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com] Sent: Wednesday, December 29, 2010 5:46 PM To: HHS HealthInsurance (HHS); OCIIO Oversight Cc: Sharon M. Goodman; William H. Tobin; Scott.Weltz@Milliman.com Subject: waiver Attachments: 1-334178-Local_400_PPACA_Waiver_Application.pdf; 1-333599Local_400_Waiver_Chart_Explanatory_Memorandum.doc; 1-334289Local_400_Waiver_Application_Chart.xls
Mr. Mayhew:
III. The Fund is a Taft-Hartley employee welfare benefit plan. The effective dates and expiration dates of theprincipal collective bargaining agreement covering Ex. % of all participants in the Fund are as follows: 10/14/2007-10/15/2011. 4
Best regards, Danielle Norris Danielle T. Norris Attorney At Law Slevin & Hart, P.C. 1625 Massachusetts Ave., N.W., Suite 450 Washington, D.C. 20036 202-797-8700 Tel 202-234-8231 Fax dnorris@slevinhart.com
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UFCW L400:000001
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II. The Fund was in existence prior to March 23, 2010. It is our understanding thatall the Fund's Plans meet the requirements of a "grandfathered plan," as that term is used in applicable regulations. The Plans are prepared to comply with the PPACA requirements applicable to grandfathered plans, effectiveFebruary 1, 2011.
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Attached please find an Application for Waiver of the PPACA Lifetime Limits Prohibition, filed on behalf ofthe United Food and Commercial WorkersLocal 400 and Employers Health and Welfare Fund ("Fund"). In addition to the Application, please note the following:
December 16,2010
SENT
BY
E-MAIL
(e-mail: healthinsurance~hhs.gov)
Re:
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Department of Health and Human Services Office of Consumer Information and Office of Oversight ATTN: James Mayhew, Room 737-F-04 200 Independence Avenue, SW Washington DC 20201
Waiver - Restricted Annual Limits for Fund Year Beginning February 1,2011
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400
400 and Employers
UFCW L400:000002
The Board of Trustees of the United Food and Commercial Workers Local
and Employers Health and Welfare Fund (the "Trustees") is the plan sponsor and plan
Health and Welfare Fund (the "Fund"). The Fund is a multiemployer plan with a Plan Year beginning February 1, 2011. The Fund provides health and welfare benefits to
employees and their dependents who are covered by collective bargaining agreements
negotiated by employers contributing to the Fund and United Food and Commercial
Workers Union Local
paid only from these assets. The Fund offers health and welfare benefits to part-time and
Employer and employee contribution rates are set by collective bargaining agreements negotiated by the Bargaining Parties. Thus, the Trustees administer the Fund and set benefits based on the limited pool of assets available to them. The Trustees have no legal abilty to require any increase in the contributions to the Fund in excess of the rates provided for under the collective bargaining agreements.
The Trustees are required to administer the Fund consistent with their fiduciary duties under the Employee Retirement Income Security Act of 1974 ("ERISA") and the Fund's governing documents. With the help and direction of the Bargaining Parties, the Fund's Trustees have created and administered the Fund's Plan of benefits, in the manner
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Board of Trustees, which consists of both Union and Employer representatives selected by the Union and the Employers which have entered into collective bargaining agreements relating to the Plan. All health benefits under the Fund are self-funded and
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Department of Health and Human Services Office of Consumer Information and Office of Oversight ATTN: James Mayhew
December 16,2010
Page 2
confines of the Fund's assets, while limiting the out-of-pocket costs payable by
participants and dependents. ERISA requires that the Trustees take those actions that are
necessary and appropriate pursuant to their fiduciary duties to safeguard the Fund's
contributions wil not occur until the current collective bargaining agreements expire.
This of course limits the Trustees' abilty to fund the costs of the mandated enhanced
benefits required under the Patient Protection and Affordable Care Act ("PPACA").
Further, faced with such dramatic increases in costs, employers also may attempt to negotiate out of the Plan or try to eliminate some coverage altogether. The effect of not
expiring contracts wil lose some access to coverage or wil have to shoulder a larger
burden in paying for such coverage. This is particularly troublesome given that coverage is provided to a significant percentage of part-time employees who would otherwise have no access to affordable quality health care. Indeed, because of the strains the restricted annual limits place on the collective bargaining process, there is an increased possibilty
that participants wil
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benefits and specific maximums for which waivers are being sought are set forth in Exhibits A-D attached hereto, to the extent that such maximums are on essential benefits under the PPACA. For clarification purposes, these are designations given by the Fund to the different programs of benefits provided to different classes of employees and retirees:
The classes of
Plan 1
Plan 500
Plan V
Plan S
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receiving a waiver from the restricted annual limits is the prospect that participants under
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that they believe best serves the Fund's participants and dependents and best uses the resources available to fund such benefits. The annual and lifetime limits on certain benefits exist to enable the Fund to provide a full range of benefits and options within the
UFCW L400:000003
Department of Health and Human Services Office of Consumer Information and Office of Oversight ATTN: James Mayhew
December 16, 2010
Page 3
1. Annual Limits.
The Fund provides benefits for a number of classes of individuals covered by the
Fund as set forth in the attached exhibits. Since the Employer contribution rates and
The Trustees have reviewed the cost of increasing the annual benefit limits to comply with the requirements of PP ACA. The Trustees have concluded that increasing the annual benefit maximum to $750,000 per year for the Plan Year beginning February 1, 2011 for all benefit programs wil increase Fund costs significantly, as calculated by the
Fund's consultant. This rise in costs would unexpectedly deplete Fund assets and
reserves. To offset this increase in costs, benefit changes, such as the type and magnitude described in the attached exhibits likely would be required. Accordingly, compliance
with PP ACA's annual benefit limit requirements can be expected to result in a significant
results.
2. Lifetime Limits.
and Health and Human Services, 75 Fed. Reg. 37187 (June 22, 2010), ("Regulations") discuss waivers of the annual limit requirements under Section 1001 of the PP ACA, it
also would be consistent with the purpose of the waiver provision to grant a waiver of the requirement that the Fund eliminate its lifetime limits. The Preamble to the Regulations
indicates that the purpose of the waiver program is to mitigate any unintended
the PPACA's application to plans with low benefit limits. See 75 Fed. Reg. 37187, 37207. The Plans, particularly the retiree programs, have several benefits
consequences of
limits that are low enough to be in the nature of annual limits (for example, all of the
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While the interim final rules issued by the Departments of the Treasury, Labor,
such lifetime limits, such a change likely wil have the direct and unintended
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decrease in access to benefits for those currently covered by the classes of benefits set forth in the attached exhibits and/or a significant increase in premiums paid by those covered by such classes of benefits upon expiration of the current collective bargaining agreements, if not sooner. This waiver application is submitted in order to avoid these
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participant cost-sharing amounts relating to the benefits described in Exhibits A to Dare fixed under the collective bargaining agreements, the Fund has no abilty to increase its source of funding from employers.
