Posts Categorized: Retiree Benefits

CMS Closes ERRP Program

in Retiree Benefits

This afternoon CMS announced that it will not accept claims for ERRP reimbursement, if the claim is incurred on January 1, 2012 or later. However, claims incurred before January 1, 2012 and paid on or after January 1, 2012 may be submitted after the claim is paid based on current ERRP guidelines. A portion of the CMS announcement is appended as follows: CMS is exercising our authority under 45 CFR 149.45(a) to deny certain reimbursement requests based on the available amount remaining of the $5 billion in appropriated program funding, and the rate at which it is being disbursed. We… Continue Reading

Retiree Medical Liabilities

in Retiree Benefits

The accounting rules for valuing OPEB liabilities may be revised soon to take into account other promises that the employer has made to employees or in certain situations a course of prior conduct. For some companies, this may mean their overall liability is increased, while in other situations it may provide a decrease in liability.  It appears this change is being contemplated to arrive at a “truer” picture of OPEB liability.   See the article in the attached link for more information.  NAIC panel wrestles with retiree benefits accounting

EBSA Electronic Distribution Rules

in Health Benefits, Retiree Benefits, Welfare Benefits

Today, EBSA posted all of the public comments received with respect to electronic distribution of benefit plan information. There are many great comments in this listing, including Kilpatrick’s comments listed as Number 32.  Although DOL is still reviewing the comments, DOL is apparently focusing on other plan materials (such as 401k statements for example) that can be delivered electronically, rather than SPDs and SMMs.  It’s unclear whether this is because DOL already has decided to adopt separate rules depending on the type of document to be transmitted.  DOL has said that proposed regulations could be issued by the end of… Continue Reading