Download - Roofers Local 96 - Redacted Bates HWM
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//T|/...0[YELLOW]/Roofers%20Local%20No.%2096%20Health%20and%20Welfare%20Fund/Annual%20Waiver%20Application.txt[08/17/2011 10:18:
rom: Mike Theirl [[email protected]]ent: Monday, November 01, 2010 3:26 PMo: HHS HealthInsurance (HHS)
Cc: [email protected]; [email protected]: Annual Waiver Application
Attachments: hhs.gov waiver application material roofers.pdf
o Whom It May Concern;
lease find enclosed a copy of the Roofers Local #96 Health & Welfare Fund waiver request/application and theupporting documentation.
will also mail an original set of the same material.
lease contact me if you have any questions.
incerely,Mike Theirl, CEBSAdministrator
Wilson-McShane Corporationhone: (952) 854-0795
Direct: (952) 851-3456ax: (952) 854-1632mail: [email protected]
Roofers L96:000001
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Roofers L96:000002
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Roofers L96:000003
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Roofers L96:000004
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Pages 5 through 23 redacted for the following reasons:- - - - - - - - - - - - - - - - - - - - - - - - - - - -Exemption 4
Roofers L96:000005
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rom: Moultrie, Cam (HHS/OCIIO)ent: Tuesday, November 16, 2010 5:06 PM
To: [email protected]; [email protected]: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
ear Mr. Rosene:
hank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section
711. In order to complete your application, please provide the following information:
In your application, your plan(s) or policy(ies) provide a lifetime limit. According to the regulation, y
may not have any lifetime limit on your plan, except in the case of non-essential benefits that are
permitted under Federal or State law. Effective September 23, 2010, you may no longer have a lifetim
limit on your plan or policy. Plans that previously had a lifetime limit may add an annual limit not les
than the lifetime limit without affecting the grandfather status of the plan.
Please confirm whether the plan has lifetime or annual limits on ambulatory, emergency, hospitalization,
aboratory, pediatric, maternity/newborn, mental health/substance abuse, rehabilitative/devices,reventive/wellness, or prescription benefits and identify the corresponding limits.
Please confirm whether the plan is in compliance with the interim final regulations relating to
grandfathered health plans.
Please provide the current monthly premium rates and the projected monthly premium rates applica
to the plan or policy forms if the plan were to comply with the restricted annual benefits. In other
words, we would like a chart that reflects the following information:
2010 JanuaryPremium (currentlevel)
2011 JanuaryPremium (renewal)
2011 JanuaryPremium (if $750,000annual limit wasapplied)
EE
EE + Child (ifapplicable or otherappropriate tier)
EE + Spouse (ifapplicable or otherappropriate tier)
Family (if applicableor other appropriatetier)
n order to complete your application, please provide this information by 5:00 pm, November 17, 2010. We
ook forward to receiving your completed application. Thank you.
Roofers L96:000006
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//T|/...cal%20No.%2096%20Health%20and%20Welfare%20Fund/equest%20for%20additional%20info%20response%2011.16.10.htm[08/17/2011 10:18
rom: Peter M. Rosene [[email protected]]ent: Tuesday, November 16, 2010 8:18 PM
To: Moultrie, Cam (HHS/OCIIO); [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]
ubject: RE: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]
ent: Tuesday, November 16, 2010 4:06 PMo: [email protected]; [email protected]: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
ear Mr. Rosene:
hank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section
711. In order to complete your application, please provide the following information:
In your application, your plan(s) or policy(ies) provide a lifetime limit. According to the regulation, y
may not have any lifetime limit on your plan, except in the case of non-essential benefits that arepermitted under Federal or State law. Effective September 23, 2010, you may no longer have a lifetim
limit on your plan or policy. Plans that previously had a lifetime limit may add an annual limit not les
than the lifetime limit without affecting the grandfather status of the plan. The Plan year, in this case
December 1 through November 30. The trustees have eliminated the lifetime maximum, as required b
law, effective with the first day of the plan year following September 23, 2010. Therefore, this plan w
have no lifetime limits as of December 1, 2010. We are asking to have an annual limit that correspon
with our old (and revoked) lifetime limit.
Please confirm whether the plan has lifetime or annual limits on ambulatory, emergency, hospitalizat
laboratory, pediatric, maternity/newborn, mental health/substance abuse, ative/devices,preventive/wellness, or prescription benefits and identify the correspondi This plan never annual limits for essential benefits. The major medical lifetime limit was $ which has beenrevoked with the first day of the plan year following September 23, 2010.
Please confirm whether the plan is in compliance with the interim final regulations relating to
grandfathered health plans. The plan is in full compliance with the interim final regulations relating t
grandfathered health plans.
Please provide the current monthly premium rates and the projected monthly premium rates applicab
to the plan or policy forms if the plan were to comply with the restricted annual benefits. In other
words, we would like a chart that reflects the following information: This is a composite rate (family
only) plan. No other elections have ever been permitted. The eligibility provisions for the plan are as
follows, which shows the minimum number of hours of collectively bargained work necessary for
coverage:
nitial Eligibility - Collective Bargained Employees
You will become eligible for benefits onRoofers L96:000007
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//T|/...cal%20No.%2096%20Health%20and%20Welfare%20Fund/equest%20for%20additional%20info%20response%2011.16.10.htm[08/17/2011 10:18
nitial Eligibility - Non-bargaining Unit Employees
Continuing Eligibility - Collective Bargained Employees
will have the administrator confirm the existing contribution rate by a separate e-mail to you, as I am current
Hawaii teaching at a conference. As we have no ability to increase employer contributions, the premium would remhe same and benefits would have to be slashed in an amount equal to the cost of stop loss insurance. I hope thats responsive to your request; please let me know if you have further inquiries.
2010 JanuaryPremium (currentlevel)
2011 JanuaryPremium (renewal)
2011 JanuaryPremium (if $750,000annual limit wasapplied)
EE
EE + Child (ifapplicable or other
appropriate tier)
EE + Spouse (ifapplicable or otherappropriate tier)
Family (if applicableor other appropriatetier)
n order to complete your application, please provide this information by 5:00 pm, November 17, 2010. We
Roofers L96:000008
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//T|/...cal%20No.%2096%20Health%20and%20Welfare%20Fund/equest%20for%20additional%20info%20response%2011.16.10.htm[08/17/2011 10:18
ook forward to receiving your completed application. Thank you.
Roofers L96:000009
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//T|/...l%20No.%2096%20Health%20and%20Welfare%20Fund/Request%20for%20additional%20info%20response%2011.17.10.htm[08/17/2011 10:18:
li is plan never had annual limits for essential benefits. The major medical lifetime limit was$ , which has been revoked with the first day of the plan year following September 23, 2010.
Pl firm whether the plan is in compliance with the interim final regulations relating to
grandfathered health plans. The plan is in full compliance with the interim final regulations relating t
grandfathered health plans.
Please provide the current monthly premium rates and the projected monthly premium rates applicabto the plan or policy forms if the plan were to comply with the restricted annual benefits. In other
words, we would like a chart that reflects the following information: This is a composite rate (family
only) plan. No other elections have ever been permitted. The eligibility provisions for the plan are as
follows, which shows the minimum number of hours of collectively bargained work necessary for
coverage:
nitial Eligibility - Collective Bargained Employees
nitial Eligibility - Non-bargaining Unit Employees
Continuing Eligibility - Collective Bargained Employees
will have the administrator confirm the existing contribution rate by a separate e-mail to you, as I am currentHawaii teaching at a conference. As we have no ability to increase employer contributions, the premium would rem
Roofers L96:000011
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he same and benefits would have to be slashed in an amount equal to the cost of stop loss insurance. I hope thats responsive to your request; please let me know if you have further inquiries.