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UFCW L400:000004
Department of Health and Human Services Office of Consumer Information and Office of Oversight ATTN: James Mayhew
December 16, 2010
Page 4
participant cost-sharing for the affected benefits, effective February 1, 2011. Thus, the
Fund's lifetime limits are precisely the types of limits for which Congress intended to
offer relief via the waiver program.
To the extent that the Department of Health and Human Services would deny
the Fund's request for a waiver for its lifetime limits but would grant a waiver for
such limits if they are converted to annual limits as permitted under PP ACA, we
hereby request such a waiver on the grounds that the Board of Trustees wil adopt a
resolution to convert its lifetime limits to annual limits, effective February 1,2011.
Attestation: The undersigned, on behalf of the Board of Trustees, hereby certifies the following:
1. That the Fund was in force prior to September 23, 2010; and
2. That the application of restricted annual limits to the classes set forth in the
attached exhibits is expected to result in a significant decrease in access to benefits for those currently covered by such classes or a significant increase in premiums paid by
those covered by such classes.
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Thank you for your consideration. Please contact the Fund's legal co-counsel, Wiliam Tobin at Reinhart Boerner Van Deuren s.c. (414-298-1000) or Sharon Goodman at Slevin and Hart (202-797-8700) with any questions or requests for additional information.
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Sincerely,
By: '-
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Steve~ L er
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consequence of significantly decreasing participants' access to benefits or significantly increasing the cost of those benefits. Absent waiver, the Board of Trustees likely wil be
UFCW L400:000005
Health and Human Services Office of Consumer Information and Office of Oversight ATTN: James Mayhew
Department of
Thomas P. McNutt
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UFCW L400:000006
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Attachments
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By:~?ff~
EXHIBIT A
Plan 1
CONVALESCENT CARE
DIABETES EDUCATION
DENTAL
VISION CARE
PHYSICAL EXAMINATION
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LIFETIME
PODIATRIST SURGERIE
HOSPICE CARE $5
5263716 A-
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Ex. 4
Ex. 4
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LrMITS
UFCW L400:000007
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Ex. 4
employees.
..
..
BIFE'lII\LIMITS
Ex. 4
GROWTH HORMONES
HEARING AIDS
Premium.
(a) Anual Limits. If
the Fund is required to remove the annual limits above, the Trustees likely would be required to consider significant benefit changes in
the following changes could be needed to offset the cost of increasing this program's the waiver is not granted (incorporating an increase from an annual maximum of $Ex. 4 the Trustees were to convert the current lifetime maximum to an anual maximum in the event HHS does not grant a waiver with regard to the lifetime maximums as requested below):
annual maximums to $750,000 for the Plan Year beginning February 1,2011, if $750,000 if
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(from $Ex. 4
order to offset these increased costs. For example, the Fund's consultant estimates that
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.
4.
to
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2011, if
annual and lifetime limits above, the Fund's consultant estimates that the following changes could be needed to offset both costs for the Plan Year beginning February 1, the above lifetime
the waiver is not granted (incorporating the conversion of
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lifetime limits above, the Trustees likely would be required to consider significant benefit changes in order to offset these increased costs. For example, the following changes could be needed to offset the cost of eliminating this program's lifetime maximums for the waiver is not granted:
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A-
(from $ Ex. 4
5263716
UFCW L400:000008
The Trustees believe the magnitude of the changes discussed above constitutes a significant decrease in access to benefits for those currently covered by the Plan 1.
Additionally, the Trustees expect the bargaining parties would consider negotiating
increases in the premiums paid by employees covered by Plan 1 at the time of the expiration of the current collective bargaining agreements due to the increased costs
attributed to higher annual benefit limits being extended to Plan 1 participants.
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A-
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UFCW L400:000009
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Accordingly, the Trustees request a waiver from the increase in the annual and lifetime essential benefit limits under PP ACA. Specifically, the Trustees request that Plan 1 be allowed to maintain all limits set forth in #3 above for the Plan Year beginning February 1, 2011. In the event that the requested waiver with regard to lifetime limits is denied, the Trustees request that Plan 1 be allowed to maintain the annual limits set forth
for the Plan Year beginning
EXHIBIT B
Plan 500
1.
Terms. Plan 500 covers employees who have less then Ex. 4 years of
seniority .
3. Current Annual and Lifetime Limits and Rates. Plan 500 provides for
limits on benefits as set forth in the Plan document. Select pertinent benefit provisions follow:
Ex. 4
. DIABETES EDUCATION
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HOSPICE CARE
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Ex. 4
LIFETIM LIMITS
Ex. 4
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UFCW L400:000010
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Ex. 4
employees.
Ex. 4
GROWTH HORMONES
4.
Premium.
above, the Trustees likely would be required to consider significant benefit changes in
order to offset these increased costs. For example, the Fund's consultant estimates that
the following changes could be needed to offset the cost of increasing this program's annual maximums to $750,000 for the Plan Year beginning February 1, 2011, if the
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). ).
(a) Anual Limits. If the Fund is required to remove the annual limits
to
$750,000 if the Trustees were to convert the current lifetime maximum to an annual maximum in the event HHS does not grant a waiver with regard to the lifetime maximums as requested below):
Increase annual deductible to $Ex. 4 (from $ Ex. 4 ).
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Limits. If
lifetime limits above, the Trustees likely would be required to consider significant benefit changes in order to offset these increased costs. For example, the following change could be needed just to offset the cost of eliminating this program's lifetime maximums for the
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Ex. 4
the Fund is required to remove the annual and lifetime limits above, the Fund's consultant estimates that the following changes could be needed to offset both costs for the Plan Year beginning February 1, 2011, if the waiver is not granted (incorporating the conversion of the above lifetime maximums to annual maximums):
(c) Combined Impact of
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(from $Ex. 4 (from $Ex. 4
.
Ex. 4
(from $ Ex. 4
).
The Trustees believe the magnitude of the changes discussed above constitutes a
significant decrease in access to benefits for those currently covered by Plan 500.
Additionally, the Trustees expect the bargaining parties would consider negotiating
5263716
B-
UFCW L400:000011
increases in the premiums paid by employees covered by Plan 500 at the time of the expiration of the current collective bargaining agreements due to the increased costs
attributed to higher annual benefit limits being extended to Plan 500 participants.
