Your company has applied for the Early Retiree Reinsurance Program (ERRP) under which it can be reimbursed for part of the claims cost of providing health insurance coverage to early retirees, eligible spouses, surviving spouses, and dependents of such retirees. One of your early retirees has a 53-year-old wife who is enrolled in your group health plan. Despite her younger age, can she be considered an “early retiree” for purposes of the ERRP?
Yes. An “early retiree” means a plan participant who is:
- age 55 and older and enrolled for health benefits in a certified employment-based plan;
- not eligible for coverage under Medicare; and
- not an active employee of an employer maintaining, or currently contributing to, the employment-based plan or of any employer that has made substantial contributions to fund such plan.
The term “early retiree” also includes the enrolled spouse, surviving spouse, and dependents of such individuals. The age and Medicare-status requirements are only applied to the individual through whom the spouse, surviving spouse, or dependent receives health benefits — not to the spouse, surviving spouse, or dependent.
Spouses, surviving spouses, and dependents must be enrolled in an ERRP-approved plan and have claims for health benefits (as defined in the regulations and HHS guidance) in excess of the cost threshold for a given plan year in order for a sponsor to get credit toward the cost threshold and to receive reimbursement for eligible claims for such individuals.
Source: Common Questions, Early Retiree Reinsurance Program, Answer ID: 300-34, December 30, 2010.