2010 JanuaryPremium (currentlevel)
2011 JanuaryPremium (renewal)
2011 JanuaryPremium (if $750,000annual limit wasapplied)
EE
EE + Child (if
applicable or otherappropriate tier)
EE + Spouse (ifapplicable or otherappropriate tier)
Family (if applicableor other appropriatetier)
n order to complete your application, please provide this information by 5:00 pm, November 17, 2010. We
ook forward to receiving your completed application. Thank you.
Roofers L96:000012
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//T|/...o.%2096%20Health%20and%20Welfare%20Fund/Request%20for%20additional%20info%20response%20(2)%2011.17.10.htm[08/17/2011 10:18
rom: [email protected]: Wednesday, November 17, 2010 3:54 PM
To: Moultrie, Cam (HHS/OCIIO); Peter M. RoseneCc: Habit, Sandra (HHS/OCIIO); [email protected]
ubject: Re: Waiver Application for Roofer Local No. 96 Health and WelfareFundDear Cam,
ly contribution rate is $ for the bargaining participants. The Non-Bargaining composite monthly rate i
ntact me if you have any further questions for me.hanks,Mike Theirl
ent on the Sprint Now Network from my BlackBerry
rom: "Moultrie, Cam (HHS/OCIIO)" Date: Wed, 17 Nov 2010 13:59:07 -0500To: Peter M. Rosene; [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]
ubject: RE: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
Mr. Rosene,
hank you for your response. I look forward to the contribution rates.
am Moultrie
am Lynne Moultrie
rogram Analyst
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
rom: Peter M. Rosene [mailto:[email protected]]ent: Tuesday, November 16, 2010 8:18 PMo: Moultrie, Cam (HHS/OCIIO); [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]: RE: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Tuesday, November 16, 2010 4:06 PMo: [email protected]; [email protected]: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
ear Mr. Rosene:
hank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section
711. In order to complete your application, please provide the following information:
Roofers L96:000013
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//T|/...o.%2096%20Health%20and%20Welfare%20Fund/Request%20for%20additional%20info%20response%20(2)%2011.17.10.htm[08/17/2011 10:18
In your application, your plan(s) or policy(ies) provide a lifetime limit. According to the regulation, y
may not have any lifetime limit on your plan, except in the case of non-essential benefits that are
permitted under Federal or State law. Effective September 23, 2010, you may no longer have a lifetim
limit on your plan or policy. Plans that previously had a lifetime limit may add an annual limit not les
than the lifetime limit without affecting the grandfather status of the plan. The Plan year, in this case
December 1 through November 30. The trustees have eliminated the lifetime maximum, as required b
law, effective with the first day of the plan year following September 23, 2010. Therefore, this plan w
have no lifetime limits as of December 1, 2010. We are asking to have an annual limit that correspon
with our old (and revoked) lifetime limit.
Please confirm whether the plan has lifetime or annual limits on ambulatory, emergency,hospitalization, laboratory, pediatric, maternity/newborn, mental health/substance abuse,r tive/devices, preventive/wellness, or prescription benefits and identify the correspondingli is plan never had annual limits for essential benefits. The major medical lifetime limit was$ which has been revoked with the first day of the plan year following September 23, 2010.
Pl firm whether the plan is in compliance with the interim final regulations relating to
grandfathered health plans. The plan is in full compliance with the interim final regulations relating tgrandfathered health plans.
Please provide the current monthly premium rates and the projected monthly premium rates applicab
to the plan or policy forms if the plan were to comply with the restricted annual benefits. In other
words, we would like a chart that reflects the following information: This is a composite rate (family
only) plan. No other elections have ever been permitted. The eligibility provisions for the plan are as
follows, which shows the minimum number of hours of collectively bargained work necessary for
coverage:
nitial Eligibility - Collective Bargained Employees
nitial Eligibility - Non-bargaining Unit Employees
Roofers L96:000014
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//T|/...o.%2096%20Health%20and%20Welfare%20Fund/Request%20for%20additional%20info%20response%20(2)%2011.17.10.htm[08/17/2011 10:18
Continuing Eligibility - Collective Bargained Employees
Any combination of the above may be used to continue eligibility.
will have the administrator confirm the existing contribution rate by a separate e-mail to you, as I am currentHawaii teaching at a conference. As we have no ability to increase employer contributions, the premium would remhe same and benefits would have to be slashed in an amount equal to the cost of stop loss insurance. I hope thats responsive to your request; please let me know if you have further inquiries.
2010 JanuaryPremium (currentlevel)
2011 JanuaryPremium (renewal)
2011 JanuaryPremium (if $750,000annual limit was
applied)EE
EE + Child (ifapplicable or otherappropriate tier)
EE + Spouse (ifapplicable or otherappropriate tier)
Family (if applicableor other appropriatetier)
n order to complete your application, please provide this information by 5:00 pm, November 17, 2010. We
ook forward to receiving your completed application. Thank you.
Roofers L96:000015
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rom: Moultrie, Cam (HHS/OCIIO)ent: Thursday, November 18, 2010 11:44 AM
To: [email protected]: Habit, Sandra (HHS/OCIIO)
ubject: RE: Waiver Application for Roofer Local No. 96 Health and WelfareFundlease provide total contribution rates (employee + employer) for 2010, 2011 and 2011 (if $the $750,000 annual limit was
pplied).
am Lynne Moultrierogram Analyst
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
rom: [email protected] [mailto:[email protected]]ent: Wednesday, November 17, 2010 3:54 PMo: Moultrie, Cam (HHS/OCIIO); Peter M. Rosenec: Habit, Sandra (HHS/OCIIO); [email protected]
ubject: Re: Waiver Application for Roofer Local No. 96 Health and WelfareFund
Dear Cam, ly contribution rate is $ for the bargaining participants. The Non-Bargaining composite monthly rate i
ntact me if you have any further questions for me.
hanks,Mike Theirl
ent on the Sprint Now Network from my BlackBerry
rom: "Moultrie, Cam (HHS/OCIIO)" Date: Wed, 17 Nov 2010 13:59:07 -0500To: Peter M. Rosene; [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]
ubject: RE: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
Mr. Rosene,
hank you for your response. I look forward to the contribution rates.
am Moultrie
am Lynne Moultrie
rogram Analyst
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
rom: Peter M. Rosene [mailto:[email protected]]ent: Tuesday, November 16, 2010 8:18 PM
Roofers L96:000016
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//T|/...Local%20No.%2096%20Health%20and%20Welfare%20Fund/2nd%20Request%20for%20additional%20info%2011.18.10.htm[08/17/2011 10:18:
o: Moultrie, Cam (HHS/OCIIO); [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]: RE: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Tuesday, November 16, 2010 4:06 PMo: [email protected]; [email protected]: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
ear Mr. Rosene:
hank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section
711. In order to complete your application, please provide the following information:
In your application, your plan(s) or policy(ies) provide a lifetime limit. According to the regulation, y
may not have any lifetime limit on your plan, except in the case of non-essential benefits that are
permitted under Federal or State law. Effective September 23, 2010, you may no longer have a lifetim
limit on your plan or policy. Plans that previously had a lifetime limit may add an annual limit not les
than the lifetime limit without affecting the grandfather status of the plan. The Plan year, in this case
December 1 through November 30. The trustees have eliminated the lifetime maximum, as required b
law, effective with the first day of the plan year following September 23, 2010. Therefore, this plan w
have no lifetime limits as of December 1, 2010. We are asking to have an annual limit that correspon
with our old (and revoked) lifetime limit.
Please confirm whether the plan has lifetime or annual limits on ambulatory, emergency,hospitalization, laboratory, pediatric, maternity/newborn, mental health/substance abuse,r tive/devices, preventive/wellness, or prescription benefits and identify the corresponding
li is plan never had annual limits for essential benefits. The major medical lifetime limit was$ which has been revoked with the first day of the plan year following September 23, 2010.
Pl irm whether the plan is in compliance with the interim final regulations relating to
grandfathered health plans. The plan is in full compliance with the interim final regulations relating t
grandfathered health plans.