Accordingly, the Trustees request a waiver from the increase in the annual and lifetime essential benefit limits under PP ACA. Specifically, the Trustees request that
Plan 500 be allowed to maintain all limits set forth in #3 above for the Plan Year
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beginning February 1, 2011. In the event that the requested waiver with regard to lifetime limits is denied, the Trustees request that Plan 500 be allowed to maintain the annual limits set forth in #3 above, including an annual maximum of $ Ex. 4 for the Plan Year beginning February 1,2011.
EXHIBIT C
Plan V
1. Terms. Plan V generally covers retirees prior to age 65.
employees.
Ex. 4
Ex. 4
PODIATRIST SURGERIES
HOSPICE CARE
GROWTH HORMONES
Premium.
limits above, the Trustees likely would be required to consider significant benefit changes
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Ex. 4
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CUFCW L400:000013
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3. Current Anual and Lifetime Limits and Rates. Plan V provides for limits on benefits as set forth in the Plan document. Select pertinent benefit provisions follow:
in order to offset these increased costs. For example, the Fund's consultant estimates that
the following changes could be needed to offset the cost of increasing this program's
annual maximums to $750,000 for the Plan Year beginning February 1, 2011, if the
waiver is not granted (incorporating an increase from an annual maximum of $ Ex. 4 to
$750,000 if the Trustees were to convert the current lifetime maximum to an annual maximum in the event HHS does not grant a waiver with regard to the lifetime maximums as requested below):
Increase annual deductible to $Ex. 4 (from $Ex. 4 ).
(from $Ex. 4
lifetime limits above, the Trustees likely would be required to consider significant benefit
could be needed to offset the cost of eliminating this program's lifetime maximums for the waiver is not granted:
(from $Ex. 4 ).
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changes could be needed to offset both costs for the Plan Year beginning February 1,
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(from $ Ex. 4 (from $ Ex. 4
changes in order to offset these increased costs. For example, the following changes
(from $ Ex. 4 ).
.
significant decrease in access to benefits for those currently covered by Plan V. Additionally, the Trustees expect to consider increases in the premiums paid by retirees
covered by Plan V due to the increased costs attributed to higher annual benefit limits being extended to Plan V participants.
Accordingly, the Trustees request a waiver from the increase in the annual and
lifetime essential benefit limits under PP ACA. Specifically, the Trustees request that limits set forth in #3 above for the Plan Year beginning February 1, 2011. In the event that the requested waiver with regard to lifetime limits is denied, the Trustees request that Plan V be allowed to maintain the annual limits set forth
Plan V be allowed to maintain all
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The Trustees believe the magnitude of the changes discussed above constitutes a
February 1,2011.
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UFCW L400:000014
EXHIBIT D
Plan S
1. Terms. Plan S generally covers retirees over age 65. 2. Number of Individuals Covered. Plan S currently covers approximately
Ex. 4
employees.
on benefits as set forth in the Plan document. Select pertinent benefit provisions follow:
Ex. 4
Ex. 4
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..
..
...
...
LIFETIME LIMITS
Ex. 4
Premium.
(a) Annual Limits. If the Fund is required to remove the annual limits above, the Trustees likely would be required to consider significant benefit changes in
order to offset these increased costs. For example, the Fund's consultant estimates that
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UFCW L400:000015
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3. Current Annual and Lifetime Limits and Rates. Plan S provides for limits
the following changes could be needed to offset the cost of increasing this program's anual maximums to $750,000 for the Plan Year beginning February 1, 2011, if the
to
$750,000 if the Trustees were to convert the current lifetime maximum to an annual maximum in the event HHS does not grant a waiver with regard to the lifetime
maximums as requested below):
lifetime limits above, the Trustees likely would be required to consider significant benefit
the Plan Year beginning February 1, 2011 if the waiver is not granted:
Increase annual deductible to $Ex. 4 (from $Ex. 4 . Increase annual out-of-pocket maximum to $Ex. 4
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(from $Ex. 4 (from $ Ex. 4
changes in order to offset these increased costs. For example, the following changes could be needed to offset the cost of eliminating this program's lifetime maximums for
changes could be needed to offset both costs for the Plan Year beginning February 1,
maximums to annual maximums):
Additionally, the Trustees expect to consider increases in the premiums paid by retirees
covered by Plan S due to the increased costs attributed to higher annual benefit limits being extended to Plan S participants.
Accordingly, the Trustees request a waiver from the increase in the annual and lifetime essential benefit limits under PP ACA. Specifically, the Trustees request that limits set forth in #3 above for the Plan Year beginning February 1, 2011. In the event that the requested waiver with regard to lifetime limits is denied, the Trustees request that Plan S be allowed to maintain the annual limits set forth
Plan S be allowed to maintain all
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The Trustees believe the magnitude of the changes discussed above constitutes a significant decrease in access to benefits for those currently covered by Plan S.
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2011, if the waiver is not granted (incorporating the conversion of the above lifetime
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).
(from $Ex. 4
).
