Common Questions

ANSWER: With respect to the Early Retiree Reinsurance Program, the U.S. Department of Health & Human Services (HHS) will generally defer to a plan's rules to determine whether a given individual is an active employee. Such plan rules should be a written plan document, published and in effect as of the day a claim for health benefits for an individual was incurred for which the sponsor seeks credit toward the cost threshold or reimbursement, that indicates whether or not the individual in question is an active employee for all plan purposes. Absent such a document, or in situations in which the plan rules regarding the definition of active employee are vague and unclear, the determination of whether an individual is an active employee for purposes of the program, is determined by whether such individual is considered to be receiving coverage by reason of current employment status under the MSP rules at 42 C.F.R. 411.104 and related Centers for Medicare & Medicaid Services' guidance.

Answer ID: 300-1
Date Posted: 08/09/2010      Last Updated: 08/12/2011

ANSWER: No. In instances when the plan sponsor is not an employer, the individual cannot be an active employee of an employer maintaining or currently contributing to, the employment-based plan or of any employer that has made substantial contributions to fund such a plan. This clarification to the regulatory definition of "early retiree" reflects what our intent was when drafting the definition.

Answer ID: 300-2
Date Posted: 08/09/2010

ANSWER: Yes.

Answer ID: 300-4
Date Posted: 09/24/2010

ANSWER: No. Under the statute and regulations, the deceased individual never met the definition of an early retiree. Therefore, the surviving spouse never met the definition of early retiree.

Answer ID: 300-5
Date Posted: 09/24/2010

ANSWER: No. Under the statute and regulations, the deceased individual never met the definition of an early retiree. Therefore, the surviving spouse never met the definition of early retiree.

Answer ID: 300-6
Date Posted: 09/24/2010

ANSWER: No.

Answer ID: 300-7
Date Posted: 09/24/2010

ANSWER: No. The statute states that an early retiree cannot be eligible for coverage under title XVIII of the Social Security Act. 1102(a)(2)(C). Individuals who do not qualify for free Medicare Part A may still be eligible for coverage under title XVIII of the Social Security Act. It is just not free Medicare Part A. The individual must purchase it. Therefore these individuals do not qualify as early retirees and sponsors cannot be reimbursed for claims incurred and paid for, and by, these individuals and their families.

Answer ID: 300-8
Date Posted: 09/24/2010

ANSWER: Yes. The definition of an "early retiree" requires that the early retiree not be "an active employee of an employer maintaining, or currently contributing to, the employment-based plan or of any employer that has made substantial contributions to fund such plan." 45 CFR 149.2. Therefore, as long as an early retiree is not employed by an employer that is maintaining, or currently contributing to, the employment-based plan or by any employer that has made substantial contributions to fund such plan, the employer-sponsor from which the early retiree retired (or employee organization, as applicable) may consider that individual and that individual's spouse or dependent, to be an early retiree, even if the individual is employed elsewhere.

Answer ID: 200-4
Date Posted: 09/24/2010      Last Updated: 10/08/2010

ANSWER: No. The regulation at 45 C.F.R. 149.100 states that" [r]eimbursement is calculated by first determining the costs for health benefits net of negotiated price concessions, within the applicable plan year for each early retiree, and then subtracting amounts below the cost threshold and above the cost limit within the applicable plan year for each such individual." Emphasis added. In order for a claim to count towards the cost threshold, cost limit, or to be reimbursed, the individual must therefore meet the definition of an "early retiree." For example, a sponsor's plan year is January 1, 2011 through December 31, 2011, and an individual who is not an active employee turns 55 on March 1, 2011 and otherwise meets the regulatory definition of an early retiree as of that date. The sponsor cannot submit claims that were incurred before March 1, 2011, for that individual, or for his or her spouse, surviving spouse, or dependents because the early retiree did not meet the definition of an early retiree until March 1, 2011.

Answer ID: 200-7
Date Posted: 09/24/2010      Last Updated: 10/08/2010

ANSWER: No. Claims of the surviving spouse that were incurred on any date after the deceased individual would have become eligible for coverage under Title XVIII of the Social Security Act had he or she lived, cannot be submitted for ERRP.

Answer ID: 200-8
Date Posted: 09/24/2010      Last Updated: 10/08/2010

ANSWER: No. In order for a spouse, surviving spouse, or dependent to satisfy the definition of an early retiree, the individual through whom he or she gets coverage in the employment-based plan must be an early retiree, who by definition may not be eligible for coverage under Medicare.

