May a sponsor submit costs for claims incurred during a plan year that ended before HHS received the plan sponsors ERRP application?
Yes, provided HHS has received or receives the application no later than 60 days after the last day of that plan year, the application is approved (not necessarily within that 60-day period), and all other program requirements are satisfied. This 60-day limit will allow HHS to monitor the disbursement of program funds in order to administer the program in an efficient manner, while providing plan sponsors with a sufficient period during which they can decide whether to submit an application, and request reimbursement, for the applicable plan year (and perhaps subsequent plan years). Of course, a sponsor may submit its application before the last day of the first plan year for which it wishes reimbursement. For sponsors to receive reimbursement for plan years ending on any day from June 1, 2010, through December 31, 2010, the application does not have to be received within 60 days after the last day of the plan year, provided HHS has received or will receive the sponsor’s application by
