As reported earlier, employment-based plans that provide medical coverage to early retirees may be eligible for reimbursement from the federal government under the Early Retiree Reinsurance Program (the “Program"). Because reimbursement will be distributed on a “first come, first served” basis, it is imperative that interested employers/plan sponsors be prepared to submit an application for certification to participate in the Program as soon as HHS begins accepting such applications.
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