Please provide the current monthly premium rates and the projected monthly premium rates applicab
to the plan or policy forms if the plan were to comply with the restricted annual benefits. In other
words, we would like a chart that reflects the following information: This is a composite rate (familyonly) plan. No other elections have ever been permitted. The eligibility provisions for the plan are as
follows, which shows the minimum number of hours of collectively bargained work necessary for
coverage:
nitial Eligibility - Collective Bargained Employees
Roofers L96:000017
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nitial Eligibility - Non-bargaining Unit Employees
Continuing Eligibility - Collective Bargained Employees
will have the administrator confirm the existing contribution rate by a separate e-mail to you, as I am currentHawaii teaching at a conference. As we have no ability to increase employer contributions, the premium would rem
he same and benefits would have to be slashed in an amount equal to the cost of stop loss insurance. I hope thats responsive to your request; please let me know if you have further inquiries.
2010 JanuaryPremium (currentlevel)
2011 JanuaryPremium (renewal)
2011 JanuaryPremium (if $750,000annual limit wasapplied)
EE
EE + Child (ifapplicable or otherappropriate tier)
EE + Spouse (ifapplicable or otherappropriate tier)
Family (if applicableor other appropriatetier)
n order to complete your application, please provide this information by 5:00 pm, November 17, 2010. We
ook forward to receiving your completed application. Thank you.
Roofers L96:000018
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Roofers L96:000019
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rom: [email protected]: Thursday, November 18, 2010 11:59 PM
To: Moultrie, Cam (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO); [email protected]; [email protected]
ubject: Re: Waiver Application for Roofer Local No. 96 Health andWelfareFundCam,
he contribution rates are technically percent employer paid. However the total package is collectively bargain
with the health and welfare contributi mount a component of the participant's fringe fund package. There are noealth and welfare contribution rates yet for 2011, or forward, as that will depend on the allocation determination toach individual fringe benefit. In short, is waiver is not granted, any available collectively bargained amounts tllocated in future years will likely all ( percent) be required to be allocated to the health and welfare fund to rehe damage/hardship of the immediate ination of the lifetime limit to the Fund, including likely money taken ohe participant/employees taxable wage and take home pay for the forseeable future.
lease contact me if you have any further questions. I have also cc'd Fund Counsel Pete Rosene in the event that heas any additional information to add to your inquiry.
incerely,Mike Theirl, CEBS
ent on the Sprint Now Network from my BlackBerry
rom: "Moultrie, Cam (HHS/OCIIO)" Date: Thu, 18 Nov 2010 11:44:21 -0500To: [email protected]: Habit, Sandra (HHS/OCIIO)
ubject: RE: Waiver Application for Roofer Local No. 96 Health and WelfareFund
lease provide total contribution rates (employee + employer) for 2010, 2011 and 2011 (if $the $750,000 annual limit was
pplied).
am Lynne Moultrie
rogram Analyst
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
rom: [email protected] [mailto:[email protected]]ent: Wednesday, November 17, 2010 3:54 PM
o: Moultrie, Cam (HHS/OCIIO); Peter M. Rosenec: Habit, Sandra (HHS/OCIIO); [email protected]: Re: Waiver Application for Roofer Local No. 96 Health and WelfareFund
Dear Cam, rly contribution rate is $ for the bargaining participants. The Non-Bargaining composite monthly rate i
ontact me if you have any further questions for me.
hanks,Mike Theirl
Roofers L96:000020
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Please confirm whether the plan has lifetime or annual limits on ambulatory, emergency,hospitalization, laboratory, pediatric, maternity/newborn, mental health/substance abuse,r tive/devices, preventive/wellness, or prescription benefits and identify the correspondingli is plan never had annual limits for essential benefits. The major medical lifetime limit was$ which has been revoked with the first day of the plan year following September 23, 2010.
Please confirm whether the plan is in compliance with the interim final regulations relating to
grandfathered health plans. The plan is in full compliance with the interim final regulations relating t
grandfathered health plans.
Please provide the current monthly premium rates and the projected monthly premium rates applicab
to the plan or policy forms if the plan were to comply with the restricted annual benefits. In other
words, we would like a chart that reflects the following information: This is a composite rate (family
only) plan. No other elections have ever been permitted. The eligibility provisions for the plan are as
follows, which shows the minimum number of hours of collectively bargained work necessary for
coverage:
nitial Eligibility - Collective Bargained Employees
nitial Eligibility - Non-bargaining Unit Employees
Continuing Eligibility - Collective Bargained Employees
Any combination of the above may be used to continue eligibility.
Roofers L96:000022
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7/27/2019 Roofers Local 96 - Redacted Bates HWM
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will have the administrator confirm the existing contribution rate by a separate e-mail to you, as I am currentHawaii teaching at a conference. As we have no ability to increase employer contributions, the premium would remhe same and benefits would have to be slashed in an amount equal to the cost of stop loss insurance. I hope thats responsive to your request; please let me know if you have further inquiries.
2010 JanuaryPremium (currentlevel)
2011 JanuaryPremium (renewal)
2011 JanuaryPremium (if $750,000annual limit wasapplied)
EE
EE + Child (ifapplicable or otherappropriate tier)
EE + Spouse (ifapplicable or otherappropriate tier)
Family (if applicableor other appropriatetier)
n order to complete your application, please provide this information by 5:00 pm, November 17, 2010. We
ook forward to receiving your completed application. Thank you.
Roofers L96:000023
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7/27/2019 Roofers Local 96 - Redacted Bates HWM
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rom: Moultrie, Cam (HHS/OCIIO)ent: Friday, November 19, 2010 11:01 AM
To: [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]
ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFundan you provide COBRA equivalency rates?
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight.S. Department of Health and Human Services
301) 492-4174
rom: [email protected] [mailto:[email protected]]ent: Thursday, November 18, 2010 11:59 PMo: Moultrie, Cam (HHS/OCIIO)c: Habit, Sandra (HHS/OCIIO); [email protected]; [email protected]: Re: Waiver Application for Roofer Local No. 96 Health andWelfareFund
Cam,
he contribution rates are technically percent employer paid. However the total package is collectively bargainwith the health and welfare contributi mount a component of the participant's fringe fund package. There are noealth and welfare contribution rates yet for 2011, or forward, as that will depend on the allocation determination toach individual fringe benefit. In short, is waiver is not granted, any available collectively bargained amounts tllocated in future years will likely all ( percent) be required to be allocated to the health and welfare fund to rehe damage/hardship of the immediate e ination of the lifetime limit to the Fund, including likely money taken ohe participant/employees taxable wage and take home pay for the forseeable future.
lease contact me if you have any further questions. I have also cc'd Fund Counsel Pete Rosene in the event that heas any additional information to add to your inquiry.
incerely,Mike Theirl, CEBS
ent on the Sprint Now Network from my BlackBerry
rom: "Moultrie, Cam (HHS/OCIIO)" Date: Thu, 18 Nov 2010 11:44:21 -0500To: [email protected]: Habit, Sandra (HHS/OCIIO)
ubject: RE: Waiver Application for Roofer Local No. 96 Health and WelfareFund
lease provide total contribution rates (employee + employer) for 2010, 2011 and 2011 (if $the $750,000 annual limit was
pplied).
am Lynne Moultrie
rogram Analyst
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
[email protected] L96:000024
Document obtained by CompleteColorado.com
-
7/27/2019 Roofers Local 96 - Redacted Bates HWM
25/109
//T|/...0Local%20No.%2096%20Health%20and%20Welfare%20Fund/3rd%20reqeust%20for%20additional%20info%2011.19.10.htm[08/17/2011 10:18:
rom: [email protected] [mailto:[email protected]]ent: Wednesday, November 17, 2010 3:54 PMo: Moultrie, Cam (HHS/OCIIO); Peter M. Rosenec: Habit, Sandra (HHS/OCIIO); [email protected]: Re: Waiver Application for Roofer Local No. 96 Health and WelfareFund
Dear Cam, rly contribution rate is $ for the bargaining participants. The Non-Bargaining composite monthly rate i
. ontact me if you have any further questions for me.hanks,
Mike Theirl
ent on the Sprint Now Network from my BlackBerry
rom: "Moultrie, Cam (HHS/OCIIO)" Date: Wed, 17 Nov 2010 13:59:07 -0500To: Peter M. Rosene; [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]
ubject: RE: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
Mr. Rosene,
hank you for your response. I look forward to the contribution rates.
