Health Law Alert: Early Retiree Reinsurance Program Compliance – Seven Ounces of Prevention


Health care providers and suppliers with employer-based health plans that participate in the Early Retiree Reinsurance Program (ERRP) should be mindful of the ongoing compliance obligations under ERRP. While many plans considered their compliance programs when submitting their applications to ERRP in 2010, now is a good time for those plans to review the effectiveness of their ERRP compliance programs.

The ERRP was created by the Patient Protection and Affordable Care Act in March 2010. Following the Department of Health and Human Services’ (HHS) interim final regulations, ERRP began accepting initial applications by June 2010. To facilitate this new program, HHS continuously updates the seemingly evolving ERRP requirements and guidelines by posting information at the ERRP website,

Many plans submitted applications to ERRP in 2010 and each participating plan was required to affirm that it had an effective compliance plan before seeking reimbursement from ERRP’s $5 billion fund. As an ERRP participant, each plan agreed to an ongoing obligation to continuously submit correct data, update incorrect data, and report changes in the plan to HHS.

Please see full alert below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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