Answer ID: 200-9
Date Posted: 09/24/2010      Last Updated: 10/08/2010

ANSWER: Yes. The statute and regulations only apply the age and Medicare-status requirements to the individual through whom the spouse, surviving spouse or dependent receive their health benefits, not to the spouse, surviving spouse, and dependent. The ERRP regulation includes spouses, surviving spouses and dependents in the definition of "early retiree", regardless of the age and Medicare eligibility of such individuals. Spouses, surviving spouses and dependents must be enrolled in an ERRP-approved plan, and have claims for health benefits (as defined in the regulations and HHS guidance) in excess of the cost threshold for a given plan year, in order for a sponsor to get credit towards the cost threshold and to receive reimbursement for eligible claims for such individuals.

Answer ID: 300-34
Date Posted: 12/30/2010      

ANSWER: No. The statute, when discussing for whom a sponsor may receive reimbursement, specifies that reimbursement may be received for claims of early retirees, their spouses, surviving spouses and dependents. The statute, while allowing reimbursement for surviving spouses, does not specify that reimbursement is allowed for surviving dependents. §1102(c)(1)(B). Therefore, we do not read the statute as permitting surviving dependents to satisfy the definition of "early retiree."

Answer ID: 200-10
Date Posted: 09/24/2010      Last Updated: 10/08/2010

ANSWER: Yes. Under the ERRP statute and regulations, an "early retiree" is defined in part as an individual "who is not an active employee," when referring to the former employee of an applicable employer. (By "applicable employer", we mean the plan sponsor, if the plan sponsor is an employer, or an employer maintaining, or currently contributing to, the employment-based plan or any employer that has made substantial contributions to fund such a plan, if the sponsor is not an employer). Thus, an early retiree who was once an employee of an applicable employer does not actually have to be retired, as long as he or she is not an active employee of an applicable employer, which is often the case with individuals receiving coverage via COBRA. Therefore, if the former employee of an applicable employer otherwise meets the statutory and regulatory definition of "early retiree" (i.e., an individual who is age 55 and older who is not eligible for coverage under Medicare and who is not an active employee), the fact that the individual is receiving health benefits via COBRA does not necessarily preclude the individual from being an early retiree.

Answer ID: 300-36
Date Posted: 07/20/2011

ANSWER: Yes. The Affordable Care Act (ACA) at section 1102(a) permits a plan sponsor to receive ERRP reimbursement for early retirees, and for "eligible" spouses, surviving spouses, and dependents of such retirees. We interpret the statutory term "eligible" to mean that the individual is an "eligible" "spouse", "surviving spouse" or "dependent" if he or she qualifies for, and has coverage under the terms of the plan, as a spouse or dependent of an early retiree (or the surviving spouse of an individual who was an early retiree upon his or her death), in instances where the spouse, surviving spouse, or dependent qualifies for and has such coverage under the terms of the plan generally, and in instances where such individual has coverage under the terms of the plan by operation of Federal and/or state law, such as COBRA. To the extent a former spouse of an early retiree has coverage under the terms of the plan by operation of state and/or federal law, we interpret the statutory term "spouse" in section 1102(a) and in the regulatory definition of "early retiree", to include such a former spouse.

Although CMS defers to the terms of a plan and expects that all plans are in compliance with applicable Federal and state laws, there are instances when the terms of a plan, with respect to its definitions of who is eligible for coverage as a spouse, surviving spouse, or dependent, may not align with Federal and state laws. In such cases, CMS will not consider the individuals as "eligible" spouses, surviving spouses, or dependents for purposes of the ERRP, even if the terms of the plan otherwise permissibly cover these individuals.

Answer ID: 300-37
Date Posted: 07/20/2011

ANSWER: Yes, assuming the individual otherwise meets the regulatory definition of an early retiree or the spouse, surviving spouse, or dependent of an early retiree. Individuals receiving health benefits from an employment-based plan to which the sponsor makes no premium contribution for that individual, receive the same advantages from the ERRP reimbursement as do individuals for whom a sponsor is making premium contributions. If the sponsor uses the reimbursement to lower or offset increases to plan participants' costs, a plan participant, regardless of whether the sponsor is contributing toward his or her premium, will receive the advantages of the reimbursement. Similarly, if the sponsor uses the funds to offset increases to its own health benefit or health benefit premium costs, a plan participant will receive the advantage of the increased likelihood of continued access to an employment-based plan, regardless of whether the sponsor is contributing toward his or her premium.

