Last week, the HHS published an interim final rule for the new Early Retiree Reinsurance Program (should we call it ERRP?).

In our first post on this, we noted that a lot was still unknown.  There still is, but it’s becoming clearer.

The White House fact sheet says “Employers can use the savings to either reduce their own health care costs, provide premium relief to their workers and families or a combination of both”.  But §149.40 of the rules says that the application must also specify “How the sponsor will use the reimbursement to maintain its level of contribution to the applicable plan”.

I’ve had a tough time reconciling those two, but the HHS helps us out:  “For example, for a sponsor that pays a premium to an insurer, if the premium increases, program funds may be used to pay the sponsor’s share of the premium increase from year to year, which reduces the sponsor’s premium
costs.”  For big plans, that premium increase can be a lot of money.