Crosswalk of Changes

CMS-10408_ERRP_Survey_Crosswalk_of_Changes_FINAL.pdf

Early Retiree Reinsurance Program: Survey of Plan Sponsors

Crosswalk of Changes

OMB: 0938-1150

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Crosswalk of Changes Between Existing Collection Instrument, and Revised Collection
Instrument
NOTE: this Crosswalk covers the email that will link to the collection instrument, as well as the
collection instrument itself. All question numbers refer to questions in the revised collection
instrument submitted with this information collection request, unless otherwise specified.
Email that will link to the Collection Instrument
Plan sponsors that have not previously completed the prior version of the survey, will be sent an
email that is almost identical to the email that was submitted as part of the information collection
request for the discontinued version of the survey. The only substantive differences are as
follows:
The new version of the email will include the plan sponsor’s prepopulated 10-digit
application ID number, which the sponsor can cut and paste as the answer to the survey
question that asks for this number.
The new version of the email will ask plan sponsors to provide their response to the
survey within 30 days, (However, as with the prior version of the survey, there is no
obligation to respond).
Neither of these changes will materially add to, nor materially diminish, burden.
Plan sponsors that have previously completed the prior version of the survey, will be sent a
version of the email that adds two short paragraphs. One that explains why they are being
resurveyed, and one that explains the circumstance under which they should not retake the
survey, and how they should respond to the email in such circumstances. The addition of these
two paragraphs will add to burden only nominally.
Collection Instrument
Summary of changes:
In revising the survey, we propose to add one new question to the survey, and clarify the
instructions to several questions. In addition, we have made several formatting changes to the
survey to make it easier for sponsors to respond, to significantly reduce the number of
ambiguous or nonsensical responses, and to significantly reduce the burden imposed on HHS for
compiling and assembling data from the responses. Collectively, we do not believe these changes
will materially add to, or materially diminish, the burden imposed on respondents.
The changes are more specifically set forth below:

Before Question 1, we have inserted a sentence suggesting that plan sponsors read the survey
before completing it. We expect that inserting this sentence will nominally reduce burden, as the
increase in burden of reading through the survey will lead to a slightly greater decrease in burden
attributable to being familiar with the questions before attempting to answer them.

Question 2
We are instructing the sponsor to copy and paste the 10-digit application ID number from the
accompanying email, into the answer space for this question. We believe this will slightly
diminish burden.
Question 3
We are clarifying in the question that the response should reflect the number of plan participants
in the applicable plan, as of the day you are completing this survey. This change has no impact
on burden.
Question 4
We are clarifying in the question that the response should reflect the number of early retirees in
the applicable plan, as of the day you are completing this survey, and also rephrasing the
question for purposes of clarify. These changes have no impact on burden.
Question 5
We are clarifying that this question asks about ERRP funding received in calendar year 2010,
and that in asking in which year they applied or intend to apply ERRP funds, we mean “spend”.
We are also instructing sponsors to skip the question if they did not receive any ERRP
reimbursement in CY 2010, and that adding up the responses to all plan years should total 100%.
Most importantly, sponsors will be asked to select their responses from a drop-down box, rather
than type in a numeric response. Collectively, we do not believe these changes will materially
add to, or materially diminish, burden.
Question 6
With respect to this question about ERRP funds received in CY 2011, we are making the same
clarification as in Question 5. Collectively, we do not believe these changes will materially add
to, or materially diminish, burden.
Question 7
This question is new. It is similar to Questions 5 and Question 6, but asks about ERRP funding
received in calendar year 2012. (Question 5 and Question 6 ask about ERRP funding received in

calendar year 2010 and 2011, respectively). We estimate this Question to increase burden by 1
hour, but expect that burden to be largely offset by the fact that many sponsors that respond to this
question, will not be updating their responses to Questions 5 and/or 6.
Questions 9 and 10
Questions 8, 9, 10, 11 and 12 in the former version of the survey, have been collapsed into what
are now Questions 9 and 10. Also, drop-down boxes with answers for sponsors to select, have
replaced answer fields into which sponsors had entered numeric responses. Collectively, we do
not believe these changes will materially add to, or materially diminish, burden.
Questions 11 and 12
Questions 13, 14, 15, 16 and 17 in the former version of the survey, have been collapsed into
what are now Questions 11 and 12. Also, drop-down boxes with answers for sponsors to select,
have replaced answer fields into which sponsors had entered numeric responses. Collectively,
we do not believe these changes will materially add to, or materially diminish, burden.

Instructions for Questions 3 and 4
We have added part of the definition of “early retiree”. We do not believe that this will impact
burden, as we believe sponsors will continue to consult the full regulatory definition of “early
retiree”.

Instructions for Questions 5 and 6
We have clarified that this set of instructions also applies to new Question 7. We have also
clarified what it means to have “received” ERRP funding in a given calendar year. We have also
added instructions for how a sponsor should round its answers, and clarified that all the sponsor’s
answers for each question should total 100. We do not believe this will impact burden.
Instructions for Question 9
Questions 8, 9, 10, and 11 of the expired version of the survey, have been collapsed into
Question 9. Therefore, we collapsed the instructions for all those questions, into the instructions
for question 9. We have also clarified that, for purposes of this survey, benefit-specific
deductibles, such as a prescription drug deductible (as opposed to overall deductibles) are
considered a type of “other out-of-pocket costs” referenced in Question 10.

Instructions for Question 11
Questions 13, 14, 15, 16 of the expired version of the survey, have been collapsed into Question
11. Therefore, we collapsed the instructions for all those questions, into the instructions for
question 11. We have also clarified that, for purposes of this survey, benefit-specific deductibles,
such as a prescription drug deductible (as opposed to overall deductibles) are considered a type of
“other out-of-pocket costs” referenced in Question 12.


File Typeapplication/pdf
File TitleCrosswalk of Changes Between Existing Collection Instrument, and Revised Collection Instrument
SubjectCrosswalk of Changes Between Existing Collection Instrument, and Revised Collection Instrument, Crosswalk of Changes, Existing C
AuthorHHS/CMS/CCIIO
File Modified2012-09-11
File Created2012-09-10

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