Common Questions

ANSWER: A sponsor can receive reimbursement for health benefit items and services for which Medicare would reimburse under Parts A, B, and D. For general reference as to what items and services are covered by Medicare Parts A and B, please refer to the Centers for Medicare & Medicaid Services' (CMS) Medicare & You 2012 and Your Medicare Benefits publications, which are available on the Medicare.gov website. For information on certain items and services that are excluded from Medicare Parts A and B, and guidance for determining which National Drug Codes (NDCs) are excluded from Medicare Part D, see the related documents at www.errp.gov, under the Regulations and Guidance tab.

Answer ID: 200-1
Date Posted: 08/31/2010      Last Updated: 02/01/2012

ANSWER: To the extent the sponsor recovers any such amounts, other than amounts reimbursed to the plan sponsor by its stop-loss carrier, the claims for which the third party reimbursement was received, are not considered to have been paid by the plan. Therefore, they are not to be included in the Costs Paid by Plan. If a sponsor had received ERRP reimbursement pursuant to a reimbursement request for which the sponsor had included such amounts in the Costs Paid by Plan, the sponsor should treat such submission as a data inaccuracy, and is expected to disclose the data inaccuracy pursuant to the ERRP regulation at 45 CFR 149.600, and any additional guidance regarding corrections of data inaccuracies. For information on reporting data inaccuracies, review the CMS guidance document, Explanation of the Processes for Reporting Early Retiree and Claims Data Inaccuracies, and for Reopening. We view amounts a sponsor receives from a stop-loss carrier differently (see Answer ID 200-17), because we believe permitting sponsors to receive ERRP reimbursement or credit toward the cost threshold, for health benefits costs reimbursed to the sponsor by its stop-loss carrier, is consistent with the fact that under the ERRP, sponsors of insured plans may receive reimbursement or credit toward the cost threshold, for claims costs paid by the sponsor's health insurance issuer.

ANSWER: Reimbursement requests may be submitted, for a given plan, only once per calendar year quarter for each plan year. The calendar year quarters are the following: January 1 – March 31, April 1 – June 30, July 1 – September 30, and October 1 – December 31. For the purpose of this limitation on reimbursement requests, a given Plan Sponsor’s plan year is irrelevant.

Answer ID: H200-31
Date Posted: 12/30/2010

ANSWER: Yes, subject to the restrictions in Common Question H200-50. While reimbursement requests for a given plan may only be submitted once per calendar year quarter for each plan year, until the program ends or such time that HHS discontinues accepting reimbursement requests, allowing reimbursement requests after the close of a sponsor's plan year enables the sponsor to initially submit or update their Early Retiree Lists, Summary Cost Data and Detailed Claims Data, if necessary.

Answer ID: H200-32
Date Posted: 12/30/2010      Last Updated: 07/20/2011

ANSWER: Yes. For example, a self-funded plan might pay a capitation rate to all or some providers in its provider network. To the extent the sponsor wishes to receive reimbursement for items and services furnished by such providers, the information required in a claim must be produced and provided to the Secretary, as set out in the regulation and applicable guidance.

Answer ID: 200-3
Date Posted: 08/09/2010

ANSWER: Yes. The interim final regulation at 45 C.F.R. 149.115 states that the cost threshold and cost limit apply individually, to each early retiree, as that term is defined in 45 C.F.R. 149.2, and a sponsor is reimbursed for each individual separately. The interim final regulation's definition of "early retiree" at 45 C.F.R. 149.2 establishes that, for purposes of the program, a spouse, surviving spouse, and dependent of an early retiree are each individually considered an early retiree under the program, provided the early retiree, early retiree's spouse, surviving spouse or dependent are enrolled in the certified employment-based plan.

Answer ID: 200-5
Date Posted: 09/24/2010      Last Updated: 08/12/2011

ANSWER: The amount of sales tax on health benefits is a part of the health benefit cost and can be included in reimbursement requests. Such amounts count toward the cost threshold and the cost limit. To the extent any amount of sales tax falls between the threshold and limit, it is reimbursable under the program.

Answer ID: 200-6
Date Posted: 09/24/2010      Last Updated: 08/12/2011

ANSWER: The transition policy in 45 CFR 149.105(a) relies upon the date on which the claim is incurred. This provision states that "[t]he amount of claims incurred before June 1, 2010 that exceed $15,000 are not eligible for reimbursement and do not count towards the cost limit." Section 149.105(b) further states that the "reinsurance amount to be paid is based only on claims incurred on and after June 1, 2010, that fall between the cost threshold and cost limit for the plan year." Therefore if a claim that falls above the cost threshold, but below the cost limit, is incurred before June 1, 2010, but is paid after June 1, 2010, HHS will not reimburse for this claim.

