As many plan sponsors are aware, the Centers for Medicare and Medicaid Services (CMS) is beginning the process of closing its Early Retiree Reinsurance Program (ERRP). In anticipation of the ERRP’s termination, CMS recently issued a notice (CMS-9996-N4) that establishes a number of important deadlines for plan sponsors who participate in the program. The notice, effective as of April 19, 2013, sets forth the impact that the January 1, 2014 sunset date of the ERRP will have on five of the program’s key operational processes.

Background on the ERRP

Congress established the ERRP in 2010 as part of the Affordable Care Act (ACA) with the aim of assisting employers in continuing to provide early retirees with health coverage. The program provides financial support to plan sponsors offering coverage to the difficult to insure population of early retirees over the age of 55 who are not yet eligible for Medicare. Under the ERRP, participating employers are reimbursed for certain expenses related to health coverage for this population until January 1, 2014 when such early retirees become eligible to acquire individual coverage through the ACA’s health exchanges. The program – closed to enrollment in 2011 – includes over 5,000 plan sponsors who are eligible to receive reimbursement for the costs of early retiree health coverage.

Key Deadlines in the Notice

The notice provides ERRP participants with guidance related to the January 1, 2014 closing of the program. The following table details the five key deadlines set forth in the notice.

Click here to view table.

Summary

The CMS notice sets forth a number of important deadlines that CMS is implementing in conjunction with the termination of the ERRP. It is advisable that plan sponsors remain aware of these deadlines in preparing for the ERRP’s January 1, 2014 sunset date.