am Moultrie
am Lynne Moultrie
rogram Analyst
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
rom: Peter M. Rosene [mailto:[email protected]]ent: Tuesday, November 16, 2010 8:18 PMo: Moultrie, Cam (HHS/OCIIO); [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]: RE: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Tuesday, November 16, 2010 4:06 PMo: [email protected]; [email protected]: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
ear Mr. Rosene:
hank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section
711. In order to complete your application, please provide the following information:Roofers L96:000025
Document obtained by CompleteColorado.com
-
7/27/2019 Roofers Local 96 - Redacted Bates HWM
26/109
-
7/27/2019 Roofers Local 96 - Redacted Bates HWM
27/109
//T|/...0Local%20No.%2096%20Health%20and%20Welfare%20Fund/3rd%20reqeust%20for%20additional%20info%2011.19.10.htm[08/17/2011 10:18:
Continuing Eligibility - Collective Bargained Employees
will have the administrator confirm the existing contribution rate by a separate e-mail to you, as I am currentHawaii teaching at a conference. As we have no ability to increase employer contributions, the premium would remhe same and benefits would have to be slashed in an amount equal to the cost of stop loss insurance. I hope thats responsive to your request; please let me know if you have further inquiries.
2010 JanuaryPremium (current
level)
2011 JanuaryPremium (renewal)
2011 JanuaryPremium (if $750,000
annual limit wasapplied)
EE
EE + Child (ifapplicable or otherappropriate tier)
EE + Spouse (ifapplicable or otherappropriate tier)
Family (if applicableor other appropriate
tier)
n order to complete your application, please provide this information by 5:00 pm, November 17, 2010. We
ook forward to receiving your completed application. Thank you.
Roofers L96:000027
Document obtained by CompleteColorado.com
-
7/27/2019 Roofers Local 96 - Redacted Bates HWM
28/109
//T|/...96%20Health%20and%20Welfare%20Fund/3rd%20request%20for%20additional%20info%20correspondence%2011.19.10.htm[08/17/2011 10:18
rom: Peter M. Rosene [[email protected]]ent: Friday, November 19, 2010 11:24 AM
To: Moultrie, Cam (HHS/OCIIO); [email protected]: Habit, Sandra (HHS/OCIIO)
ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFundwill immediately forward this to our actuary; the problem we have is that the benefit schedule will need to be slashed
ramatically if we do not get the waiver. That is because we will have no additional source of employer funding due to th
BA, and if we deduct the money from the workers wage package, we will lose our grandfathered status. Therefore, slash
medical benefits for participants is the only way that we can balance the budget. The COBRA equivalency is difficult to knot this juncture, because we have not started slashing benefits before knowing if we will get the waiver.
will see if the actuary can give any other thoughts,
hanks,
ete Rosene
eneral Counsel
rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Friday, November 19, 2010 10:01 AMo: [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFund
an you provide COBRA equivalency rates?
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
rom: [email protected] [mailto:[email protected]]ent: Thursday, November 18, 2010 11:59 PMo: Moultrie, Cam (HHS/OCIIO)c: Habit, Sandra (HHS/OCIIO); [email protected]; [email protected]: Re: Waiver Application for Roofer Local No. 96 Health andWelfareFund
Cam,
he contribution rates are technically percent employer paid. However the total package is collectively bargain
with the health and welfare contributi mount a component of the participant's fringe fund package. There are noealth and welfare contribution rates yet for 2011, or forward, as that will depend on the allocation determination toach individual fringe benefit. In short, is waiver is not granted, any available collectively bargained amounts tllocated in future years will likely all ( percent) be required to be allocated to the health and welfare fund to rehe damage/hardship of the immediate ination of the lifetime limit to the Fund, including likely money taken ohe participant/employees taxable wage and take home pay for the forseeable future.
lease contact me if you have any further questions. I have also cc'd Fund Counsel Pete Rosene in the event that heas any additional information to add to your inquiry.
incerely,
Roofers L96:000028
Document obtained by CompleteColorado.com
-
7/27/2019 Roofers Local 96 - Redacted Bates HWM
29/109
//T|/...96%20Health%20and%20Welfare%20Fund/3rd%20request%20for%20additional%20info%20correspondence%2011.19.10.htm[08/17/2011 10:18
Mike Theirl, CEBS
ent on the Sprint Now Network from my BlackBerry
rom: "Moultrie, Cam (HHS/OCIIO)" Date: Thu, 18 Nov 2010 11:44:21 -0500To: [email protected]: Habit, Sandra (HHS/OCIIO)
ubject: RE: Waiver Application for Roofer Local No. 96 Health and WelfareFund
lease provide total contribution rates (employee + employer) for 2010, 2011 and 2011 (if $the $750,000 annual limit was
pplied).
am Lynne Moultrie
rogram Analyst
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
rom: [email protected] [mailto:[email protected]]ent: Wednesday, November 17, 2010 3:54 PMo: Moultrie, Cam (HHS/OCIIO); Peter M. Rosenec: Habit, Sandra (HHS/OCIIO); [email protected]: Re: Waiver Application for Roofer Local No. 96 Health and WelfareFund
Dear Cam, rly contribution rate is $ for the bargaining participants. The Non-Bargaining composite monthly rate i
ontact me if you have any further questions for me.
hanks,Mike Theirl
ent on the Sprint Now Network from my BlackBerry
rom: "Moultrie, Cam (HHS/OCIIO)" Date: Wed, 17 Nov 2010 13:59:07 -0500To: Peter M. Rosene; [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]
ubject: RE: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
Mr. Rosene,
hank you for your response. I look forward to the contribution rates.
am Moultrie
am Lynne Moultrie
rogram Analyst
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
Roofers L96:000029
Document obtained by CompleteColorado.com
-
7/27/2019 Roofers Local 96 - Redacted Bates HWM
30/109
//T|/...96%20Health%20and%20Welfare%20Fund/3rd%20request%20for%20additional%20info%20correspondence%2011.19.10.htm[08/17/2011 10:18
301) 492-4174
rom: Peter M. Rosene [mailto:[email protected]]ent: Tuesday, November 16, 2010 8:18 PMo: Moultrie, Cam (HHS/OCIIO); [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]: RE: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Tuesday, November 16, 2010 4:06 PMo: [email protected]; [email protected]: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
ear Mr. Rosene:
hank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section
711. In order to complete your application, please provide the following information:
In your application, your plan(s) or policy(ies) provide a lifetime limit. According to the regulation, y
may not have any lifetime limit on your plan, except in the case of non-essential benefits that are
permitted under Federal or State law. Effective September 23, 2010, you may no longer have a lifetim
limit on your plan or policy. Plans that previously had a lifetime limit may add an annual limit not les
than the lifetime limit without affecting the grandfather status of the plan. The Plan year, in this case
December 1 through November 30. The trustees have eliminated the lifetime maximum, as required b
law, effective with the first day of the plan year following September 23, 2010. Therefore, this plan w
have no lifetime limits as of December 1, 2010. We are asking to have an annual limit that correspon
with our old (and revoked) lifetime limit.
Please confirm whether the plan has lifetime or annual limits on ambulatory, emergency, hospitalizatlaboratory, pediatric, maternity/newborn, mental health/substance abuse, ative/devices,preventive/wellness, or prescription benefits and identify the correspondi . This plan never annual limits for essential benefits. The major medical lifetime limit was $ , which has beenrevoked with the first day of the plan year following September 23, 2010.
Please confirm whether the plan is in compliance with the interim final regulations relating to
grandfathered health plans. The plan is in full compliance with the interim final regulations relating t
grandfathered health plans.
