Employers with Retirees must apply for part of the $5 billion dollar Subsidy for Retiree Coverage


By Mark Stember, JD


Although applications for the early retiree reimbursement program will not be available until the end of June, today HHS released interim final regulations establishing the early retiree reinsurance program.  The PPACA appropriates funding of $5 billion for the temporary program, which begins on June 21, 2010 and ends no later than January 1, 2014.  The program provides reimbursement to participating employment-based plans for a portion of the cost of health benefits for early retirees and their spouses, surviving spouses and dependents. The Secretary will reimburse plans for certain claims between $15,000 and $90,000 (with those amounts being indexed for plan years starting on or after October 1, 2011).

Additional details will be forthcoming as we work our way through the regulations.



Mark  L. Stember
Kilpatrick Stockton LLP
Suite 900
607 14th Street, NW 
Washington, DC 20005
t 202 508 5802
f 202 585 0018