Answer ID: 200-11
Date Posted: 09/24/2010      Last Updated: 08/12/2011

ANSWER: Prima facie evidence is evidence that shows that a claim was incurred by an early retiree or the early retiree's spouse, surviving spouse or dependent during a plan year, and that shows that the claim was actually paid. A receipt for a health care item or service could satisfy this requirement. Some parties have suggested to HHS that an explanation of benefits should meet this requirement. However, an explanation of benefits does not show that a claim was actually incurred or that a claim was actually paid, as is required by the statute and regulations. An explanation of benefits only shows what a plan would have paid had a claim been incurred.

Answer ID: 200-12
Date Posted: 09/24/2010

ANSWER: Yes. The statute states that:

For purposes of determining the amount of any such claim, the costs paid by the early retiree or the retiree's spouse, surviving spouse, or dependent in the form of deductibles, co-payments, or co-insurance shall be included in the amounts paid by the participating employment-based plan.

The statute requires that the cost be paid by the early retiree or the early retiree's spouse, surviving spouse or dependent in order for a sponsor to be reimbursed for that portion of the claim, or for that portion of the claim to be credited toward the cost threshold. Therefore HHS will need proof that the early retiree or the early retiree's spouse, surviving spouse, or dependent paid his or her portion of the claim in order for the sponsor to submit that portion of the claim. This does not mean that if the sponsor cannot get prima facie evidence of payment from the early retiree or the early retiree's spouse, surviving spouse, or dependent, that the sponsor cannot submit the portion of the claim the plan paid. The sponsor may submit the portion of the claim that the plan paid, and if the request otherwise meets the program requirements, the sponsor will receive credit towards the cost threshold or be reimbursed for the portion that it paid, as applicable.

Answer ID: 200-13
Date Posted: 09/24/2010      Last Updated: 08/12/2011

ANSWER: Further guidance will be provided on this issue. However, please be aware that a sponsor's inability to produce such prima facie evidence does not mean that the sponsor cannot submit the portion of the claim the plan paid. The sponsor may submit the portion of the claim that the plan paid, and if the request otherwise meets the program requirements, the sponsor will receive credit towards the cost threshold or be reimbursed for the portion that it paid, as applicable.

Answer ID: 200-14
Date Posted: 09/24/2010      Last Updated: 08/12/2011

ANSWER: If the sponsor wants the early retiree's, or early retiree's spouse's, surviving spouse's, or dependent's, portion of the claim to count towards the cost threshold, the sponsor must produce prima facie evidence that the early retiree or early retiree's spouse, surviving spouse, or dependent paid his or her portion of the claim.
A receipt for a health care item or service could satisfy this requirement The regulations require that all claims that are submitted for a plan year must be incurred during the plan year and paid (although the claims need not be paid during the plan year). Please be aware that a sponsor's inability to produce the prima facie evidence discussed in the response to this Question does not mean that the sponsor cannot submit the portion of the claim the plan paid. The sponsor may submit the portion of the claim that the plan paid, and if the request otherwise meets the program requirements, the sponsor will receive credit towards the cost threshold or be reimbursed for the portion that it paid, as applicable.

Answer ID: 200-15
Date Posted: 09/24/2010      Last Updated: 08/12/2011

ANSWER: Yes. Prima facie evidence that an early retiree or early retiree's spouse, surviving spouse, or dependent paid his or her portion of the claim is required for each and every claim under the program for health benefits that includes amounts paid by such individuals. This does not mean that if the sponsor cannot obtain such evidence, the sponsor cannot submit the portion of the claim the plan paid. The sponsor may submit the portion of the claim that the plan paid, and if the request otherwise meets the program requirements, the sponsor will receive credit towards the cost threshold or be reimbursed for the portion that it paid, as applicable.

Answer ID: 200-16
Date Posted: 09/24/2010      Last Updated: 08/12/2011

ANSWER: Provided all applicable program criteria are met, the fact that a stop-loss insurer reimbursed the health insurance issuer or employment-based plan for some or all costs of a claim, does not prohibit the sponsor from submitting that claim to HHS for credit toward the cost threshold, or reimbursement. For purposes of submitting the claim to HHS, and for purposes of the amount of program credit or reimbursement that HHS will issue to the sponsor, the amount of reimbursement the stop-loss carrier paid to the plan or insurer is irrelevant.

