HHS Implements Early Retiree Reinsurance Program
The health care reform law, now generally referred to as the Affordable Care Act, established a program to provide claims reimbursement to group health plans providing coverage to early retirees. If your group health plan does not offer coverage to retirees, the program does not apply to you.
The Early Retiree Reinsurance Program provides $5 billion in temporary funding for the Secretary of Health and Human Services (HHS) to reimburse group health plans for claims paid to provide benefits to early retirees, their spouses or surviving spouses, and dependents. Generally, group health plans are eligible for an 80% reimbursement of claims paid between $15,000 and $90,000. The program began on June 1, 2010, and only claims paid for medical expenses incurred after June 1, 2010 will qualify for the reimbursement. The program is scheduled to expire in 2014, once the health benefit exchanges are open for business.
To file a request for reimbursement, employers and group health plans must submit an application for reimbursement to HHS. Over the weekend, the Secretary of HHS released her first “draft” of the Early Retiree Reinsurance Program application. You can get a copy of it here:
www.hhs.gov/ociio/Documents/application.pdf
HHS expects to make a “final” application available later this month after it has the administrative infrastructure in place to handle the claims submission process.
Over the weekend, HHS also released a fact sheet and other information about the program on the HHS website. The fact sheet can be found among the Early Retiree Reinsurance Program details here:
www.hhs.gov/ociio/regulations/#early_retiree
We’ll be sure to let you know as soon as the “final” program application form is available. Please contact your LMV attorney if you have questions about the Early Retiree Reinsurance Program or any other facet of the Affordable Care Act at (205) 326.3002.
Article courtesy of Worklaw Network firm Lehr, Middlebrooks & Vreeland, P.C. (www.lehrmiddlebrooks.com).