Answer ID: 200-19
Date Posted: 09/24/2010      Last Updated: 10/08/2010

ANSWER: Yes. Such persons can satisfy the regulatory definition of "early retiree", under the same circumstances as individuals receiving coverage through COBRA who do not enjoy reduced premiums due to ARRA. The ARRA COBRA premium does not relate, for purposes of the ERRP, to reimbursement for health care claims that may be incurred by an early retiree and an early retiree's spouse, surviving spouse or dependent.

Answer ID: 200-20
Date Posted: 09/24/2010      Last Updated: 10/08/2010

ANSWER: There is no single, specific method of showing that a sponsor has met this requirement.

For the actual early retiree who worked for the plan sponsor, HHS expects that an employer had performed all tasks required at time of hiring, to ensure that an employee is a U.S. citizen or legally present and able to work in the U.S. We would expect a sponsor that is NOT an employer, such as a board or committee that operates a multiemployer plan, to make a reasonable, good faith effort to solicit written assurances from the employers that contribute to its plan, that the employer performed such tasks.

Furthermore, ensuring that early retirees and their spouses, surviving spouses, and dependents, for whom ERRP reimbursement is being requested, have a Social Security Number (SSN) could be a reasonable way of performing the due diligence required to ensure that an ERRP sponsor is only submitting claims for individuals who are U.S. citizens, or lawfully present in the U.S. In fact, HHS is requiring sponsors to include, on the Early Retiree List, the SSN for the early retiree (otherwise known as the "subscriber") through whom the early retiree's spouse, surviving spouse, and/or dependent(s) are receiving access to coverage so if a plan sponsor can complete the Early Retiree List with respect to the subscriber, it will have already made a reasonable good faith effort to comply with this standard with respect to the subscriber. This is because only U.S. citizens, and noncitizens who are legally present in the U.S., can obtain SSNs. For ERRP purposes, we presume that if an individual has an SSN, the individual is in the U.S. legally. There may be other Federally-issued numbers that do not relate to citizenship or legal-residence status but may resemble an SSN. For example, an Individual Taxpayer Identification Number issued by the Internal Revenue Service, is one such number. Therefore numbers that resemble an SSN, but start with the number "9", would not be evidence, for ERRP purposes, that an individual is legally present in the U.S.

As part of the information included on the Early Retiree List, sponsors provide one of the following Federal identification numbers for spouses, surviving spouses, and dependents:

• • A. an SSN,
  • B. an Alien Identification Number,
  • C. an I-94 Number, or
  • D. other Federal identification number.

See the Early Retiree List Format. Only Federally-issued identification numbers of the type that are only issued to U.S. citizens or individuals legally present in the U.S may serve as evidence that an individual is a U.S. citizen or is lawfully present in the U.S. Therefore, again, if the sponsor can complete the Early Retiree List with such an identifier, the plan sponsor will have made a reasonable, good faith effort to comply with this standard.

Of course, if an ERRP sponsor has reason to know that an individual is no longer legally present in the U.S. but still retains an SSN (or other Federally-issued identification number, as applicable), it is the sponsor's obligation to not submit claims for that individual.

Answer ID: 300-35
Date Posted: 12/30/2010      

ANSWER: Generally, the term early retiree will apply to the early retiree (Subscriber) and an enrolled spouse, surviving spouse and/or dependent(s) (Members). When determining ERRP eligibility, all of the following must be true for the Subscriber before the Subscriber, or associated Member(s), can be considered for participation in ERRP. The Subscriber must be:

• • Age 55 and older,
  • Enrolled for health benefits in the certified employment-based plan identified on the application,
  • Not eligible for coverage under Medicare, (which the U.S. Department of Health & Human Services will verify upon receiving a sponsor's Early Retiree List), and
  • Not an active employee of the Plan Sponsor identified on the application (in accordance with the rules of the plan).

For more detailed information about who can be an early retiree, please see the early retiree-related Common Questions on the ERRP Public Website at http://errp.gov/faq_eligible.shtml.

