How have the courts interpreted the meaning of the word 'expense' in the context of a government employee's insurance policy?

1 The insurer argues that the government has incurred no 'expense' since it has not paid money to the injured parties for medical services. However, we are persuaded that 'expense' has been incurred whether it be in the form of cash or, as here, services rendered. See, e.g., United States v. Government Employees Insurance Co., 461 F.2d 58 (4th Cir. 1972).

2 In United States v. Nationwide Mutual Ins. Co., 499 F.2d 1355, 1358--59 (9th Cir. 1974), a divided panel of this court remanded for the purpose of ascertaining whether the United States was an 'intended' third party beneficiary under the policy at issue. In the instant case, the plain language of the policy protects the United States as an 'insured.' There is in this case no need to consider whether it was 'intended' that the United States be a third party beneficiary.