As previously discussed, since June 29, 2010, the Department of Health and Human Services (HHS) has been accepting applications for plan certification under the Early Retiree Reinsurance Program (ERRP). However, last week, HHS announced that it will no longer accept new ERRP applications from plan sponsors after May 5, 2011, due to the limited availability of funding.
HHS noted that its decision is based on the actual availability of remaining appropriated ERRP funds and the rate at which it has been disbursing reimbursements, as opposed to the projected amounts of ERRP reimbursements that applicants listed in their ERRP applications. Furthermore, HHS reserved the right to resume accepting applications should circumstances related to the availability of ERRP funding change.
This means that any plan sponsors interested in participating in ERRP who have not yet applied for plan certification should do so as soon as possible. In the Notice, HHS clarified that merely postmarking an application before May 5 will not be sufficient and promised to post additional information at the ERRP website.