Answer ID: H300-9
Date Posted:10/01/2010

ANSWER: The Early Retiree List is a collection of data about the person(s) for whom a Plan Sponsor will request reimbursement. The Early Retiree List must be submitted to the ERRP Center prior to submitting a reimbursement request.

Answer ID: H300-10
Date Posted: 10/01/2010

ANSWER: After the Plan Sponsor has identified its early retirees (Subscribers), a second condition must be present for an individual to be included in the ERRP Early Retiree list. The individual (i.e. the Subscriber and/or Member) must have accumulated an amount of plan and/or early retiree paid claims for health benefits during the plan year, of at least the applicable cost threshold for that plan year (review Common Question H200-25 for plan year specific cost threshold and cost limit amounts), which are eligible for credit towards the ERRP cost threshold or ERRP reimbursement. Accrual of eligible claims occurs on an individual basis. Therefore, a Subscriber’s claims accrue for the Subscriber. A Member’s claims accrue for the individual Member. In order for a claim for a specific medical item or service to count towards the cost threshold, it must meet all of the following conditions. It must be:

• A medical item or service that is not excluded for reimbursement by Medicare;

• Incurred within the plan year (For plan years that start before and end after June 1, 2010, claims incurred between the start of the plan year and May 31, 2010 can only be credited toward the $15,000 threshold, and only claims incurred on or after June 1, 2010 are eligible for reimbursement);

• Actually paid by the participating employment-based plan and/or by the individual (For amounts paid by the individual, the sponsor must provide prima facie evidence that the individual paid the amount).

It is important to note that an Early Retiree List should ONLY include ERRP-eligible Subscribers and/or Members meeting the cost threshold. Additionally, if the Subscriber does not meet the cost threshold, but a Member does, then the Subscriber record must also be submitted on the Early Retiree List in addition to the associated Member record. For example, if Bob Jones is the Subscriber and his wife Mary Jones is the Member, and Bob does not meet the cost threshold, but Mary does, Bob needs to be included on the early retiree list (one record for Bob and one record for Mary). The Subscriber record is required, because a Member's ERRP eligibility is based on the Subscriber's ERRP eligibility.

Answer ID: H300-11
Date Posted: 10/01/2010      Last Updated: 08/12/2011

ANSWER: Yes. The Plan Sponsor must submit an early retiree list to the ERRP Center, and receive and review an early retiree list response file, before submitting a reimbursement request or claims for those individuals. This will ensure that only claim costs associated with ERRP-eligible individuals are being included in the reimbursement request.

Answer ID: H300-12
Date Posted: 10/01/2010

ANSWER: HHS' ERRP Center will accept an Early Retiree List one of two ways: uploaded to the ERRP Secure Website (SWS), or transmitted via a mainframe connection to the ERRP Center mainframe. The Plan Sponsor will specify which submission method it is using in the ERRP Secure Website. For step-by-step instructions on how to select the Early Retiree File Submission Method, refer to the How Do I... section in the ERRP SWS.

If mainframe submission is preferred, it is necessary to call HHS' ERRP Center as soon as possible to begin the setup process. Minimal setup is required for ERRP SWS submission, and no phone call to HHS' ERRP Center is required.

A Plan Sponsor will be required to submit each Early Retiree List using a format specified by HHS' ERRP Center. Click here for the detailed Early Retiree List format requirements.

Answer ID: H300-13
Date Posted: 10/01/2010      Last Updated: 10/08/2010

ANSWER: If an error message is received while uploading an Early Retiree List, this indicates that the Early Retiree List has been rejected and must be uploaded again. Click here for the detailed ERRP SWS Upload Retiree File Error Messages. Use this list to troubleshoot the errors before resubmitting your file.

Answer ID: H300-14
Date Posted: 10/01/2010

ANSWER: Yes. If a Plan Sponsor wishes to submit an Early Retiree List by uploading a file to the ERRP Secure Website, then it must use the specific file template published by HHS' ERRP Center for doing so. Click here for the SWS Early Retiree File Template.

Note: Once the spreadsheet is complete, do not forget to create a .csv version of the file to upload by clicking the Save As CSV File button. Do not upload the .xls file.

Answer ID: H300-15
Date Posted: 10/01/2010

ANSWER: The Member ID is the unique identifier assigned to each individual (i.e. each early retiree, each spouse, each surviving spouse and each dependent will have a different Member ID) by each claims processor within an employment-based plan. The Member Group ID is the unique identifier that claims processors assign to each group for which they process claims.

