Here is what the folks who wrote the regulations regarding the early retiree reinsurance program say about what you need to be reimbursed for the portion of a claim paid by the retiree:

Prima facie evidence that early retiree (or the early retiree’s spouse, surviving spouse or dependent) paid his or her share of the costs

(if the sponsor is requesting credit or reimbursement for the amounts paid by these plan participants).

 

The key word here is “paid” as opposed to incurred.  What they are talking about is getting a receipt to prove the out of pocket cost was paid by the retiree (no kidding) although they are looking for ideas on how else the evidence can be provided.

I can just see it now, millions of retirees receiving a letter form their former employer that starts out:

“We hate to bother you, but we need your receipts for the coinsurance, co-payments and deductible you paid for health care you received since the first of the year.”  “Cancelled checks, credit card statements or a note from your doctor will do…we think.”  Why, you may ask, well so your former employer can get reimbursed by the federal government for bills that you actually paid.”