Plans that participate in the Early Retiree Reinsurance Program (ERRP) that requested reimbursement before April 2011 and that have subsequently received reimbursement, must submit an error-free claims list with a reimbursement request before December 31, 2011, substantiating the amount that was reimbursed. If a plan fails to submit the claims list, the Department of Health and Human Services (HHS) will consider the previously reimbursed amount to be unsubstantiated and will initiate the process to recoup that money from the plan.