A claims processor is an entity such as a health insurance issuer, pharmacy benefit manager, or third party administrator that receives and processes health benefits claims on behalf of the plan. A plan may have more than one claims processor. In such cases an individual may have more than one Member ID, and will likely have more than one Member Group ID, within the plan. For example, a plan sponsor's plan may include an entity that functions as a claims processor for medical benefits and another entity that functions as a claims processor for prescription drug benefits, and each entity may assign a different Member ID to each individual. Therefore, each individual might have two different Member IDs, one for medical benefits and one for prescription drug benefits. However, in some plans, each individual may be assigned only one Member ID that pertains to all benefits, even if the plan uses different claims processors for different types of benefits. The number of Member IDs per individual will likely vary from plan sponsor to plan sponsor depending how each sponsor administers its benefits. Also, an individual may be associated with more than one Member Group ID within the plan. In other cases there might be only one Member Group ID within the plan.

For each unique individual whose health benefit costs meet the cost threshold, there should be a separate record included on the Early Retiree List that identifies each unique Member ID/Member Group ID combination. The ERRP program will only be able to process records that include a unique Member ID/Member Group ID combination for each claims processor that processed one or more claims for that individual under the plan. Each claim included in the Detailed Claims Data for an individual must include the appropriate Member ID/Member Group ID combination. This Member ID/Member Group ID combination must also match the appropriate combination included on the Early Retiree List for that individual and claims processor.

If a plan sponsor or its data aggregator does not have access to each claims processor's Member Group ID or each Member ID that is assigned by each claims processor to each individual, the plan sponsor or data aggregator can create a proxy Member Group ID for each claims processor and a proxy Member ID for each individual. In such instances, the plan sponsor will use these proxy IDs when submitting Early Retiree Lists and Detailed Claims Data. Upon request by HHS, the Plan Sponsor will be expected to be able to explain to HHS how it produced the proxy IDs and be able to map the proxy IDs on the Detailed Claims Data and Early Retiree Lists, submitted to HHS, to the paid claim record(s) from the claims processor(s), and to any other data necessary to substantiate compliance with the program requirements.

HHS' designed its systems so they can only process records that include Member IDs and Member Group IDs, to ensure that HHS is collecting sufficient information to ultimately satisfy its statutory obligation to conduct annual audits of claims data in such a way to ensure plans' compliance with ERRP requirements. As a result, in order for claims to be processed, each claims processor needs to have its own real or proxy Member Group ID. Each individual needs to have either one real or proxy Member ID across the plan, or have a separate real or proxy Member ID that corresponds with each discrete Member Group ID.

Answer ID: H300-32
Date Posted: 10/15/2010      Last Updated: 12/30/2010

ANSWER: The Comma Separated Value (CSV) file is also referred to as a "flat file" or "comma delimited file." Computer systems use this type of file to pass information back and forth between databases. Each line represents one entry or record; a comma separates each field within a record. In this case, there will be at least one record for each early retiree that the Plan Sponsor wishes to submit for reimbursement and a comma in-between each of the data elements.

Answer ID: H300-16
Date Posted: 10/01/2010

ANSWER: Yes. Click here for the detailed Early Retiree List format requirements.

Answer ID: H300-17
Date Posted: 10/01/2010

ANSWER: If the Plan Sponsor does not have all of the required information for submitting individual early retirees at this time, gather the missing information and resubmit the missing early retirees in the next full replacement Early Retiree List file.

Important Reminder: ERRP requires that Plan Sponsors include all applicable Early Retirees for the specified Plan Year each time an Early Retiree List is submitted. This means that every Early Retiree who reaches the cost threshold in the Plan Year must be included each time an Early Retiree List is submitted for that Plan Year, even if they were previously submitted. If the Subscriber does not meet the threshold limit but a Member does, the Subscriber record will also need to be submitted on the Early Retiree List, along with the associated Member record. In addition, Plan Sponsors will only be reimbursed for Early Retirees included on the latest Early Retiree List that the ERRP Center has on record. The ERRP Center suggests that each Plan Sponsor routinely review their latest Early Retiree List Response File and verify the counts of ERRP-eligible records against the Current Covered Early Retiree Counts page on the ERRP Secure Website.

