On March 25, 2011, HHS issued new ERRP guidance regarding claims list submissions. ERRP, established by PPACA, provides reimbursement to participating employment-based health plans for a portion of the costs of health benefits for early retirees and their spouses, surviving spouses, and dependents. The new guidance notifies plans that, beginning in April 2011, the plans will be required to submit a “Claims List” with each reimbursement request. The Claims List will be a cumulative list of all health benefit items or services for which the plan is requesting reimbursement for that plan year. Prior guidance indicated that plans would eventually have to submit detailed claims data in addition to the summary cost data for each reimbursement request.

Plans will submit the Claims List in the same manner as the Early Retiree Lists, either by uploading the Claims List to the ERRP Secure Website or through its mainframe. All Claims Lists greater than or equal to 100 MB in size (which HHS states is a Claims List with approximately 249,000 claim service lines) must be submitted through the mainframe because of upload limitations. Those plans that believe their Claims Lists will reach the size threshold and that do not already use the mainframe system to submit Early Retiree Lists should contact the ERRP Center as soon as possible to begin the mainframe set-up process, as it can take a significant amount of time.