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Health Care Alert: Navigating Health Care Reform (May 19, 2010)
HHS Issues Guidance on Early Retiree Reinsurance Program

05/19/2010

On May 3, 2010, the Department of Health and Human Services ("HHS") issued interim final rules implementing the Early Retiree Reinsurance Program ("Program") included in the Patient Protection and Affordable Care Act as amended by the Health Care and Education Affordability Reconciliation Act (collectively, the "Act"). As discussed in our April 2, 2010 Snell & Wilmer Health Care Reform Alert, the Program allocates $5 billion in federal money to reimburse employer sponsored plans for a portion of the cost of providing health benefits to early retirees between the ages of 55 and 64.

The interim final rule is effective June 1, 2010. The Program will end on the earlier of January 1, 2014 or the date HHS exhausts the $5 billion allocated for the Program. Any public comments on the interim final rule must be received by HHS on or before June 4, 2010.

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