Please provide the current monthly premium rates and the projected monthly premium rates applicab
to the plan or policy forms if the plan were to comply with the restricted annual benefits. In other
words, we would like a chart that reflects the following information: This is a composite rate (family
only) plan. No other elections have ever been permitted. The eligibility provisions for the plan are as
follows, which shows the minimum number of hours of collectively bargained work necessary for
coverage:
Roofers L96:000030
Document obtained by CompleteColorado.com
-
7/27/2019 Roofers Local 96 - Redacted Bates HWM
31/109
//T|/...96%20Health%20and%20Welfare%20Fund/3rd%20request%20for%20additional%20info%20correspondence%2011.19.10.htm[08/17/2011 10:18
nitial Eligibility - Non-bargaining Unit Employees
Continuing Eligibility - Collective Bargained Employees
will have the administrator confirm the existing contribution rate by a separate e-mail to you, as I am currentHawaii teaching at a conference. As we have no ability to increase employer contributions, the premium would remhe same and benefits would have to be slashed in an amount equal to the cost of stop loss insurance. I hope thats responsive to your request; please let me know if you have further inquiries.
2010 JanuaryPremium (currentlevel)
2011 JanuaryPremium (renewal)
2011 JanuaryPremium (if $750,000annual limit wasapplied)
EEEE + Child (ifapplicable or otherappropriate tier)
EE + Spouse (ifapplicable or otherappropriate tier)
Family (if applicableor other appropriatetier)
Roofers L96:000031
Document obtained by CompleteColorado.com
-
7/27/2019 Roofers Local 96 - Redacted Bates HWM
32/109
//T|/...96%20Health%20and%20Welfare%20Fund/3rd%20request%20for%20additional%20info%20correspondence%2011.19.10.htm[08/17/2011 10:18
n order to complete your application, please provide this information by 5:00 pm, November 17, 2010. We
ook forward to receiving your completed application. Thank you.
Roofers L96:000032
Document obtained by CompleteColorado.com
-
7/27/2019 Roofers Local 96 - Redacted Bates HWM
33/109
//T|/...ELLOW]/Roofers%20Local%20No.%2096%20Health%20and%20Welfare%20Fund/Additional%20response%2011.19.10.htm[08/17/2011 10:18:
rom: Peter M. Rosene [[email protected]]ent: Friday, November 19, 2010 8:22 AM
To: [email protected]; Moultrie, Cam (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO)
ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFundam,
dditionally, the trustees will need to reject contributions that come from employee wages if the amounts would cause a
f grandfathered status for the plan. In the end, only severe benefits cuts are available to this plan if it is to maintainrandfathered status.
eter Rosene
eneral Counsel
rom: [email protected] [mailto:[email protected]]ent: Thursday, November 18, 2010 10:59 PMo: Moultrie, Cam (HHS/OCIIO)c: Habit, Sandra (HHS/OCIIO); [email protected]; [email protected]: Re: Waiver Application for Roofer Local No. 96 Health andWelfareFund
Cam,
he contribution rates are technically percent employer paid. However the total package is collectively bargainwith the health and welfare contributi mount a component of the participant's fringe fund package. There are noealth and welfare contribution rates yet for 2011, or forward, as that will depend on the allocation determination toach individual fringe benefit. In short, is waiver is not granted, any available collectively bargained amounts tllocated in future years will likely all ( percent) be required to be allocated to the health and welfare fund to rehe damage/hardship of the immediate ination of the lifetime limit to the Fund, including likely money taken ohe participant/employees taxable wage and take home pay for the forseeable future.
lease contact me if you have any further questions. I have also cc'd Fund Counsel Pete Rosene in the event that heas any additional information to add to your inquiry.
incerely,Mike Theirl, CEBS
ent on the Sprint Now Network from my BlackBerry
rom: "Moultrie, Cam (HHS/OCIIO)" Date: Thu, 18 Nov 2010 11:44:21 -0500To: [email protected]: Habit, Sandra (HHS/OCIIO)
ubject: RE: Waiver Application for Roofer Local No. 96 Health and WelfareFund
lease provide total contribution rates (employee + employer) for 2010, 2011 and 2011 (if $the $750,000 annual limit was
pplied).
am Lynne Moultrie
rogram Analyst
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174Roofers L96:000033
Document obtained by CompleteColorado.com
-
7/27/2019 Roofers Local 96 - Redacted Bates HWM
34/109
//T|/...ELLOW]/Roofers%20Local%20No.%2096%20Health%20and%20Welfare%20Fund/Additional%20response%2011.19.10.htm[08/17/2011 10:18:
rom: [email protected] [mailto:[email protected]]ent: Wednesday, November 17, 2010 3:54 PMo: Moultrie, Cam (HHS/OCIIO); Peter M. Rosenec: Habit, Sandra (HHS/OCIIO); [email protected]: Re: Waiver Application for Roofer Local No. 96 Health and WelfareFund
Dear Cam,
ly contribution rate is $ for the bargaining participants. The Non-Bargaining composite monthly rate i
ontact me if you have any further questions for me.hanks,
Mike Theirl
ent on the Sprint Now Network from my BlackBerry
rom: "Moultrie, Cam (HHS/OCIIO)" Date: Wed, 17 Nov 2010 13:59:07 -0500To: Peter M. Rosene; [email protected]
Cc: Habit, Sandra (HHS/OCIIO); [email protected]: RE: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
Mr. Rosene,
hank you for your response. I look forward to the contribution rates.
am Moultrie
am Lynne Moultrie
rogram Analyst
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
rom: Peter M. Rosene [mailto:[email protected]]ent: Tuesday, November 16, 2010 8:18 PMo: Moultrie, Cam (HHS/OCIIO); [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]: RE: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Tuesday, November 16, 2010 4:06 PMo: [email protected]; [email protected]: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
ear Mr. Rosene:
hank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act SectionRoofers L96:000034
Document obtained by CompleteColorado.com
-
7/27/2019 Roofers Local 96 - Redacted Bates HWM
35/109
//T|/...ELLOW]/Roofers%20Local%20No.%2096%20Health%20and%20Welfare%20Fund/Additional%20response%2011.19.10.htm[08/17/2011 10:18:
711. In order to complete your application, please provide the following information:
In your application, your plan(s) or policy(ies) provide a lifetime limit. According to the regulation, y
may not have any lifetime limit on your plan, except in the case of non-essential benefits that are
permitted under Federal or State law. Effective September 23, 2010, you may no longer have a lifetim
limit on your plan or policy. Plans that previously had a lifetime limit may add an annual limit not les
than the lifetime limit without affecting the grandfather status of the plan. The Plan year, in this case
December 1 through November 30. The trustees have eliminated the lifetime maximum, as required b
law, effective with the first day of the plan year following September 23, 2010. Therefore, this plan w
have no lifetime limits as of December 1, 2010. We are asking to have an annual limit that correspon
with our old (and revoked) lifetime limit.
Please confirm whether the plan has lifetime or annual limits on ambulatory, emergency, hospitalizatlaboratory, pediatric, maternity/newborn, mental health/substance abuse, tative/devices,preventive/wellness, or prescription benefits and identify the correspondi . This plan never annual limits for essential benefits. The major medical lifetime limit was $ , which has beenrevoked with the first day of the plan year following September 23, 2010.
Please confirm whether the plan is in compliance with the interim final regulations relating to
grandfathered health plans. The plan is in full compliance with the interim final regulations relating t
grandfathered health plans.
