In preparing to implement the January 1, 2014 sunset date on ACA's Early Retiree Reinsurance Program (ERRP), the Centers for Medicare & Medicaid Services (CMS) published a notice regarding termination dates of certain operational processes under the program including:

These deadlines and the sunsetting of the ERRP program have no impact upon plan sponsors' obligation to retain plan-related records for six years after the expiration of the plan year during which the costs were incurred, or longer if otherwise required by law. Read more.

• Submission of changes to plan sponsor ERRP applications (December 31, 2013 unless subject to an active audit, in most cases);

   

  • Reporting of plan sponsor ownership changes (not required for any ownership change that will take effect after December 31, 2013);
  • Submission of reimbursement requests (July 31, 2013);
  • Reports or requests to correct data (July 31, 2013); and
  • Submission of requests to reopen reimbursement determinations (December 31, 2013).