On September 17, 2010, HHS posted additional guidance online encouraging plan sponsors with approved applications to begin taking the following steps to prepare for the ERRP reimbursement process.

Accessing the ERRP Secure Website. The guidance notes that one key preparation step is accessing the ERRP Secure Website (ERRP SWS). Authorized representatives and account managers with approved plan sponsor applications will receive e-mails from the ERRP Center with registration links to register with the ERRP SWS. Authorized representatives and account managers should register as soon as possible because the ERRP SWS will be the primary means of communication to the ERRP Center for reporting data and requesting reimbursement.

Early Retiree Lists. Plan sponsors should prepare early retiree lists. A plan sponsor will be required to submit an early retiree list to the ERRP Center before a reimbursement request can be submitted. On September 24, 2010, HHS posted additional guidance explaining that there are two primary considerations to determine if an early retiree's costs are eligible for reimbursement under the ERRP. First, the individual that the plan sponsor is claiming must be an early retiree, the determination of which is based on such things as age, plan participation, and employment status. Second, the early retiree or the early retiree╩╝s spouse, surviving spouse, or dependent(s) must have accumulated $15,000 or more in planreimbursed and/or self-paid claims that are eligible for credit towards the ERRP cost threshold or for ERRP reimbursement.

Cost Data. The guidance notes that to simplify cost data submissions for reimbursement, plan sponsors need only submit claims cost data initially at the plan level, not at the benefit option level or at the medical item or service level. However, plan sponsors must supplement any submitted summary cost data with corresponding claim-level data at a future date to be announced by the ERRP Center. Thus plan sponsors should identify resource(s) to assist with consolidation and reporting of such data if necessary. The ERRP Center will begin accepting eligible summary-level cost data in mid-October. Generally, only those items and services that Medicare would cover are eligible for reimbursement under ERRP. On September 28, 2010, the HHS ERRP Center also published new program guidance describing the types of medical items or services that are generally excluded from Medicare coverage. However, this guidance also describes how some of Medicare's specific limits do not apply in the ERRP.