Key legal question
When does the five-year extinction period for a reimbursement claim under KVG/ATSG begin in Tiers garant?
Extracted holding
It begins when the insured receives the physician's invoice; here, receipt on 2007-04-03 made the claim timely on 2012-04-02.
Extracted reasoning
Art. 24 ATSG is not autonomously regulated by insurers. Of the possible reference points, invoice receipt is the only practical and legally certain one for reimbursement claims under Art. 42 KVG.