Answer ID: 200-17
Date Posted: 09/24/2010      Last Updated: 08/12/2011

ANSWER: No.

Answer ID: 200-33
Date Posted: 12/30/2010

ANSWER: The ERRP regulations state that costs are aggregated for each plan year, because each individual's cost threshold and cost limit are specific to each plan year.

Answer ID: 200-34
Date Posted: 12/30/2010

ANSWER: No. See the transition policy established in 45 CFR 149.105.

Answer ID: 200-35
Date Posted: 12/30/2010

ANSWER: Yes, prescription drugs are included in the definition of "health benefits" in the ERRP statute and regulations. The costs of these items may count toward the cost threshold and cost limit, and be reimbursed provided the prescription drugs would be covered under Medicare Part B, or by a standard Medicare Part D plan. See the guidance documents available on the Regulations and Guidance page.

Answer ID: 200-36
Date Posted: 12/30/2010

ANSWER: To the extent an employment-based plan incurs and pays costs for health benefits that are provided by an out-of-network and/or out-of-service area provider, the associated costs may count toward the ERRP cost threshold and cost limit and may be reimbursed. To the extent an early retiree, spouse, surviving spouse, or dependent incurs and pays costs for such health benefits, those costs may count toward the ERRP cost threshold and cost limit and be reimbursed under either of the following circumstances: (1) The employment-based plan pays any portion of the out-of-network or out-of-service-area health benefit, or (2) The employment-based plan would have paid any portion of the out-of-network or out-of-service-area benefit, but for the fact that the individual has not satisfied a deductible. We believe that permitting sponsors to submit costs paid by early retirees, spouses, surviving spouses, and dependents under such circumstances is consistent with the statute and regulations, which include costs paid by such individuals in the form of deductibles, copayments, or coinsurance in the amounts eligible for submission by sponsors of participating employment-based plans. Consistent with HHS' guidance on Claims Eligible for Reimbursement, HHS will not credit the costs of these health benefits towards the cost threshold and cost limit, or reimburse for these items and services if not furnished within the United States. To the extent a sponsor wishes to submit costs for any amounts paid by an early retiree, spouse, surviving spouse, or dependent, the sponsor is expected to submit prima facie evidence that the individual paid such costs. (See related questions related to prima facie evidence).

Answer ID: 200-38
Date Posted: 12/30/2010

ANSWER: Yes. The ERRP statute and regulations require that claims submitted under the program be based on the actual amount expended by the sponsor (and by the early retiree or spouse, surviving spouse, or dependent, if such amounts are being submitted to HHS). Further, the ERRP regulations state that "A claim may be submitted only if it... has been incurred during the applicable plan year, and has been paid." 45 CFR §149.325. We interpret the statute and regulations to mean that claims must be incurred in the applicable plan year, and paid (but not necessarily during the plan year), in order for the costs to count towards the cost threshold and cost limit, and to be reimbursed.

Answer ID: 200-39
Date Posted: 12/30/2010

ANSWER: No. In order for HHS' systems to process reimbursement requests for a given plan year, it is necessary for submissions to be cumulative (i.e. containing cumulative data from the beginning of the plan year). Further, in order for HHS' systems to process reimbursement requests, Early Retiree Lists, Summary Claims Data, and Detailed Claims Data must always be reported using full-replacement files (i.e. updating cumulative records from the beginning of the plan year). For example, a plan sponsor would not submit a reimbursement request to account for paid claims incurred between July 1 and September 30th, and then submit a separate reimbursement request to account solely for the paid claims incurred between October 1st and December 31st.

Answer ID: H200-40
Date Posted: 12/30/2010

ANSWER: Yes, subject to the restrictions in Common Question H200-50. The ERRP statute and regulations require that claims submitted under the program be based on the actual amount expended by the sponsor. Further, the ERRP regulations state that "A claim may be submitted only if it ... has been incurred during the applicable plan year, and has been paid." 45 CFR §149.325. We interpret the statute and regulations to mean that claims must be incurred in the applicable plan year, and paid (but not necessarily during the plan year). Some costs incurred during a plan year might not be paid until after the plan year is over. In such cases, once the costs have been paid, the sponsor may submit them for credit toward the cost threshold and cost limit, or for reimbursement for the plan year in which they were incurred.

