The U.S. Department of Health and Human Services has posted guidance on the Early Retiree Reinsurance Program, which goes into effect this month. This program was established under the national health care reform legislation to encourage employers to maintain health coverage for pre-Medicare retirees. It follows regulations that HHS published last month. (Click here to read our legal alert dated May 4, 2010.)

The new guidance includes an application to participate in the Early Retiree Reinsurance Program, along with related instructions and frequently asked questions and answers. More information on the application and claims submission process will be posted in the near future. Perhaps most significantly, the "official" application (which is expected to be exactly like the one now posted except that it will add how and where to submit the application) is scheduled to be posted later this month.

To see the new guidance and future updates, click here.

We can assist employers and other plan sponsors who wish to apply for the Early Retiree Reinsurance Program.

As the federal health care reform effort gained steam, Ballard Spahr attorneys formed an initiative to monitor and analyze legislative developments. With federal health care reform now a reality, our attorneys are assisting employers in understanding the relevant changes and planning for the future. For more information on the firm’s Health Care Reform Initiative, please click here.


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