Please provide the current monthly premium rates and the projected monthly premium rates applicab
to the plan or policy forms if the plan were to comply with the restricted annual benefits. In other
words, we would like a chart that reflects the following information: This is a composite rate (family
only) plan. No other elections have ever been permitted. The eligibility provisions for the plan are as
follows, which shows the minimum number of hours of collectively bargained work necessary for
coverage:
nitial Eligibility - Collective Bargained Employees
nitial Eligibility - Non-bargaining Unit Employees
Roofers L96:000035
Document obtained by CompleteColorado.com
-
7/27/2019 Roofers Local 96 - Redacted Bates HWM
36/109
//T|/...ELLOW]/Roofers%20Local%20No.%2096%20Health%20and%20Welfare%20Fund/Additional%20response%2011.19.10.htm[08/17/2011 10:18:
Continuing Eligibility - Collective Bargained Employees
will have the administrator confirm the existing contribution rate by a separate e-mail to you, as I am currentHawaii teaching at a conference. As we have no ability to increase employer contributions, the premium would remhe same and benefits would have to be slashed in an amount equal to the cost of stop loss insurance. I hope thats responsive to your request; please let me know if you have further inquiries.
2010 January
Premium (currentlevel)
2011 January
Premium (renewal)
2011 January
Premium (if $750,000annual limit wasapplied)
EE
EE + Child (ifapplicable or otherappropriate tier)
EE + Spouse (ifapplicable or otherappropriate tier)
Family (if applicable
or other appropriatetier)
n order to complete your application, please provide this information by 5:00 pm, November 17, 2010. We
ook forward to receiving your completed application. Thank you.
Roofers L96:000036
Document obtained by CompleteColorado.com
-
7/27/2019 Roofers Local 96 - Redacted Bates HWM
37/109
//T|/...YELLOW]/Roofers%20Local%20No.%2096%20Health%20and%20Welfare%20Fund/Request%20for%20info%2012.2.10.htm[08/17/2011 10:18
rom: Moultrie, Cam (HHS/OCIIO)ent: Thursday, December 02, 2010 7:13 PM
To: Peter M. Rosene; [email protected]: Habit, Sandra (HHS/OCIIO)
ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFundi,
ave you received a response from your actuary?
lease note that we cannot process your application until we have received all of the necessary information. You will rece
decision within 30 days of when we receive all of the requested information. We look forward to receiving your comple
pplication.
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
his information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribu
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
rom: Peter M. Rosene [mailto:[email protected]]ent: Friday, November 19, 2010 11:24 AMo: Moultrie, Cam (HHS/OCIIO); [email protected]
c: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFund
will immediately forward this to our actuary; the problem we have is that the benefit schedule will need to be slashed
ramatically if we do not get the waiver. That is because we will have no additional source of employer funding due to th
BA, and if we deduct the money from the workers wage package, we will lose our grandfathered status. Therefore, slash
medical benefits for participants is the only way that we can balance the budget. The COBRA equivalency is difficult to kno
t this juncture, because we have not started slashing benefits before knowing if we will get the waiver.
will see if the actuary can give any other thoughts,
hanks,
ete Rosene
eneral Counsel
rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Friday, November 19, 2010 10:01 AMo: [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFund
Roofers L96:000037
Document obtained by CompleteColorado.com
-
7/27/2019 Roofers Local 96 - Redacted Bates HWM
38/109
//T|/...YELLOW]/Roofers%20Local%20No.%2096%20Health%20and%20Welfare%20Fund/Request%20for%20info%2012.2.10.htm[08/17/2011 10:18
an you provide COBRA equivalency rates?
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
rom: [email protected] [mailto:[email protected]]ent: Thursday, November 18, 2010 11:59 PMo: Moultrie, Cam (HHS/OCIIO)c: Habit, Sandra (HHS/OCIIO); [email protected]; [email protected]: Re: Waiver Application for Roofer Local No. 96 Health andWelfareFund
Cam,
he contribution rates are technically percent employer paid. However the total package is collectively bargainwith the health and welfare contributi mount a component of the participant's fringe fund package. There are noealth and welfare contribution rates yet for 2011, or forward, as that will depend on the allocation determination to
ach individual fringe benefit. In short, if this waiver is not granted, any available collectively bargained amounts tollocated in future years will likely all ( percent) be required to be allocated to the health and welfare fund to rehe damage/hardship of the immediate e ination of the lifetime limit to the Fund, including likely money taken ohe participant/employees taxable wage and take home pay for the forseeable future.
lease contact me if you have any further questions. I have also cc'd Fund Counsel Pete Rosene in the event that heas any additional information to add to your inquiry.
incerely,Mike Theirl, CEBS
ent on the Sprint Now Network from my BlackBerry
rom: "Moultrie, Cam (HHS/OCIIO)" Date: Thu, 18 Nov 2010 11:44:21 -0500To: [email protected]: Habit, Sandra (HHS/OCIIO)
ubject: RE: Waiver Application for Roofer Local No. 96 Health and WelfareFund
lease provide total contribution rates (employee + employer) for 2010, 2011 and 2011 (if $the $750,000 annual limit was
pplied).
am Lynne Moultrierogram Analyst
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
rom: [email protected] [mailto:[email protected]]ent: Wednesday, November 17, 2010 3:54 PMo: Moultrie, Cam (HHS/OCIIO); Peter M. Rosene
Roofers L96:000038
Document obtained by CompleteColorado.com
-
7/27/2019 Roofers Local 96 - Redacted Bates HWM
39/109
//T|/...YELLOW]/Roofers%20Local%20No.%2096%20Health%20and%20Welfare%20Fund/Request%20for%20info%2012.2.10.htm[08/17/2011 10:18
c: Habit, Sandra (HHS/OCIIO); [email protected]: Re: Waiver Application for Roofer Local No. 96 Health and WelfareFund
Dear Cam, ly contribution rate is $ for the bargaining participants. The Non-Bargaining composite monthly rate i
ntact me if you have any further questions for me.
hanks,Mike Theirl
ent on the Sprint Now Network from my BlackBerry
rom: "Moultrie, Cam (HHS/OCIIO)" Date: Wed, 17 Nov 2010 13:59:07 -0500To: Peter M. Rosene; [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]
ubject: RE: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
Mr. Rosene,
hank you for your response. I look forward to the contribution rates.
am Moultrie
am Lynne Moultrie
rogram Analyst
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
rom: Peter M. Rosene [mailto:[email protected]]ent: Tuesday, November 16, 2010 8:18 PMo: Moultrie, Cam (HHS/OCIIO); [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]: RE: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Tuesday, November 16, 2010 4:06 PMo: [email protected]; [email protected]
c: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
ear Mr. Rosene:
hank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section
711. In order to complete your application, please provide the following information:
In your application, your plan(s) or policy(ies) provide a lifetime limit. According to the regulation, y
may not have any lifetime limit on your plan, except in the case of non-essential benefits that are
Roofers L96:000039
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permitted under Federal or State law. Effective September 23, 2010, you may no longer have a lifetim
limit on your plan or policy. Plans that previously had a lifetime limit may add an annual limit not les
than the lifetime limit without affecting the grandfather status of the plan. The Plan year, in this case
December 1 through November 30. The trustees have eliminated the lifetime maximum, as required b
law, effective with the first day of the plan year following September 23, 2010. Therefore, this plan w
have no lifetime limits as of December 1, 2010. We are asking to have an annual limit that correspon
with our old (and revoked) lifetime limit.
Please confirm whether the plan has lifetime or annual limits on ambulatory, emergency,hospitalization, laboratory, pediatric, maternity/newborn, mental health/substance abuse,r ive/devices, preventive/wellness, or prescription benefits and identify the correspondingli is plan never had annual limits for essential benefits. The major medical lifetime limit was$ which has been revoked with the first day of the plan year following September 23, 2010.
Pl irm whether the plan is in compliance with the interim final regulations relating to
grandfathered health plans. The plan is in full compliance with the interim final regulations relating t
grandfathered health plans.