UFCW L400:000016
United Food and Commercial Workers Local 400 and Employers Health and Welfare Fund
Waiver of Annual Limits Requirements Attachment to Application General The attached spreadsheet has been prepared in a good faith effort to comply with the published requirements for applying for a waiver from PPACA's annual limits. The spreadsheet has been completed in as broad and comprehensive a manner as possible, but its fields should not be interpreted as confirmation that a given benefit is an essential benefit or a benefit for which a waiver is required. Despite the answers given on the spreadsheet, the titles to a number of columns do not fit with the nature of the Fund as a multiemployer plan, as more fully explained below and in the letter enclosed with these materials. That letter provides a more detailed explanation regarding the application, and we refer HHS to that letter for important information regarding the application which cannot be adequately expressed in the spreadsheet. Column AK - AU
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Each of the benefit packages referenced in the United Food and Commercial Workers Local 400 and Employers Health and Welfare Funds waiver application is part of a self insured, multiemployer Taft-Hartley health and welfare fund. Employer contribution rates and Employee contribution rates applicable to certain active employees are established in Collective Bargaining Agreements (CBA) between the Funds contributing employers and the Local Union. As such, employer and employee contributions and coverage tiers vary depending upon the CBA terms. The Trustees who serve as the Fund's administrator and the bargaining parties are bound by the negotiated rates in the CBAs, until the expiration dates of the CBAs. The Trustees also cannot speculate as to whether and how any increased contributions needed to offset the cost of complying with the $750,000 annual limits would be assigned between participants or employers. The principal CBA covering Ex. 4% of all Plan participants will not expire until October 15, 2011. Therefore, the Fund c ot at this point determine how it would cover the additional costs of complying with the annual limits prohibition if the waiver is not granted. Plan 1 and Plan 500 (Active Employees) For the purposes of completing this spreadsheet, the Plan's benefit consultant has included a composite premium equivalent rate in columns AL - AN (Current Monthly Premium Rates or Premium Equivalent Rate) and Columns AO -AQ (Renewal Monthly Premium Rate or Premium Equivalent Rate if Waiver Granted) to show average rates for each plan of benefits and the percentage increases in costs if the waiver is not granted. Since it is currently impossible for the Fund to anticipate how any necessary rate increases would be assigned (between employee and employer contributions) if the
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UFCW L400:000017
waiver is not granted and the Trustees are bound by the negotiated employer contribution rates in the CBAs, the full projected increases are reflected only in the employee contribution rate in column AS. With regard to Plan 1 and Plan 500, the structure of the chart and the percentage reflected in Column AU (Projected Rate Increase that would result from compliance with $750,000 Annual Limit Restriction) does not adequately reflect the potential increase attributed to employee contributions if the waiver is not granted. In the event the waiver is not granted for Plans 1 and Plan 500, employee contributions could increase by the following projected percentages under this approach: UFCW Local 400 & Employers Plan Individual/ Employee Tier
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With regard to Plan S and Plan V, the security features within the chart made it impossible for the Fund to illustrate the Premium Equivalent for these Plans accurately. Employers do not make a monthly contribution on behalf of each retiree. Instead, the employer contribution for active employees reflects a share of the costs to cover claims and administration for the retirees of the active employers covered by Plan S and Plan V. Retirees of inactive employers pay the full cost of coverage. However, as explained above, the Trustees cannot increase the active employee contribution to offset the cost of complying with the $750,000 annual limits. Therefore, if the cost of coverage increases, the retirees co-payment also likely will increase, even if there is no change in the costsharing percentage. For purposes of completing the chart, only the rates for the employee contribution portions of the premium rates are populated in Columns AL, AO, and AR (Employee Contribution). Because there is no direct monthly employer contribution, the employer contribution rate in Columns AM, AP and AS and Totals in Columns AN, AQ, and AT were left blank. In addition, the Projected Rate Increase that would result from compliance with $750,000 Annual Limit Restriction in Column AU reflects only the increase to the applicable rate for employee contributions.
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UFCW L400:000018
Employee Employee + Children Employee + Spouse Employee + Family Employee Employee + Family
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Ex. 4
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Projected Percentage Rate Increase that would result from compliance with $750,000 Annual
Column AV - Decrease in Access to Benefits that would Result from compliance with $750,000 Annual Limit Restriction As a multiemployer Taft-Hartley Plan with contribution rates set in collective bargaining agreements, the Board of Trustees is limited in its ability to fund the costs of the annual limits required under PPACA. As the Trustees believe that a waiver of the PPACA annual limits is warranted, no decisions have been made at this time regarding the actual benefit decreases that would be needed to offset a $750,000 annual limit. However, if the waiver is not granted, the Trustees would likely have to consider increases to deductibles and/or increases to the contribution amounts required to be paid by participants. These increases could be unaffordable for a large number of participants who would forego medical care because of the large contributions and deductibles. Please see the accompanying letter and exhibits regarding the level of benefit changes which the Fund's benefit consultant has calculated could be necessary to offset the expected increased costs of complying with the $750,000 annual limit.
333599v1
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UFCW L400:000019
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Policy Name (use a new row for each Applicant (Plan/ Policy policy application) Situs) City
Applicant (Plan/ Plan/ Policy Policy Effective Date Contact Situs) (mm/dd/yyyy) Names State
Street Addresses
Cities
State
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Email Addresses sgoodman@ slevinhart.co m/wtobin@re inhartlaw.co m Other Yes sgoodman@ slevinhart.co m/wtobin@re inhartlaw.co m Other Yes
Total Number of Individuals Current Covered by Type of Plan Overall Policy Coverage Annual (include all Self(e.g., Limited Limit (in Benefit, HRA, Insured Individual or dependents dollars) Rx only, Other) (Yes/No) Group Policy covered)
Ex. 4
Plan 1
Charleston
WV
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01/01/2011
1625 Massachuset ts Ave NW, Suite 450/1000 Sharon M. North Water Goodman/Wi Street, Suite Washington/ lliam Tobin 1700 Milwaukee
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Plan 1
Charleston
WV
01/01/2011
1625 Massachuset ts Ave NW, Suite 450/1000 Sharon M. North Water Goodman/Wi Street, Suite Washington/ lliam Tobin 1700 Milwaukee
DC
20036/53 202
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202-7978700/414298-8279 202-7978700/414298-8279
Group
DC
20036/53 203
Group
UFCW L400:000020
Ex. 4
Plan 1
Charleston
WV
01/01/2011
DC
20036/53 204
202-7978700/414298-8279
Plan 1
Charleston
WV
01/01/2011
DC
20036/53 205
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202-7978700/414298-8279 202-7978700/414298-8279
1625 Massachuset ts Ave NW, Suite 450/1000 Sharon M. North Water Goodman/Wi Street, Street Suite Washington/ lliam Tobin Milwaukee 1700
