Erek M. Sharp
The U.S. Department of Health and Human Services ("HHS") announced on June 29, 2010 that it will begin accepting applications to participate in the Early Retiree Reinsurance Program established under the Patient Protection and Affordable Care Act ("PPACA"). In connection with this announcement, the agency has posted on its website the "official" versions of both the Early Retiree Reinsurance Program application and instructions, and the address to which completed applications should be sent. In addition, HHS posted a document entitled "Application Submission Do’s and Don’ts" which provides practical information that plan sponsors should read prior to submitting completed applications for certification. Of particular note, plan sponsors are required to use the new, "official" application (which does contain a few changes from the draft application) and applications must be submitted in hard copy. Applications that deviate from the "official" application format will not be accepted. Finally, late in the day, HHS also posted an updated list of
FAQs which provides new information that should be reviewed prior to submitting an application.
Please note that although HHS did not provide a deadline by which applications must be received, the agency has indicated that applications will be accepted on a "first come, first served" basis.
The documents described above can be accessed on the HHS, Office of Consumer Information and Insurance Oversight (OCIIO) website: http://www.hhs.gov/ociio/regulations/index.html