing for the ERRP reimbursement process.
Access the ERRP Secure Website: The ERRP Secure Website will serve as a plan sponsor’s primary method of reporting data to the ERRP Center and requesting reimbursement. HHS suggests authorized representatives and account managers associated with approved plan sponsor applications register on the Secure Website as soon as possible after receiving the registration email.
Identify Early Retirees: Before a reimbursement request can be submitted, plan sponsors must submit an early retiree list to the ERRP Center. Plan sponsors must (i) determine who in their plan(s) meets the ERRP criteria based on age, employment status, Medicare eligibility and claim experience; and (ii) complete the early retiree list setup in the ERRP Secure Website. The guidance contains early retiree eligibility information and instructions as to how to format and upload the lists.
Cost Data: Under the ERRP, plan sponsors will be required to submit claims cost data at the plan level. The guidance encourages plan sponsors to identify resources as necessary to assist with consolidation and reporting of the eligible summary cost data. The ERRP Center will begin accepting eligible cost data in mid-October.
Other Features Now Available: In addition to the registration and early retiree data features mentioned above, the guidance explains that plan sponsors may now assign and manage designees, update banking information and assign account manager reimbursement privileges via the ERRP Secure Website.
Claims Ineligible for Reimbursement
The ERRP Center published a document clarifying which claims are ineligible for reimbursement under the ERRP. This guidance lists specific items and services which are not covered by Medicare and will not be credited toward the cost threshold or reimbursed under ERRP. A detailed list of codes that correspond with each exclusion is expected to be published later this month on the ERRP website.