As we discussed in a prior Alert (published on May 19, 2010), the Department of Health and Human Services (HHS) recently issued interim final regulations implementing the Early Retiree Reinsurance Program, as established under the Patient Protection and Affordable Care Act (PPACA). This week, a draft application for certification to participate in this program, and accompanying instructions, were posted to the website of the Office of Management and Budget (OMB). Please note that the application and instructions are in draft form only, but are helpful in terms of illustrating what information may be requested. HHS officials have indicated that a final application for certification will be available sometime this month and will be posted on the HHS Office of Consumer Information and Insurance Oversight's (OCIIO) website.  

The draft application and instructions can be accessed at the following web address: 012