Yes. The primary goal of the health reform early retiree medical provision is simply to ensure that retirees younger than age 65 are able to continue medical coverage through their employers when they retire. Therefore, an employer does not have to have a separate plan dedicated strictly to providing "retiree medical coverage" to be eligible for the “Early Retiree Reinsurance Program” under PPACA. An active employee plan that is offered to early retirees also qualifies.
Employers should apply for the program as soon as possible, since the funds allocated for it likely will be exhausted within the next two years, well before the 2014 termination date for the program, according to a study by the Employee Benefit Research Institute. To participate in the program, the employment-based plan must submit an application for certification to the U.S. Department of Health and Human Services. To be certified, the plan must implement programs and procedures to generate cost savings with respect to participants with chronic and high-cost conditions, and provide documentation of the actual cost of medical claims involved.
Source: Act Sec. 1102 of the Patient Protection and Affordable Care Act, as amended by Act Sec. 10102(a).