Under the Patient Protection and
Affordable Care Act (P.L. 111-148) and implementing regulations at
45 CFR Part 149, employment-based plans that offer health coverage
to early retirees and their spouses, surviving spouses, and
dependents are eligible to receive tax-free reimbursement for a
portion of the costs of health benefits provided to such
individuals. To qualify, a plan sponsor must submit a complete
application to HHS, and must submit reimbursement requests that
consist of a list of individuals for whom reimbursement is sought,
and documentation of the costs of health benefits
provided.
The original PRA package
for the Early Retiree Reinsurance Program (ERRP) was approved in
May 2010 on an emergency basis, and expires November 30, 2010. The
original, approved PRA package was developed in April 2010 with
certain assumptions about how the program would operate. However,
as this program quickly developed, unforeseen circumstances have
dictated that HHS must collect certain data that it did not foresee
having to collect, or which HHS must collect in a manner not
envisioned at the time the original package was developed, by
October 1, 2010. In fact, the Administration now wants ERRP plan
sponsors to be able to begin submitting, on October 1 2010, lists
of early retirees for whom the sponsors wish to submit their first
reimbursement request under the program, as well as summary claims
data upon which the reimbursement requests would be based. However,
the currently approved PRA package does not specify the necessary
data elements that have since been developed for early retiree
lists, nor does it envision the collection of summary claims data,
or the required elements to collect with respect to such data.
Therefore, in order to be able to meet the Administration's
objectives specified above, we request emergency approval of the
accompanying revisions to OMB 0938-1087, by September 30,
2010.
The overall burden hour change
is largely attributed to the fact that HHS will now be requiring
sponsors to submit summary cost data (as well as line-item cost
data) with respect to each reimbursement request, and that sponsors
will have to scrutinize cost data to ensure that the sponsor is
only submitting costs for items and services that Medicare would
cover. This has caused the first-year burden estimate for
submitting reimbursement requests to increase by 88 hours (from 90
hours, to 176 hours).
$20,000,000
No
No
Yes
Uncollected
No
Uncollected
William Parham
4107864669
No
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
Data Inaccuracies (Private)