202-7978700/4148700/414 298-8279
Plan 500
Charleston
WV
01/01/2011
1625 Massachuset ts Ave NW, Suite 450/1000 Sharon M. North Water Goodman/Wi Street, Suite Washington/ lliam Tobin 1700 Milwaukee 1625 Massachuset ts Ave NW, Suite 450/1000 Sharon M. North Water Goodman/Wi Street, Suite Washington/ lliam Tobin 1700 Milwaukee
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DC
20036/53 205
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Plan 500
Charleston
WV
01/01/2011
DC
20036/53 205
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sgoodman@ slevinhart.co m/wtobin@re inhartlaw.co m Other Yes sgoodman@ slevinhart.co m/wtobin@re inhartlaw co inhartlaw.co m Other Yes sgoodman@ slevinhart.co m/wtobin@re inhartlaw.co m Other Yes sgoodman@ slevinhart.co m/wtobin@re inhartlaw.co m Other Yes
1625 Massachuset ts Ave NW, Suite 450/1000 Sharon M. North Water Goodman/Wi Street, Suite Washington/ lliam Tobin 1700 Milwaukee
Group
Group
Group
Group
UFCW L400:000021
Ex. 4
Plan V
Charleston
WV
01/01/2011
DC
20036/53 205
Plan V
Charleston
WV
01/01/2011
1625 Massachuset ts Ave NW, Suite 450/1000 Sharon M. North Water Goodman/Wi Street, Suite Washington/ lliam Tobin 1700 Milwaukee
DC
20036/53 205
202-7978700/414298-8279
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Plan S
Charleston
WV
01/01/2011
1625 Massachuset ts Ave NW, Suite 450/1000 Sharon M. North Water Goodman/Wi Street, Suite Washington/ lliam Tobin 1700 Milwaukee
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Plan S
Charleston
WV
01/01/2011
1625 Massachuset ts Ave NW, Suite 450/1000 Sharon M. North Water Goodman/Wi Street, Suite Washington/ lliam Tobin 1700 Milwaukee
DC
20036/53 205
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202-7978700/414298-8279 202-7978700/414298-8279
DC
20036/53 205
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Other Yes sgoodman@ slevinhart.co m/wtobin@re inhartlaw.co m Other Yes sgoodman@ slevinhart.co m/wtobin@re inhartlaw.co m Other Yes sgoodman@ slevinhart.co m/wtobin@re inhartlaw.co m Other Yes
1625 Massachuset ts Ave NW, Suite 450/1000 Sharon M. North Water Goodman/Wi Street, Suite Washington/ lliam Tobin 1700 Milwaukee
202-7978700/414298-8279
Group
Group
Group
Group
UFCW L400:000022
Current Essential Benefits Annual Limits (Annual Limit for Each Essential Benefit)
Office Visit Hospital Inpatient Emergency Room Rx Copays/Coinsurance Copay/Coinsurance Copay/Coinsurance Copay/Coninsurance
Ambulatory
Emergency
Hospitalization
Laboratory
Pediatric
Maternity/ Newborn
Rehabilitative/ Devices
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Preventive/ Wellness Prescription
Coinsura Coinsura Copay (if Coinsuranc Copay (if nce (if Copay (if nce (if Copay (if Coinsuran ce (if applicabl applicabl applicabl applicabl applicabl e (if applicabl Plan applicable) e) e) e) e) e) applicable) e) Deductible
Ex. 4
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UFCW L400:000023
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Ex. 4
UFCW L400:000024
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Ex. 4
UFCW L400:000025
Projected Rate Increase that would result from compliance with $750,000 Annual Limit Renewal Monthly Premium Rates or Premium Equivalent Rates if Waiver Granted Restriction (in dollars) (Average Premium by Individual)* (in dollars)*
ra do .c om
Total
Ex. 4
Employee Employer /Retiree Individual/ Employee contribution contribution (if applicable) (if applicable) Tier*
Total
Total
Decrease in Access to Benefits that Projected Rate Increase would result that would result from from compliance with $750,000 compliance Annual Limit Restriction with $750,000 (in dollars)(Average Annual Limit Premium by Individual) Restriction (Difference of Column AT (describe and AQ divided by briefly in cell Column AQ) or in a
et eC
Employee
Board of Trustees Access could of UFCW be restricted Local 400 due to benefit & changes Employer described in s Health & attached Welfare memo. Fund
ol o
Fund Administrator
Employee + Children
Co m
Board of Trustees Access could of UFCW be restricted Local 400 due to benefit & changes Employer described in s Health & attached Welfare memo. Fund
pl
Fund Administrator
UFCW L400:000026
Employee + Spouse
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please l see attached tt h d memo
Ex. 4
Board of Trustees Access could of UFCW be restricted Local 400 due to benefit & changes Employer described in s Health & attached Welfare memo. Fund
Fund Administrator
Employee + Family
Board of Trustees Access could of UFCW be restricted Local 400 & due to benefit Employer changes described in s Health & attached Welfare memo. Fund
Fund Administrator
Employee
Employee + Family
Board of Trustees of UFCW Local 400 & Employer s Health & Welfare Fund Board of Trustees of UFCW Local 400 & Employer s Health & Welfare Fund
Fund Administrator
Fund Administrator
UFCW L400:000027
Employee
ra do .c om ol o et eC
* When completing the columns requesting premium rate information, please express the premium rates as a composite rate (if premiums are a range based on years of service or age) and by tier (Employee, Employee + Spouse, Employee + Child, Family, etc.) as applicable. If you are an issuer, please provide the premium amount in the column titled, "Total" (Column AN, AQ and AT).
Ex. 4
Employee + Family
Board of Trustees of UFCW Local 400 & Employer s Health & Welfare Fund Board of Trustees of UFCW Local 400 & Employer s Health & Welfare Fund
Fund Administrator
Fund Administrator
Employee
Co m
pl
Employee + Family
Board of Trustees of UFCW Local 400 & Employer s Health & Welfare Fund Board of Trustees of UFCW Local 400 & Employer s Health & Welfare Fund
Fund Administrator
Fund Administrator
UFCW L400:000028
From: Scelzo, Kathleen (HHS/OCIIO) Sent: Friday, January 28, 2011 1:27 PM To: Habit, Sandra (HHS/OCIIO) Subject: FW: Waiver UFCW LOcal 400 Employers Health and Welfare Fund Attachments: 1-339302-4506_01_110120_Local_400_Waiver_Application_(revised).xls
Kathleen M. Scelzo, RN, MSN Rules Compliance Division Office of Insurance Oversight Office of Consumer Information and Insurance Oversight (OCIIO) Department of Health and Human Services 7501 Wisconsin Avenue Bethesda, MD 301-492-4121
From: Danielle T. Norris [mailto:dnorris@slevinhart.com] Sent: Monday, January 24, 2011 1:37 PM To: Scelzo, Kathleen (HHS/OCIIO) Subject: Waiver
Co m
Danielle T. Norris Attorney At Law Slevin & Hart, P.C. 1625 Massachusetts Ave., N.W., Suite 450 Washington, D.C. 20036 202-797-8700 Tel 202-234-8231 Fax dnorris@slevinhart.com
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As you requested in ourtelephone discussion on January20th regardingthe waiver application for the UFCW Local 400 and Employers Health and Welfare Fund, attached isa revised spreadsheet that reflectstheincreasesif the waivers are not granted andonlythe employee contributions bear those higher costs.
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UFCW L400:000029
From: Scelzo, Kathleen (HHS/OCIIO) Sent: Friday, January 28, 2011 11:29 AM To: 'Danielle T. Norris' Cc: Habit, Sandra (HHS/OCIIO) Subject: RE: Waiver UFCW Local 400
Danielle, Can you give me a call please? I need to clarify two more points: Lifetime limits Plan S and V employer contribution Kathleen M. Scelzo, RN, MSN Rules Compliance Division Office of Insurance Oversight Office of Consumer Information and Insurance Oversight (OCIIO) Department of Health and Human Services 7501 Wisconsin Avenue Bethesda, MD 301-492-4121
Importance: High
From: Danielle T. Norris [mailto:dnorris@slevinhart.com] Sent: Monday, January 24, 2011 1:37 PM To: Scelzo, Kathleen (HHS/OCIIO) Subject: Waiver
If you need anyadditional information, please feel free to call me at 202-797-8700. Best regards, Danielle
Danielle T. Norris Attorney At Law Slevin & Hart, P.C. 1625 Massachusetts Ave., N.W., Suite 450 Washington, D.C. 20036 202-797-8700 Tel 202-234-8231 Fax dnorris@slevinhart.com
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et eC
As you requested in ourtelephone discussion on January20th regardingthe waiver application for the UFCW Local 400 and Employers Health and Welfare Fund, attached isa revised spreadsheet that reflectstheincreasesif the waivers are not granted andonlythe employee contributions bear those higher costs.
