ERRP Program Highlights

Claim List Response Files

The ERRP Center is now sending Claim List Response Files (CLRFs). To assist Plan Sponsors in understanding CLRFs, the ERRP Center has published the CLRF Reference Guide, CLRF Layout, and CLRF Reason Codes on the Reference Materials page. In addition, a number of new Claim List Response File-related questions have been added to the Claim List Common Questions.

Data Inaccuracies and Reopening and Appeals Guidance Documents

On October 1, the ERRP Center published two new guidance documents. Explanation of the Processes for Reporting Early Retiree and Claims Data Inaccuracies, and for Reopening discusses the manner and timing for reporting and correcting inaccuracies with previously submitted data. The guidance also describes the process for instances when CMS reopens and revises a reimbursement determination on its own volition or upon request of a Plan Sponsor. Explanation of the Appeals Process for the Early Retiree Reinsurance Program provides guidance regarding how a Plan Sponsor can submit a request for appeal of an adverse reimbursement determination and also describes how the appeals process works.

Reporting Rebates and Price Concessions

On June 7, 2011, CMS published guidance on how to report post-point of sale negotiated price concessions, such as rebates on prescription drugs. The guidance, Allocating Post-Point of Sale Negotiated Price Concessions to Individual Early Retirees Under the Early Retiree Reinsurance Program, assists Plan Sponsors in determining how much of a particular price concession should be allocated to a given early retiree. The guidance references an additional Claim List Cost Adjustment Layout for reporting price concessions applied to costs incurred before June 1, 2010. Price concessions occurring on claims incurred prior to June 1, 2010 must be reported separately from those occurring on or after June 1, 2010.

ERRP Eligible and Ineligible Claims Guidance Updated

ERRP guidance documents offer important information, such as which items and services are ineligible for reimbursement under the ERRP. On July 18, 2011, the ERRP Center updated the Procedure Codes Ineligible for Reimbursement guidance document and published new program guidance, Supplemental Guidance: Additional Coding Details for Ineligible Items and Services. Plan Sponsors are encouraged to carefully review the guidance for important information regarding excluded items and services.