Do the $15,000 cost threshold and $90,000 cost limit apply separately to each individual for whom a plan sponsor is submitting reimbursement requests under the Early Retiree Reimbursement Program?
Yes. The interim final regulation at 45 C.F.R. 149.115 states that the cost threshold and cost limit apply individually, to each early retiree, as that term is defined in 45 C.F.R. 149.2, and a sponsor is reimbursed for each individual separately. The interim final regulation’s definition of “early retiree” at 45 C.F.R. 149.2 establishes that, for purposes of the program, a spouse, surviving spouse, and dependent of an early retiree are each individually considered an early retiree under the program, provided the early retiree, early retiree’s spouse, surviving spouse or dependent are enrolled in the certified employment-based plan.
Related Questions
- Is there a cost limit for an early retiree or early retirees spouse, surviving spouse or dependent, for whom a plan sponsor is requesting reimbursement under the Early Retiree Reinsurance Program?
- For an individual who has exceeded the cost limit, what amount must be included in the total Limit Reduction amount field when reporting Summary Cost Data?
- Can costs for prescription drugs count toward the cost threshold and cost limit, and be reimbursed?
