May a sponsor submit a reimbursement request for a given plan year after the plan year ends?
Yes, subject to the restrictions in Common Question H200-50. While reimbursement requests for a given plan may only be submitted once per calendar year quarter for each plan year, until the program ends or such time that HHS discontinues accepting reimbursement requests, allowing reimbursement requests after the close of a sponsor’s plan year enables the sponsor to initially submit or update their Early Retiree Lists, Summary Cost Data and Detailed Claims Data, if necessary.