Health Care Reform Advisory: HHS Issues "Early Retiree Reinsurance Program" Guidance

The Patient Protection and Affordable Care Act of 2010 together with the Healthcare and Education Reconciliation Act of 2010 (collectively, the “Act”) established the Early Retiree Reinsurance Program (the “Program”) for the purposes of subsidizing retiree medical benefits by reimbursing participating plan sponsors for the costs of providing group health plan coverage to early retirees. “Early retirees” consist of former employees age 55 and older who are not yet eligible for Medicare and who are not active employees of an employer maintaining or currently contributing to a plan, or of an employer that has made substantial contributions to fund a plan. The Program not only covers medical claims for early retirees, but also their eligible spouses, surviving spouses and dependents. Pursuant to the mandate of the Act, the Secretary of Health and Human Services (HHS) issued a regulation on the Program as of May 5, 2010. The Program is effective June 1, 2010 and terminates on January 1, 2014. If you provide applicable retiree medical coverage or advise entities that do, this Advisory contains important information for you.

Please see full advisory below for more information.

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