Here is something I wrote in August of 2004. It might be applicable to what your writing about;
http://nebraskanews.blogspot.com/search?q=retired+peace+officersExcerpt; To my mind the biggest trap in this whole thing (CCCW) is that it requires officers to pay for yearly certification out of their own pocket. This would not be so bad if the now fixed income just had to shell out, say forty or fifty bucks to punch holes in some paper Saturday afternoon.
The Devil is in the details, as they say. The Devil in all of this can be found in 926C section (c) paragraph (5) that reads; during the most recent 12-month period, has met, at the expense of the individual, the State's standards for training or qualification to carry firearms.
Yearly qualification in most if not all departments is not limited to sending 50 or a 100 rounds down range once or twice a year. There is a lot of classroom use of force training written into the yearly qualification for some states.
It has been rumored that one state is in the thought process of complying with H.R. 218 and what they have determined so far is that it will require 80 hours of training billed to the retirees at a rate of 40 dollars per hour. That is 3200 dollars a year folks.
Whether those numbers are true or not is moot, the point is if a state wants to opt out all they have to do is make it so financially prohibitive that no retired Peace Officer could afford it.