Answer ID: H300-18
Date Posted: 10/01/2010      Last Updated: 08/12/2011

ANSWER: A Plan Sponsor can submit an Early Retiree List as often as it likes. Each Plan Sponsor must submit an Early Retiree List as close as possible to when it wishes to submit a reimbursement request.

ERRP requires that Plan Sponsors include all applicable Early Retirees for the specified Plan Year each time an Early Retiree List is submitted. This means that every Early Retiree who reaches the cost threshold in the Plan Year must be included each time an Early Retiree List is submitted for that Plan Year, even if they were previously submitted. If the Subscriber does not meet the threshold limit but a Member does, the Subscriber record will also need to be submitted on the Early Retiree List, along with the associated Member record.

In addition, Plan Sponsors will only be reimbursed for Early Retirees included on the latest Early Retiree List that the ERRP Center has on record. The ERRP Center suggests that each Plan Sponsor routinely review their latest Early Retiree List Response File and verify the counts of ERRP-eligible records against the Current Covered Early Retiree Counts page on the ERRP Secure Website.

Answer ID: H300-19
Date Posted: 10/01/2010      Last Updated: 08/12/2011

ANSWER: If a Plan Sponsor wishes to submit Early Retiree Lists and/or Claim Lists to the ERRP Center via mainframe, and/or receive response files via mainframe, then a Vendor ID will need to be established for the connection. Vendor IDs are assigned by the ERRP Center. Vendors must contact the ERRP Center to establish an ERRP Vendor ID. If a vendor has a Retiree Drug Subsidy Program Vendor ID, they still need to contact the ERRP Center to establish an ERRP Vendor ID.

Answer ID: H300-20
Date Posted: 10/01/2010      Last Updated: 04/17/2011

ANSWER: Some setup is required before a Plan Sponsor can send early retiree files via Mainframe-to-Mainframe. When setting its Early Retiree List Submission Method the Plan Sponsor must identify a Technical Contact and provide the following information about that person: First Name, Last Name, Telephone, Fax, and E-mail Address. The ERRP Center will contact the Technical Contact to setup and test the mainframe connection.

Answer ID: H300-21
Date Posted: 10/01/2010

ANSWER: If a mainframe-submitted Early Retiree List is rejected during the first level of edits (because errors were found in the Header Record, Detail Record, and or Trailer Record), the Plan Sponsor's technical contact will receive a phone call from the ERRP Center. The ERRP Center does not send an Early Retiree List Response File back for a rejected early retiree file that does not pass first level editing. At this point, no records have been accepted.

However, if a Plan Sponsor's early retiree file passes the first level of edits but fails the second level of edits (errors within specific records, such as invalid Application ID, SSN or incorrectly formatted data elements, etc.), the Plan Sponsor will receive an Early Retiree List Response File with reason codes explaining why the records were rejected. A Plan Sponsor must research the data element and corresponding reason code to apply a correction before resubmitting its file to the ERRP Center. It is important that the data elements provided in the early retiree list file, such as date of birth, gender, and SSN, are accurate. After correcting all errors, resubmit the early retiree(s) in your next full replacement of the Early Retiree List.

Answer ID: H300-22
Date Posted:10/01/2010

ANSWER: Each time a Plan Sponsor submits an Early Retiree List, the Plan Sponsor will receive a response (i.e. a Response File) from HHS' ERRP Center with records communicating the periods of time for which each individual is ERRP-eligible, and corresponding reason codes. ERRP Early Retiree List Response File Reason Codes are identification numbers that correspond to a specific message about a record in a response file. Click here for the detailed ERRP Early Retiree List Response File Reason Codes.

An Early Retiree List Response File will be delivered to the Plan Sponsor in a manner consistent with its chosen method of submission. For example, if the Plan Sponsor submitted using an upload to the ERRP Secure Website, then the Response File will be available for download via the ERRP Secure Website. The only exception is if a Plan Sponsor selects: Submission via Plan Sponsor Mainframe to ERRP Data Center Mainframe - Response via ERRP Data Center Mainframe to Plan Sponsor Mainframe with a copy of all Early Retiree List Response Files sent to the ERRP Secure Website. In this case, a Plan Sponsor will be able to access a copy of the Early Retiree List Response File on the Download Early Retiree Response Files page.