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UFCW L400:000030
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From: Danielle T. Norris [dnorris@slevinhart.com] Sent: Wednesday, February 02, 2011 6:16 PM To: Scelzo, Kathleen (HHS/OCIIO) Cc: Sharon M. Goodman; William H. Tobin Subject: Re: Waiver UFCW Local 400 Importance: High Attachments: 1-333599-Local_400_Waiver_Chart_Explanatory_Memorandum.doc; 1-3432484506_01_110202_Local_400_Waiver_application_chart.xls
Dear Ms. Scelzo, In our telephone discussion on January28th regardingtherevised waiver application for the UFCW Local 400 and Employers Health and Welfare Fund, you indicated thatthe waiver application spreadsheet must include specific dollar figures in the section pertaining to the employer contribution for Plan S and Plan V rather thanreferencethe attachment. As wediscussed,the Fund's application (a copy of which is attached) explains thepremium equivalents and employer contributions for these Plans accurately. However, since you indicated that a numerical entry is required,as you requested, we haverevised the chart toshowa $0 employer contribution for Plan S and Plan Veach monthto reflect that the employer does not pay a separate employer contribution for each retiree each month. Best regards, Danielle Danielle T. Norris Attorney At Law Slevin & Hart, P.C. 1625 Massachusetts Ave., N.W., Suite 450 Washington, D.C. 20036 202-797-8700 Tel 202-234-8231 Fax dnorris@slevinhart.com
Danielle, Can you give me a call please? I need to clarify two more points: Lifetime limits Plan S and V employer contribution Kathleen M. Scelzo, RN, MSN Rules Compliance Division Office of Insurance Oversight Office of Consumer Information and Insurance Oversight (OCIIO) Department of Health and Human Services 7501 Wisconsin Avenue Bethesda, MD 301-492-4121
From: Danielle T. Norris [mailto:dnorris@slevinhart.com] Sent: Monday, January 24, 2011 1:37 PM
UFCW L400:000031
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From: Scelzo, Kathleen (HHS/OCIIO) [mailto:Kathleen.Scelzo@hhs.gov] Sent: Friday, January 28, 2011 11:29 AM To: Danielle T. Norris Cc: Habit, Sandra (HHS/OCIIO) Subject: RE: Waiver UFCW Local 400 Importance: High
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Dear Ms. Scelzo, As you requested in ourtelephone discussion on January20th regardingthe waiver application for the UFCW Local 400 and Employers Health and Welfare Fund, attached isa revised spreadsheet that reflectstheincreasesif the waivers are not granted andonlythe employee contributions bear those higher costs.
If you need anyadditional information, please feel free to call me at 202-797-8700. Best regards, Danielle Danielle T. Norris Attorney At Law Slevin & Hart, P.C. 1625 Massachusetts Ave., N.W., Suite 450 Washington, D.C. 20036 202-797-8700 Tel 202-234-8231 Fax dnorris@slevinhart.com
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UFCW L400:000032
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Policy Name (use a new row for each Applicant (Plan/ Policy policy application) Situs) City
Applicant (Plan/ Plan/ Policy Policy Effective Date Contact Situs) (mm/dd/yyyy) Names State
Street Addresses
Cities
State
ra do .c om
Email Addresses sgoodman@ slevinhart.co m/wtobin@re inhartlaw.co m Other Yes sgoodman@ slevinhart.co m/wtobin@re inhartlaw.co m Other Yes
Total Number of Individuals Current Covered by Type of Plan Overall Policy Coverage Annual (include all Self(e.g., Limited Limit (in Benefit, HRA, Insured Individual or dependents dollars) Rx only, Other) (Yes/No) Group Policy covered)
Ex. 4
Plan 1
Charleston
WV
Co m
01/01/2011
1625 Massachuset ts Ave NW, Suite 450/1000 Sharon M. North Water Goodman/Wi Street, Suite Washington/ lliam Tobin 1700 Milwaukee
pl
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Plan 1
Charleston
WV
01/01/2011
1625 Massachuset ts Ave NW, Suite 450/1000 Sharon M. North Water Goodman/Wi Street, Suite Washington/ lliam Tobin 1700 Milwaukee
DC
20036/53 202
ol o
202-7978700/414298-8279 202-7978700/414298-8279
Group
DC
20036/53 203
Group
UFCW L400:000033
Current Essential Benefits Annual Limits (Annual Limit for Each Essential Benefit)
Office Visit Hospital Inpatient Emergency Room Rx Copays/Coinsurance Copay/Coinsurance Copay/Coinsurance Copay/Coninsurance
Ambulatory
Emergency
Hospitalization
Laboratory
Pediatric
Maternity/ Newborn
Rehabilitative/ Devices
ra do .c om
Preventive/ Wellness Prescription
Coinsura Coinsura Copay (if Coinsuran Copay (if nce (if Copay (if Coinsuranc Copay (if nce (if ce (if applicabl applicabl applicabl applicabl applicabl e (if applicabl Plan applicable) e) e) e) e) e) applicable) e) Deductible
Ex. 4
Co m
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UFCW L400:000034
Projected Rate Increase that would result from compliance with $750,000 Annual Limit Renewal Monthly Premium Rates or Premium Equivalent Rates if Waiver Granted Restriction (in dollars) (Average Premium by Individual)* (in dollars)*
ra do .c om
Total
Ex. 4
Employee Employer /Retiree Individual/ Employee contribution contribution (if applicable) (if applicable) Tier*
Total
Total
Decrease in Access to Benefits that Projected Rate Increase would result that would result from from compliance with $750,000 compliance Annual Limit Restriction with $750,000 (in dollars)(Average Annual Limit Premium by Individual) Restriction (Difference of Column AT (describe and AQ divided by briefly in cell Column AQ) or in a
et eC
Employee
Board of Trustees Access could of UFCW be restricted Local 400 due to benefit & changes Employer described in s Health & attached Welfare memo. Fund
ol o
Fund Administrator
Employee + Children
Co m
Board of Trustees Access could of UFCW be restricted Local 400 due to benefit & changes Employer described in s Health & attached Welfare memo. Fund
pl