Please provide the current monthly premium rates and the projected monthly premium rates applicab
to the plan or policy forms if the plan were to comply with the restricted annual benefits. In other
words, we would like a chart that reflects the following information: This is a composite rate (family
only) plan. No other elections have ever been permitted. The eligibility provisions for the plan are as
follows, which shows the minimum number of hours of collectively bargained work necessary for
coverage:
nitial Eligibility - Collective Bargained Employees
nitial Eligibility - Non-bargaining Unit Employees
Continuing Eligibility - Collective Bargained EmployeesRoofers L96:000040
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INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
his information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribu
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
rom: Peter M. Rosene [mailto:[email protected]]ent: Friday, November 19, 2010 11:24 AM
o: Moultrie, Cam (HHS/OCIIO); [email protected]: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFund
will immediately forward this to our actuary; the problem we have is that the benefit schedule will need to be slashed
ramatically if we do not get the waiver. That is because we will have no additional source of employer funding due to th
BA, and if we deduct the money from the workers wage package, we will lose our grandfathered status. Therefore, slash
medical benefits for participants is the only way that we can balance the budget. The COBRA equivalency is difficult to kno
t this juncture, because we have not started slashing benefits before knowing if we will get the waiver.
will see if the actuary can give any other thoughts,
hanks,
ete Rosene
eneral Counsel
rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Friday, November 19, 2010 10:01 AMo: [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFund
an you provide COBRA equivalency rates?
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
rom: [email protected] [mailto:[email protected]]ent: Thursday, November 18, 2010 11:59 PM
o: Moultrie, Cam (HHS/OCIIO)c: Habit, Sandra (HHS/OCIIO); [email protected]; [email protected]: Re: Waiver Application for Roofer Local No. 96 Health andWelfareFund
Cam,
he contribution rates are technically percent employer paid. However the total package is collectively bargainwith the health and welfare contributi mount a component of the participant's fringe fund package. There are noealth and welfare contribution rates yet for 2011, or forward, as that will depend on the allocation determination toach individual fringe benefit. In short, is waiver is not granted, any available collectively bargained amounts tllocated in future years will likely all ( percent) be required to be allocated to the health and welfare fund to re
Roofers L96:000043
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he damage/hardship of the immediate elimination of the lifetime limit to the Fund, including likely money taken ofhe participant/employees taxable wage and take home pay for the forseeable future.
lease contact me if you have any further questions. I have also cc'd Fund Counsel Pete Rosene in the event that heas any additional information to add to your inquiry.
incerely,Mike Theirl, CEBS
ent on the Sprint Now Network from my BlackBerry
rom: "Moultrie, Cam (HHS/OCIIO)" Date: Thu, 18 Nov 2010 11:44:21 -0500To: [email protected]: Habit, Sandra (HHS/OCIIO)
ubject: RE: Waiver Application for Roofer Local No. 96 Health and WelfareFund
lease provide total contribution rates (employee + employer) for 2010, 2011 and 2011 (if $the $750,000 annual limit was
pplied).
am Lynne Moultrie
rogram Analyst
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
rom: [email protected] [mailto:[email protected]]ent: Wednesday, November 17, 2010 3:54 PMo: Moultrie, Cam (HHS/OCIIO); Peter M. Rosene
c: Habit, Sandra (HHS/OCIIO); [email protected]: Re: Waiver Application for Roofer Local No. 96 Health and WelfareFund
Dear Cam, ly contribution rate is $ for the bargaining participants. The Non-Bargaining composite monthly rate i
ontact me if you have any further questions for me.
hanks,Mike Theirl
ent on the Sprint Now Network from my BlackBerry
rom: "Moultrie, Cam (HHS/OCIIO)" Date: Wed, 17 Nov 2010 13:59:07 -0500To: Peter M. Rosene; [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]
ubject: RE: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
Mr. Rosene,
hank you for your response. I look forward to the contribution rates.
Roofers L96:000044
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to the plan or policy forms if the plan were to comply with the restricted annual benefits. In other
words, we would like a chart that reflects the following information: This is a composite rate (family
only) plan. No other elections have ever been permitted. The eligibility provisions for the plan are as
follows, which shows the minimum number of hours of collectively bargained work necessary for
coverage:
nitial Eligibility - Collective Bargained Employees
nitial Eligibility - Non-bargaining Unit Employees
Continuing Eligibility - Collective Bargained Employees
will have the administrator confirm the existing contribution rate by a separate e-mail to you, as I am current
Hawaii teaching at a conference. As we have no ability to increase employer contributions, the premium would remhe same and benefits would have to be slashed in an amount equal to the cost of stop loss insurance. I hope thats responsive to your request; please let me know if you have further inquiries.
2010 JanuaryPremium (currentlevel)
2011 JanuaryPremium (renewal)
2011 JanuaryPremium (if $750,000annual limit wasapplied)
EE
EE + Child (ifapplicable or other
Roofers L96:000046
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appropriate tier)
EE + Spouse (ifapplicable or otherappropriate tier)
Family (if applicableor other appropriatetier)
n order to complete your application, please provide this information by 5:00 pm, November 17, 2010. We
ook forward to receiving your completed application. Thank you.
Roofers L96:000047
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rom: Moultrie, Cam (HHS/OCIIO)ent: Monday, December 13, 2010 3:00 PM
To: Peter M. Rosene; [email protected]; 'Helmer, Michael'Cc: Habit, Sandra (HHS/OCIIO)
ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFundappreciate the information, but what I am looking for is either 1) the average contributions per employee (per month), o
he COBRA equivalency rates. Please use the following table as a guide:
2010 JanuaryContributions/Premium(current level)
2011 JanuaryContribution/Premium(renewal)
2011 JanuaryContribution/Premium(if $750,000 annuallimit was applied)
EE
EE + Child (ifapplicable or otherappropriate tier)
EE + Spouse (ifapplicable or otherappropriate tier)
Family (if applicableor other appropriatetier)
hank you for your attention to this matter.
am
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
his information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribu
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
rom: Peter M. Rosene [mailto:[email protected]]ent: Tuesday, December 07, 2010 4:13 PMo: Moultrie, Cam (HHS/OCIIO); [email protected]; 'Helmer, Michael'c: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFund
Dear Cam,
hank you for your patience. I am providing information from our actuary that I think gets to the heart of wou are looking for; before that, please recall for this Taft-Hartley Multi-Employer Plan, that the employer
Roofers L96:000048
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49/109
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ontributions are constrained by the collective bargaining agreements that were in effect on September 23010. Because of this, no further employer contributions would be available. Any increased costs mustither come by virtue of benefit reductions or from the workers pay as additional co-insurance for premiumither scenario assures loss of Grandfathered Status.
Our Actuary, Mr. Michael Helmer, E.A., from the Segal Company provided the following:
f the Fund doe get the waiver the ave to cut benefits. If the Fund cuts benefits it'll lose GF stat
which will cost $ equates to $ PMPM which se pretty harsh for a group of employees thurrently contrib $ per hour to That's an extra hours a month of employment to pay fohe additional cost br t about by ACA in an economic en ment that sees shedding eligibility becauhe lack of work won't sustain the hours necessary to pro he current membership coverage. The botne is that we're asking for a waiver from the additional $ PMPM for a group of relatively low wagemployees.
Please let me know if you need anything further.
Peter RoseneGeneral Counsel
rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Thursday, December 02, 2010 6:13 PMo: Peter M. Rosene; [email protected]: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFund
i,
ave you received a response from your actuary?
lease note that we cannot process your application until we have received all of the necessary information. You will rece
decision within 30 days of when we receive all of the requested information. We look forward to receiving your comple
pplication.