Answer ID: H300-23
Date Posted: 10/01/2010

ANSWER: The Early Retiree List Response File contains all of the original fields sent by the Plan Sponsor in the Early Retiree List, plus the response reason code(s) added by the ERRP Center. Click here for the detailed ERRP Early Retiree List Response File Reason Codes. The Plan Sponsor may receive multiple responses (records) for a single early retiree in the event that there is a gap in ERRP eligibility periods.

Note: Early Retiree List Response Files must be reviewed and processed by Plan Sponsors in order to ensure that only those claim costs associated with ERRP-eligible early retirees are included in reimbursement requests.

Answer ID: H300-24
Date Posted: 10/01/2010      Last Updated: 12/02/2010

ANSWER: A plan sponsor will receive an Early Retiree List Response File, from HHS' ERRP Center, following a submission of an Early Retiree List. To the extent a retiree (as opposed to a spouse, surviving spouse, or dependent) on the Early Retiree List is eligible for Medicare coverage during a period of time for which the plan sponsor is seeking reimbursement for that individual, the Early Retiree List Response File will indicate that the individual cannot be claimed for ERRP reimbursement during a period of time when the individual is eligible for coverage under Medicare. Given the complexities of data exchanges between HHS' ERRP Center and the agency that administers Medicare, it is possible that the ERRP-eligible time periods may be adjusted over time to reflect the best available data regarding the retiree's eligibility for coverage under Medicare. For more information regarding Early Retiree List Response Files, please review related materials on the Reference Materials page on this website.

Answer ID: 300-33
Date Posted: 12/02/2010

ANSWER: It takes the ERRP Center approximately fourteen business days to process an Early Retiree List submitted via mainframe. If more than fourteen days pass without receiving an Early Retiree List Response File, contact the ERRP Center for more information.

Answer ID: H300-25
Date Posted: 10/01/2010

ANSWER: When a Plan Sponsor receives its Early Retiree List Response File, the Plan Sponsor must review and process the information as soon as possible. If the Early Retiree List Response File is returned with an early retiree record with a reason code other than zero, a Plan Sponsor must research the data elements in the early retiree record with the corresponding reason code. Click here for the detailed ERRP Early Retiree List Response File Reason Codes.

Answer ID: H300-26
Date Posted: 10/01/2010

ANSWER: In this situation, a Plan Sponsor should verify that the individual's information was entered correctly. If incorrect information was entered, please change the information accordingly and resubmit the corrected record in the next submission of the full replacement Early Retiree List.

If after verifying the early retiree's information, the Plan Sponsor still believes the determination made by the ERRP Center was incorrect, then the Plan Sponsor should contact the ERRP Center.

Answer ID: H300-27
Date Posted: 10/01/2010

ANSWER: In this situation, please verify that the information was entered correctly. In many cases, files with no valid early retirees have an invalid Application ID or a basic formatting problem. If incorrect information was entered, please change the information accordingly and resubmit a full replacement Early Retiree List. Check the reason codes associated with the denied records and trouble-shoot accordingly.

Answer ID: H300-28
Date Posted: 10/01/2010

ANSWER: The Plan Sponsor should contact the ERRP Center to discuss this matter. The ERRP Center will research the determination(s) as necessary and advise the Plan Sponsor accordingly. A Plan Sponsor should continue to resubmit the early retiree(s) while the ERRP Center researches the matter.

Answer ID: H300-29
Date Posted: 10/01/2010

ANSWER: A Plan Sponsor may review the Current Covered Early Retiree Counts page in the ERRP SWS. This page displays the following information about the most recently processed early retiree file, and the count of ERRP-eligible individuals the ERRP Center currently has on record for a given plan year for the Plan Sponsor.

• Application ID
• Application Plan Year
• Application Plan Year Unique Early Retiree Count
• Early Retiree File Last Received Date
• Response File Last Created Date
• Plan Year Early Retiree Count

Note: The Application Unique Early Retiree Count may not match the Early Retiree Count because Early Retirees may not be eligible every month of the Plan Year.

Answer ID: H300-30
Date Posted: 10/01/2010

ANSWER: Four.

Answer ID: H300-31
Date Posted: 10/01/2010

ANSWER: Yes, but only if the individual is considered a "dependent" under the plan's rules.

Answer ID: 300-38
Date Posted: 03/09/2012