Fund Administrator
UFCW L400:000035
Policy Name (use a new row for each Applicant (Plan/ Policy policy application) Situs) City
Applicant (Plan/ Plan/ Policy Policy Effective Date Contact Situs) (mm/dd/yyyy) Names State
Street Addresses
Cities
State
ra do .c om
Email Addresses sgoodman@ slevinhart.co m/wtobin@re inhartlaw.co m Other Yes sgoodman@ slevinhart.co m/wtobin@re inhartlaw.co m Other Yes
Total Number of Individuals Current Covered by Type of Plan Overall Policy Coverage Annual (include all Self(e.g., Limited Limit (in Benefit, HRA, Insured Individual or dependents dollars) Rx only, Other) (Yes/No) Group Policy covered)
Ex. 4
Co m
Plan 1
Charleston
WV
01/01/2011
1625 Massachuset ts Ave NW, Suite 450/1000 Sharon M. North Water Goodman/Wi Street, Suite Washington/ lliam Tobin 1700 Milwaukee
pl
et eC
Plan 1
Charleston
WV
01/01/2011
1625 Massachuset ts Ave NW, Suite 450/1000 Sharon M. North Water Goodman/Wi Street, Suite Washington/ lliam Tobin 1700 Milwaukee
DC
20036/53 204
ol o
202-7978700/414298-8279 202-7978700/414298-8279
Group
DC
20036/53 205
Group
UFCW L400:000036
Current Essential Benefits Annual Limits (Annual Limit for Each Essential Benefit)
Office Visit Hospital Inpatient Emergency Room Rx Copays/Coinsurance Copay/Coinsurance Copay/Coinsurance Copay/Coninsurance
Ambulatory
Emergency
Hospitalization
Laboratory
Pediatric
Maternity/ Newborn
Rehabilitative/ Devices
ra do .c om
Preventive/ Wellness Prescription
Coinsura Coinsura Copay (if Coinsuran Copay (if nce (if Copay (if Coinsuranc Copay (if nce (if ce (if applicabl applicabl applicabl applicabl applicabl e (if applicabl Plan applicable) e) e) e) e) e) applicable) e) Deductible
Ex. 4
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pl
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UFCW L400:000037
Projected Rate Increase that would result from compliance with $750,000 Annual Limit Renewal Monthly Premium Rates or Premium Equivalent Rates if Waiver Granted Restriction (in dollars) (Average Premium by Individual)* (in dollars)*
ra do .c om
Total
Ex. 4
Employee Employer /Retiree Individual/ Employee contribution contribution (if applicable) (if applicable) Tier*
Total
Total
Decrease in Access to Benefits that Projected Rate Increase would result that would result from from compliance with $750,000 compliance Annual Limit Restriction with $750,000 (in dollars)(Average Annual Limit Premium by Individual) Restriction (Difference of Column AT (describe and AQ divided by briefly in cell Column AQ) or in a
et eC
Employee + Spouse
Board of Trustees Access could of UFCW be restricted Local 400 due to benefit & changes Employer described in s Health & attached Welfare memo. Fund
ol o
Fund Administrator
Co m
Board of Trustees Access could of UFCW be restricted Local 400 due to benefit & changes Employer described in s Health & attached Welfare memo. Fund attached memo
pl
Fund Administrator
attached memo
attached memo
attached memo
attached memo
attached memo
UFCW L400:000038
Policy Name (use a new row for each Applicant (Plan/ Policy policy application) Situs) City
Applicant (Plan/ Plan/ Policy Policy Effective Date Contact Situs) (mm/dd/yyyy) Names State
Street Addresses
Cities
State
ra do .c om
Email Addresses sgoodman@ slevinhart.co m/wtobin@re inhartlaw.co m Other Yes sgoodman@ slevinhart.co m/wtobin@re inhartlaw.co m Other Yes sgoodman@ slevinhart.co m/wtobin@re inhartlaw.co m Other Yes
Total Number of Individuals Current Covered by Type of Plan Overall Policy Coverage Annual (include all Self(e.g., Limited Limit (in Benefit, HRA, Insured Individual or dependents dollars) Rx only, Other) (Yes/No) Group Policy covered)
Ex. 4
Plan 500
Charleston
WV
01/01/2011
DC
20036/53 205
ol o
202-7978700/414298-8279 202-7978700/414298-8279
1625 Massachuset ts Ave NW, Suite 450/1000 Sharon M. North Water Goodman/Wi Street, Suite Washington/ lliam Tobin 1700 Milwaukee 1625 Massachuset ts Ave NW, Suite 450/1000 Sharon M. North Water Goodman/Wi Street, Suite Washington/ lliam Tobin 1700 Milwaukee
202-7978700/414298-8279
Group
et eC
20036/53 205
Plan 500
Charleston
WV
01/01/2011
DC
Group
Co m
Plan V
Charleston
WV
01/01/2011
1625 Massachuset ts Ave NW, Suite 450/1000 Sharon M. North Water Goodman/Wi Street, Suite Washington/ lliam Tobin 1700 Milwaukee
pl
20036/53 205
DC
Group
UFCW L400:000039
Current Essential Benefits Annual Limits (Annual Limit for Each Essential Benefit)
Office Visit Hospital Inpatient Emergency Room Rx Copays/Coinsurance Copay/Coinsurance Copay/Coinsurance Copay/Coninsurance
Ambulatory
Emergency
Hospitalization
Laboratory
Pediatric
Maternity/ Newborn
Rehabilitative/ Devices
ra do .c om
Preventive/ Wellness Prescription
Coinsura Coinsura Copay (if Coinsuran Copay (if nce (if Copay (if Coinsuranc Copay (if nce (if ce (if applicabl applicabl applicabl applicabl applicabl e (if applicabl Plan applicable) e) e) e) e) e) applicable) e) Deductible
Ex. 4
Co m
pl
et eC
ol o
UFCW L400:000040
Projected Rate Increase that would result from compliance with $750,000 Annual Limit Renewal Monthly Premium Rates or Premium Equivalent Rates if Waiver Granted Restriction (in dollars) (Average Premium by Individual)* (in dollars)*
ra do .c om
Total
Ex. 4
Employee Employer /Retiree Individual/ Employee contribution contribution (if applicable) (if applicable) Tier*
Total
Total
Decrease in Access to Benefits that Projected Rate Increase would result that would result from from compliance with $750,000 compliance Annual Limit Restriction with $750,000 (in dollars)(Average Annual Limit Premium by Individual) Restriction (Difference of Column AT (describe and AQ divided by briefly in cell Column AQ) or in a
Employee
ol o
Employee + Family
et eC
Plan Administr ator/ CEO of Health Insuranc e Issuer Name Board of Trustees of UFCW Local 400 & Employer s Health & Welfare Fund Board of Trustees of UFCW Local 400 & Employer s Health & Welfare Fund