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
his information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribu
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
rom: Peter M. Rosene [mailto:[email protected]]ent: Friday, November 19, 2010 11:24 AMo: Moultrie, Cam (HHS/OCIIO); [email protected]
Roofers L96:000049
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//T|/...ELLOW]/Roofers%20Local%20No.%2096%20Health%20and%20Welfare%20Fund/Request%20for%20info%2012.13.10.htm[08/17/2011 10:18:
rom: "Moultrie, Cam (HHS/OCIIO)" Date: Thu, 18 Nov 2010 11:44:21 -0500To: [email protected]: Habit, Sandra (HHS/OCIIO)
ubject: RE: Waiver Application for Roofer Local No. 96 Health and WelfareFund
lease provide total contribution rates (employee + employer) for 2010, 2011 and 2011 (if $the $750,000 annual limit was
pplied).
am Lynne Moultrie
rogram Analyst
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
rom: [email protected] [mailto:[email protected]]ent: Wednesday, November 17, 2010 3:54 PM
o: Moultrie, Cam (HHS/OCIIO); Peter M. Rosenec: Habit, Sandra (HHS/OCIIO); [email protected]: Re: Waiver Application for Roofer Local No. 96 Health and WelfareFund
Dear Cam, ly contribution rate is $ for the bargaining participants. The Non-Bargaining composite monthly rate i
ntact me if you have any further questions for me.
hanks,Mike Theirl
ent on the Sprint Now Network from my BlackBerry
rom: "Moultrie, Cam (HHS/OCIIO)" Date: Wed, 17 Nov 2010 13:59:07 -0500To: Peter M. Rosene; [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]
ubject: RE: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
Mr. Rosene,
hank you for your response. I look forward to the contribution rates.
am Moultrie
am Lynne Moultrie
rogram Analyst
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
Roofers L96:000051
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7/27/2019 Roofers Local 96 - Redacted Bates HWM
52/109
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rom: Peter M. Rosene [mailto:[email protected]]ent: Tuesday, November 16, 2010 8:18 PMo: Moultrie, Cam (HHS/OCIIO); [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]: RE: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Tuesday, November 16, 2010 4:06 PMo: [email protected]; [email protected]: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application for Roofer Local No. 96 Health and Welfare Fund
ear Mr. Rosene:
hank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section
711. In order to complete your application, please provide the following information:
In your application, your plan(s) or policy(ies) provide a lifetime limit. According to the regulation, y
may not have any lifetime limit on your plan, except in the case of non-essential benefits that arepermitted under Federal or State law. Effective September 23, 2010, you may no longer have a lifetim
limit on your plan or policy. Plans that previously had a lifetime limit may add an annual limit not les
than the lifetime limit without affecting the grandfather status of the plan. The Plan year, in this case
December 1 through November 30. The trustees have eliminated the lifetime maximum, as required b
law, effective with the first day of the plan year following September 23, 2010. Therefore, this plan w
have no lifetime limits as of December 1, 2010. We are asking to have an annual limit that correspon
with our old (and revoked) lifetime limit.
Please confirm whether the plan has lifetime or annual limits on ambulatory, emergency,
h ation, laboratory, pediatric, maternity/newborn, mental health/substance abuse,r tive/devices, preventive/wellness, or prescription benefits and identify the correspondingli is plan never had annual limits for essential benefits. The major medical lifetime limit was$ which has been revoked with the first day of the plan year following September 23, 2010.
Pl irm whether the plan is in compliance with the interim final regulations relating to
grandfathered health plans. The plan is in full compliance with the interim final regulations relating t
grandfathered health plans.
Please provide the current monthly premium rates and the projected monthly premium rates applicab
to the plan or policy forms if the plan were to comply with the restricted annual benefits. In other
words, we would like a chart that reflects the following information: This is a composite rate (family
only) plan. No other elections have ever been permitted. The eligibility provisions for the plan are as
follows, which shows the minimum number of hours of collectively bargained work necessary for
coverage:
nitial Eligibility - Collective Bargained Employees
Roofers L96:000052
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nitial Eligibility - Non-bargaining Unit Employees
Continuing Eligibility - Collective Bargained Employees
will have the administrator confirm the existing contribution rate by a separate e-mail to you, as I am current
Hawaii teaching at a conference. As we have no ability to increase employer contributions, the premium would remhe same and benefits would have to be slashed in an amount equal to the cost of stop loss insurance. I hope thats responsive to your request; please let me know if you have further inquiries.
2010 JanuaryPremium (currentlevel)
2011 JanuaryPremium (renewal)
2011 JanuaryPremium (if $750,000annual limit wasapplied)
EE
EE + Child (ifapplicable or other
appropriate tier)
EE + Spouse (ifapplicable or otherappropriate tier)
Family (if applicableor other appropriatetier)
n order to complete your application, please provide this information by 5:00 pm, November 17, 2010. We
Roofers L96:000053
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7/27/2019 Roofers Local 96 - Redacted Bates HWM
54/109
//T|/...ELLOW]/Roofers%20Local%20No.%2096%20Health%20and%20Welfare%20Fund/Request%20for%20info%2012.13.10.htm[08/17/2011 10:18:
ook forward to receiving your completed application. Thank you.
Roofers L96:000054
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55/109
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rom: Helmer, Michael [[email protected]]ent: Tuesday, December 14, 2010 11:00 AM
To: Moultrie, Cam (HHS/OCIIO); 'Peter M. Rosene'; '[email protected]'Cc: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFund
Per Month 2010 JanuaryContributions/Premium(current level)
2011 JanuaryContribution/Premium(renewal)
2011 JanuaryContribution/Premium(if $750,000 annual
Composite
Good morning Cam -Above are projected COBRA rates as follows:
Current rate $ Projected 2011 COBRA rate under current plan designProjected 2011 COBRA rate without Waiver approval $
Currently the COBRA rates are developed using a composite strategy where everyone pay sa tegardless of single, 2 party or family status or age. The increase shown above from the $ to $
ncludes the purchase of stoploss to account for the added risk to the plan should the plan be a eor the Waiver.
you need any additional information, please let me know.
hank you
Michael Helmer EA, MAAA
rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Monday, December 13, 2010 2:00 PMo: Peter M. Rosene; [email protected]; Helmer, Michaelc: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFund
appreciate the information, but what I am looking for is either 1) the average contributions per employee (per month), o
he COBRA equivalency rates. Please use the following table as a guide:
2010 JanuaryContributions/Premium(current level)
2011 JanuaryContribution/Premium(renewal)
2011 JanuaryContribution/Premium(if $750,000 annual
limit was applied)EE
EE + Child (ifapplicable or otherappropriate tier)
EE + Spouse (ifapplicable or otherappropriate tier)
Family (if applicableor other appropriatetier)
Roofers L96:000055
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56/109
//T|/...ofers%20Local%20No.%2096%20Health%20and%20Welfare%20Fund/Request%20for%20info%20response%2012.14.10.htm[08/17/2011 10:18:
hank you for your attention to this matter.
am
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services301) 492-4174
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
his information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribu
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
rom: Peter M. Rosene [mailto:[email protected]]ent: Tuesday, December 07, 2010 4:13 PMo: Moultrie, Cam (HHS/OCIIO); [email protected]; 'Helmer, Michael'c: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFund
Dear Cam,
hank you for your patience. I am providing information from our actuary that I think gets to the heart of wou are looking for; before that, please recall for this Taft-Hartley Multi-Employer Plan, that the employerontributions are constrained by the collective bargaining agreements that were in effect on September 23010. Because of this, no further employer contributions would be available. Any increased costs mustither come by virtue of benefit reductions or from the workers pay as additional co-insurance for premiumither scenario assures loss of Grandfathered Status.
Our Actuary, Mr. Michael Helmer, E.A., from the Segal Company provided the following:
f the Fund doe get the waiver the ave to cut benefits. If the Fund cuts benefits it'll lose GF statwhich will cost $ equates to $ PMPM which se pretty harsh for a group of employees thurrently contrib $ per hour to H&W. That's an extra hours a month of employment to pay fohe additional cost brought about by ACA in an economic environment that sees shedding eligibility becau
he lack of work won't sustain the hours necessary to provide the current membership coverage. The botne is that we're asking for a waiver from the additional $ PMPM for a group of relatively low wagemployees.
Please let me know if you need anything further.
Peter RoseneGeneral Counsel
Roofers L96:000056
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57/109
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rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Thursday, December 02, 2010 6:13 PMo: Peter M. Rosene; [email protected]: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFund
i,
ave you received a response from your actuary?
lease note that we cannot process your application until we have received all of the necessary information. You will rece
decision within 30 days of when we receive all of the requested information. We look forw