Answer ID: H200-41
Date Posted: 12/30/2010      Last Updated: 07/20/2011

ANSWER: Only the portion of the cost of the specific item or service that exceeds the cost limit, for an individual, should be included in the Limit Reduction field. For example, an early retiree has costs of $89,990 for a plan year. The plan then pays an incurred claim for $200 for that individual. When aggregating the Summary Cost Data, the sponsor would, for this individual, include $200 in Costs Paid by Plan and $190 in Limit Reduction. (This example assumes the plan has not received any price concessions.) Note that 45 C.F.R. 149.320(c) states that sponsors must not submit claims for health benefits for an early retiree to the extent the sponsor has already submitted claims for the early retiree that total more than the applicable cost limit for the applicable plan year. This principle applies to Summary Cost Data and Detailed Claims Data.

Answer ID: H200-42
Date Posted: 12/30/2010

ANSWER: The ERRP regulation defines "incurred" as "the point in time when the sponsor, health insurance issuer (as defined in 45 CFR 160.103), employment-based plan, plan participant, or a combination of these or similar stakeholders, become responsible for payment of the claim." 45 C.F.R. § 149.2. We interpret this regulatory definition to mean, with respect to the costs associated with an inpatient acute care hospital stay, the date of admission. Thus, a plan sponsor must submit such costs in the Summary Cost Data and Detailed Claims Data for the plan year in which they are incurred. For example, if a plan year is a calendar year and an early retiree was admitted for an inpatient acute care hospital stay on December 31, 2010, and remained hospitalized through January 15, 2011, all the costs are incurred on December 31, 2010 (i.e. in the plan sponsor's 2010 plan year), for purposes of ERRP. If an early retiree was admitted to an acute care hospital on May 31, 2010, and remained an inpatient through June 15, 2010, no portion of the total cost would be reimbursed because the costs will be viewed as incurred before June 1, 2010, the start of the ERRP. However, the first $15,000 could be applied toward the cost threshold and cost limit.

Answer ID: 200-43
Date Posted: 12/30/2010      Last Updated: 08/12/2011

ANSWER:45 C.F.R. § 149.2 defines "incurred" as "the point in time when the sponsor, health insurance issuer (as defined in 45 CFR § 160.103), employment-based plan, plan participant, or a combination of these or similar stakeholders, become responsible for payment of the claim." CMS interprets this regulatory definition to mean, with respect to costs for items and services furnished by institutions (other than inpatient acute care hospitals), to be the "FROM Date of Service" for the specific item or service specified on the bill.

As compared to individuals who are inpatients in an acute care hospital, individuals in other types of institutions might remain in the institution and receive items and services for a significantly longer period of time. So, the institution may submit multiple bills with different FROM Dates of Service for the same individual. Due to these situations, we believe that the FROM Date of Service is the appropriate incurred date in these settings.

The date of admission may not be a relevant date for the ERRP in these settings. In some situations, an employment-based plan could be responsible for paying costs for health benefits for items and services that are furnished during some, but not all, of the length of stay that starts on the admission date. For example, an employment-based plan might become responsible for payment for a period of time that begins after the admission date. This is because a given individual’s coverage with an employment-based plan might commence on a date after the admission date.

For the purposes of inpatient acute care hospital claims, ERRP relies on the date of admission for determining the incurred date. Using the date of admission for institutional claims other than inpatient acute care hospital claims may not allow sponsors to be reimbursed or credited for significant claims resulting from long stays in an institution if the admission date was before the effective date of ERRP on June 1, 2010. In addition, using the date of admission may cause plan sponsors to have to report new costs incurred during an extended stay, numerous times for a past plan year, if it wishes to receive reimbursement or receive credit towards the cost threshold for those new costs.

Answer ID: 200-44
Date Posted: 12/30/2010      Last Updated: 07/20/2011

ANSWER: The ERRP regulation defines "incurred" as "the point in time when the sponsor, health insurance issuer (as defined in 45 CFR 160.103), employment-based plan, plan participant, or a combination of these or similar stakeholders, become responsible for payment of the claim." 45 C.F.R. § 149.2. We interpret this regulatory definition to mean, with respect to the costs associated with a professional service, the date that the service is furnished to the early retiree. For example, if an early retiree is treated by a physician on June 1, 2010, the Date of Service on the claim (i.e. the incurred date) would be June 1, 2010. If a service is rendered over more than one day, the incurred date would be the first date that the service was rendered. For example, if an early retiree is treated by a physician from June 1, 2010 through June 2, 2010, and the Dates of Service on the claim are from June 1, 2010, to June 2, 2010, the incurred date is June 1, 2010.