Fund Administrator
Fund Administrator
pl
Employee
Co m
Board of Trustees Access could of UFCW be restricted Local 400 due to benefit & changes Employer described in s Health & attached Welfare memo. Fund
Fund Administrator
UFCW L400:000041
Policy Name (use a new row for each Applicant (Plan/ Policy policy application) Situs) City
Applicant (Plan/ Plan/ Policy Policy Effective Date Contact Situs) (mm/dd/yyyy) Names State
Street Addresses
Cities
State
ra do .c om
Email Addresses sgoodman@ slevinhart.co m/wtobin@re inhartlaw.co m Other Yes sgoodman@ slevinhart.co m/wtobin@re inhartlaw.co m Other Yes sgoodman@ slevinhart.co m/wtobin@re inhartlaw.co m Other Yes
Total Number of Individuals Current Covered by Type of Plan Overall Policy Coverage Annual (include all Self(e.g., Limited Limit (in Benefit, HRA, Insured Individual or dependents dollars) Rx only, Other) (Yes/No) Group Policy covered)
Ex. 4
Plan V
Charleston
WV
01/01/2011
DC
20036/53 205
ol o
202-7978700/414298-8279 202-7978700/414298-8279
1625 Massachuset ts Ave NW, Suite 450/1000 Sharon M. North Water Goodman/Wi Street, Suite Washington/ lliam Tobin 1700 Milwaukee
202-7978700/414298-8279
Group
Plan S
Charleston
WV
01/01/2011
1625 Massachuset ts Ave NW, Suite 450/1000 Sharon M. North Water Goodman/Wi Street, Suite Washington/ lliam Tobin 1700 Milwaukee 1625 Massachuset ts Ave NW, Suite 450/1000 Sharon M. North Water Goodman/Wi Street, Suite Washington/ lliam Tobin 1700 Milwaukee
et eC
20036/53 205
DC
Group
Co m
Plan S
Charleston
WV
pl
DC 20036/53 205
01/01/2011
Group
UFCW L400:000042
Current Essential Benefits Annual Limits (Annual Limit for Each Essential Benefit)
Office Visit Hospital Inpatient Emergency Room Rx Copays/Coinsurance Copay/Coinsurance Copay/Coinsurance Copay/Coninsurance
Ambulatory
Emergency
Hospitalization
Laboratory
Pediatric
Maternity/ Newborn
Rehabilitative/ Devices
ra do .c om
Preventive/ Wellness Prescription
Coinsura Coinsura Copay (if Coinsuran Copay (if nce (if Copay (if Coinsuranc Copay (if nce (if ce (if applicabl applicabl applicabl applicabl applicabl e (if applicabl Plan applicable) e) e) e) e) e) applicable) e) Deductible
Ex. 4
Co m
pl
et eC
ol o
UFCW L400:000043
Projected Rate Increase that would result from compliance with $750,000 Annual Limit Renewal Monthly Premium Rates or Premium Equivalent Rates if Waiver Granted Restriction (in dollars) (Average Premium by Individual)* (in dollars)*
ra do .c om
Total
Ex. 4
Employee Employer /Retiree Individual/ Employee contribution contribution (if applicable) (if applicable) Tier*
Total
Total
Decrease in Access to Benefits that Projected Rate Increase would result that would result from from compliance with $750,000 compliance Annual Limit Restriction with $750,000 (in dollars)(Average Annual Limit Premium by Individual) Restriction (Difference of Column AT (describe and AQ divided by briefly in cell Column AQ) or in a
Employee + Family
ol o
Board of Trustees Access could of UFCW be restricted Local 400 due to benefit & changes Employer described in s Health & attached Welfare memo. Fund
Fund Administrator
Employee
Employee + Family
Co m
Board of Trustees of UFCW Local 400 & Employer s Health & Welfare Fund Board of Trustees of UFCW Local 400 & Employer s Health & Welfare Fund
et eC
Fund Administrator
pl
Fund Administrator
* When completing the columns requesting premium rate information, please express the premium rates as a composite rate (if premiums are a range based on years of service or age) and by tier (Employee, Employee + Spouse, Employee + Child, Family, t ) li bl If i l id th i t i th l titl d "T t l" (C l AN AQ d AT)
UFCW L400:000044
From: Botwinick, Alexandra (HHS/OCIIO) Sent: Thursday, February 03, 2011 2:49 PM To: 'sgoodman@slevinhart.com'; 'wtobin@reinhartlaw.com' Cc: Habit, Sandra (HHS/OCIIO) Subject: UFCW Local 400 and Employers H&W Plan Waiver of the Annual Limits Requirements 2-3-2011 Importance: High Attachments: Updated Jan 1 Approval Letter .pdf Good Morning, Thank you for submitting an application for a Waiver of the Annual Limits Requirements of the PHS Act Section 2711 for UFCW Local 400 and Employers H&W Plan. HHS has reviewed your application and made its determination. Please see the attached letter. The attached letter refers to the following plans:
Plan 1
Plan 500
Plan S
alexandra.botwinick@hhs.gov
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pl
Please confirm receipt of this letter by replying to this e-mail. Please let me know if I can be of further assistance.
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UFCW L400:000045
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UFCW L400:000046
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UFCW L400:000047
From: Scelzo, Kathleen (HHS/OCIIO) Sent: Tuesday, February 15, 2011 11:11 AM To: 'sgoodman@slevinhart.com' Cc: 'wtobin@reinhartlaw.com' Subject: UFCW Local 400 Limited Waiver Approval Attachments: Jan 1 Approval.pdf Good Morning, Thank you for submitting an application for a Waiver of the Annual Limits Requirements of the PHS Act Section 2711 for UFCW Local 400 HHS has reviewed your application and made its determination. Please see the attached letter. The attached letter refers to the following plans: Plan V Please confirm receipt of this letter by replying to this e-mail. Please let me know if I can be of further assistance.
Kathleen M. Scelzo, RN, MSN Rules Compliance Division Office of Insurance Oversight Office of Consumer Information and Insurance Oversight (OCIIO) Department of Health and Human Services 7501 Wisconsin Avenue Bethesda, MD 301-492-4121
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UFCW L400:000048
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UFCW L400:000049
Co m pl et eC ol o ra do . co m
UFCW L400:000050