A Messsage from Lockton's Health Reform Advisory Group Attorneys: A draft application and set of instructions for the Early Retiree Reinsurance Program (ERRP) has been posted to the website of the Office of Management and Budget (OMB) http://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=201005-0938-012 The U.S. Department of Health and Human Services (HHS) recently issued interim final regulations implementing the program. Our Alert of 5/5/10 discusses those regulations. Please … [Read more...]
HHS Cracks the Door on the Retiree Reinsurance Money Grab
The Department of Health and Human Services (HHS) has issued the first in what promises to be a decades-long series of regulations and other guidance on the new health reform law. The new guidance concerns the temporary $5 billion retiree healthcare reinsurance fund authorized by the health reform legislation. The purpose of the reinsurance fund is to provide an incentive for employers supplying retiree health coverage for certain pre-Medicare-eligible retirees to continue providing that … [Read more...]