Answer ID: 200-45
Date Posted: 12/30/2010

ANSWER: The ERRP regulation defines "incurred" as "the point in time when the sponsor, health insurance issuer (as defined in 45 CFR 160.103), employment-based plan, plan participant, or a combination of these or similar stakeholders, become responsible for payment of the claim." 45 C.F.R. § 149.2. We interpret this regulatory definition to mean, with respect to costs for a health benefit item furnished to an early retiree, the FROM Date of Service included for the item on the claim. For example, if a piece of durable medical equipment is furnished to an early retiree, and is included as an item, with Dates of Service from June 1, 2010, to June 30, 2010, on a paid claim, then the incurred date is June 1, 2010.

Answer ID: 200-46
Date Posted: 12/30/2010

ANSWER: The ERRP regulation defines "incurred" as "the point in time when the sponsor, health insurance issuer (as defined in 45 CFR 160.103), employment-based plan, plan participant, or a combination of these or similar stakeholders, become responsible for payment of the claim." 45 C.F.R. § 149.2. We interpret this regulatory definition to mean, with respect to costs for prescription drugs, the date the prescription is filled (i.e., the "Date of Service" identified on an electronic claim or the "FROM Date of Service" on a paper claim).

Answer ID: 200-47
Date Posted: 12/30/2010

ANSWER: A sponsor must submit health benefit costs to HHS for purposes of the ERRP, for the plan year in which the costs were incurred. The ERRP regulation defines “incurred” as "the point in time when the sponsor, health insurance issuer (as defined in 45 CFR 160.103), employment-based plan, plan participant, or a combination of these or similar stakeholders, become responsible for payment of the claim." 45 C.F.R. § 149.2. HHS's interpretation of this requirement regarding when items or services are incurred, as stated in other Common Questions, apply regardless of whether the item or service is delivered pursuant to a capitated arrangement, via an integrated health care system or via another health benefit arrangement. With respect to items and services delivered pursuant to a capitated arrangement or integrated health care system, the date of an encounter is the incurred date.

Answer ID: 200-48
Date Posted: 12/30/2010

ANSWER: A sponsor may not submit health benefit costs to HHS for purposes of ERRP unless the costs have been paid (among other criteria). We will consider the costs for items and services that are furnished pursuant to a capitated arrangement or integrated health care system to have been "paid" on the date the costs for the item or service were incurred, provided there is no outstanding liability for payment on the part of the employment-based plan for the item or service (if submitting claims to the ERRP for the plan's portion of the costs) , or no outstanding liability for payment with respect to the early retiree, or early retiree’s spouse, surviving spouse, or dependent (if submitting claims to the ERRP for such an individual's portion of the costs). If costs for items or services that are provided over a span of more than one consecutive day are accrued, a plan sponsor may not submit the costs until the item or service is actually provided. This is because if an item or service is not provided, the costs for such services have not been incurred, which is a prerequisite for submitting costs. A plan sponsor may not project costs and submit cost data for any items and services not provided as of the date of the applicable reimbursement request.

As an example of a situation where there may be outstanding liability for payment, an employment-based plan's capitated arrangement with a provider requires the plan to make additional payment (over and above the capitated payment) for certain outlier procedures. Under the terms of the arrangement, the outlier payments are made after the procedure is performed. In this instance, for purposes of ERRP, the payment date for the procedure will be the actual date of payment for the service (which is also the case for items and services that are provided on a fee-for-service basis). The reason for the dichotomy with respect to when items and services are considered to have been paid under a capitated or integrated health system arrangement versus under a capitated outlier or fee-for-service basis is that providers are not paid for specific items or services under a capitated arrangement or integrated health care system, but they are under other health benefit arrangements.

Answer ID: 200-49
Date Posted: 12/30/2010

ANSWER: The ERRP regulation states that for employment-based plans for which a provider in the normal course of business does not produce a claim, the information required in a claim must be produced and provided to CMS, as set out in the regulation and applicable guidance. 45 C.F.R. 149.310(c). The regulation requires sponsors to include, as part of a claim, the date and amount of payment for each health benefit provided. (See 45 CFR §149.330, and the definition of claim or medical claim at 45 C.F.R. §149.2). Therefore, sponsors of employment-based plans under which providers are paid capitation, may not include, in the Cost Paid by Plan field that appears in the Summary Cost Data and in the Item Plan Paid Amount field in a Claim List, the amount of a capitated payment. Rather, they must derive, and include, an amount of payment for each health benefit provided.

The preamble to the regulation, when discussing an example under which a sponsor contracts with a staff-model HMO that either has its own providers on staff or pays providers a capitated payment, states that the information a sponsor submits with respect to a health benefit item or service (including information about amount of payment) must be reasonable in light of the specific market that the insurer is serving. We interpret this principle to also apply to other instances where capitation might be paid, such as a self-funded plan (i.e. the information submitted by a sponsor of a self-funded plan, including information about amount of payment, must be reasonable in light of the geographic area).

Upon audit, a sponsor of a plan that pays providers through capitation, may be required to demonstrate the reasonableness of its derived and reported costs for health benefit items and services.

Answer ID: H200-62
Date Posted: 07/20/2011

ANSWER: Yes, provided all other program requirements are satisfied.

Answer ID: H200-50
Date Posted: 12/30/2010      Last Updated: 08/19/2011

ANSWER: Professional claims, Institutional claims, and Prescription claims are eligible for reimbursement through the Early Retiree Reinsurance Program (ERRP) if they satisfy all of the following conditions:

• The claim is for a health benefit item or service that would not be excluded for reimbursement by Medicare and that is not otherwise excluded by ERRP (for guidance on claims eligible for reimbursement please see the Regulations and Guidance tab on the errp.gov website);

• The claim was paid by the participating employment-based plan and/or by the individual; and

• The claim was incurred within the plan year and within the Early Retiree's ERRP eligibility dates.

Professional claims are defined as claims submitted to the insurer on the CMS 1500. Institutional claims are defined as claims submitted to the insurer on Form UB-04. Prescription claims are defined as claims submitted to the insurer on a non-specified form, the CMS 1500, ASC X12 837P, or the NCPDP. All applicable claim types will be submitted in one Claim List.

Answer ID: H200-52
Date Posted: 04/17/2011

ANSWER: As part of each plan sponsor's first reimbursement request for each of its Early Retiree Reinsurance Program (ERRP) applications, the sponsor's Authorized Representative must indicate that the sponsor will make a reasonable, good faith effort to meet all the requirements necessary to make a reimbursement request, and that the sponsor will be prepared to demonstrate that it has made such a good faith effort upon request.

Answer ID: 200-21
Date Posted: 09/24/2010

ANSWER: Before reporting costs using the ERRP Secure Website, the Plan Sponsor must submit an approved application, register an Authorized Representative and an Account Manager, and complete Reimbursement Setup (For step-by-step instructions on how to complete reimbursement setup, refer to the How Do I... section in the ERRP SWS.)

Answer ID: H200-22
Date Posted: 10/23/2010

ANSWER: The frequency with which cost are reported to HHS' ERRP Center is at the discretion of the Plan Sponsor. However, each data submission replaces the costs for the entire plan year. Reported costs must have been incurred during the approved time periods listed in the Early Retiree List Response File. Reported cost data submitted to HHS' ERRP Center are used to build reimbursement requests; cost data must be submitted before a reimbursement request can be created and submitted by the Plan Sponsor. HHS' ERRP Center recommends the Plan Sponsor perform reimbursement-related activities quarterly, to include Retiree List submission, cost summary reporting and reimbursement request submission, since reimbursement requests may only be submitted by a Plan Sponsor once per calendar year quarter for a plan year.

Answer ID: H200-23
Date Posted: 10/23/2010      Last Updated: 10/27/2010

ANSWER: The cost threshold and cost limit for an early retiree or early retiree's spouse, surviving spouse or dependent, for whom a plan sponsor is requesting reimbursement under the Early Retiree Reinsurance Program are as follows:

Answer ID: H200-25
Date Posted: 10/23/2010      Last Updated: 08/12/2011

ANSWER: Authorized Representatives, Account Managers with the Request Reimbursement privilege and Designees with the Request Reimbursement privilege are all Reimbursement Requestors. Account Managers with the Report Costs privilege and Designees with the Report Costs privilege may Report Costs and view, but not submit reimbursement requests.

Answer ID: H200-27
Date Posted: 10/23/2010

ANSWER: A Plan Sponsor may request reimbursement once per calendar year quarter for a given plan year, as long as both of the following conditions have been satisfied: 30 days must have elapsed between the previous reimbursement request date and the date a Plan Sponsor wishes to request reimbursement, and 15 days must have elapsed between the previous reimbursement determination date and the date a Plan Sponsor wishes to request reimbursement.

Answer ID: H200-28
Date Posted: 10/23/2010      Last Updated: 03/17/2011