neca ibew local 4 - redacted bates hwm

8/22/2019 NECA IBEW Local 4 - Redacted Bates HWM

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//T|/...EW%20Local%20480%20Health%20&%20Welfare%20Plan/Waiver%20of%20the%20Annual%20Limits%20Requirement.htm[08/26/2011 4:03:1

rom: Michele La Motte [[email protected]]ent: Thursday, November 11, 2010 12:44 PM

To: HHS HealthInsurance (HHS)ubject: Waiver of the Annual Limits Requirement

Attachments: Waiver Application for Annual Limits--Signed.pdfear Office of Consumer Information and Insurance Oversight, Office of Oversight

ttention: James Mayhew

lease see attached the Application for Waiver of the Annual Limits Requirement of Public Health Service Act wh

as been prepared and signed on November 10, 2010 and submitted on November 11, 2010 on behalf of: NECA-

BEW Local 480 Health and Welfare Plan.

hank you for your consideration.

incerely,

Michele LaMotte

enefits Consultant

HA Consulting LLC

400 Laurel Springs Pkwy, Suite 1306

uwanee, GA 30024

78-456-6200 x. 18

78-456-6205 (fax)

_________ Information from ESET NOD32 Antivirus, version of virus signature database 5612 (20101111)_________

he message was checked by ESET NOD32 Antivirus.

ttp://www.eset.com

NECA-IBEW L4:000001

Document obtained by CompleteColorado.com
http://www.eset.com/http://www.eset.com/


2/20

N.E.C.A. - I.B.E.W. LOCAL 480 Health & Welfare Plan

P. O. Box 6467 JACKSON, MISSISSIPPI 39282-6467

. ~ 1 7

Application for Waiver of the Annual Limits Requirement of Public Health Service Act Section 2711

Prepared and submitted on behalf of: NECA-IBEW Local 480 Health and Welfare Plan

The purpose of this document is to request that the Secretary ofHealth and Human Services waive the annual limit restrictions set forth in Section 2711(a)(2) of the Public Health Service Act and established in the interim final regulations promulgated thereunder, for the following group health plan: .i\TECA-IBEW Local 480 Health and Welfare Plan (the "Plan")

This Plan was offered prior to September 23, 2010. Accordingly, the Plan was offered prior to September 23, 2010 for its first plan yearbeginning between September 23, 2010, and September 23,2011. The first day of the Plan's Plan Year is January 1 and this application is hereby in excess ofthirty (30) days in advance of that date.

I. TERMS OF THE PLANThe terms of the Plan for which a waiver is sought:Plan Name:NECA-IBEW Local 480 Health and Welfare PlanPlan Year:January 1-December 31Type of PlanlBenefits Provided under the PlanThe Plan is a collectively bargained health and welfare plan that offers medical, dental, prescriptiondrug, life insurance and accidental death and dismemberment benefits to eligible participants andtheir dependents.

NECA-IBEW L4:000002



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AdministrationThe Plan is administered by a Board of Trustees, which consists of both Union and Employerrepresentatives, selected by the Union and the Employers who have entered into collectivebargaining agreements, which relate to the Plan. The day-to-day administration of the Fund ishandled by:NECA-IBEW Local 480 Health and Welfare PlanAttn: Joel HillP.O. Box 6467J a c k s o n , ~ S 39282Source of ContributionsAll contributions to the Plan are made by Employers in accordance with Collective BargainingAgreements with employee representatives, except for COBRA contributions made by participantsor beneficiaries. The Collective Bargaining Agreements require contributions to the Plan at a fixedrate per hour worked. The Plan also receives contributions on behalf of certain non-collectivelybargaining participants pursuant to written participation agreements between the Fund andEmployers, which agreements provide for periodic contributions at fixed rates per month. Retireesalso make contributions to the Plan.Benefit FundingBenefits are provided from the Fund's assets which are accumulated under the provisions of theCollective Bargaining Agreement and the Trust Agreement and held in a Trust Fund for the purposeof providing benefits to covered persons and defraying reasonable administrative expenses. Allassets and reserves are held in trust and invested by the Board of Trustees pursuant to fiduciarystandards required by federal law,II. COVERED INDIVIDUALSAs of the date ofthis submission, the Plan covers approximately active and retiree employees,plus dependents, for a total of covered persons.III. ANNUAL LIMITSThe list below outlines the Plan's current annual limits, as well as lifetime limits which will beconverted to an annual limit for the next Plan Year:

Annual ~ a x i m u m Benefit $ IndividualAnnual Therapy Visits ~ a x i m u m Benefit $ IndividualAnnual Chiropractic ~ a x i m u m Benefit $ IndividualAnnual Dental ~ a x i m u m Benefit $ Individual

2 NECA-IBEW L4:000003



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IV. COMPLIANCE IMPLICATIONSCompliance with the interim final regulations regarding maximum annual plan benefits will result ina significant decrease in access to benefits for Plan participants and their beneficiaries. The Plan'sConsultant has indicated that if the above-mentioned limits are eliminated, the Plan \\ti e nochoice but to purchase reinsurance. The Plan anticipates a reinsurance premium of $ pereligible per month based on preliminary quotations received from several reinsurance issuers toreinsure from the current $ annual limit up to the $750,000 annual maximum allowed forcalendar year 2011. The total additional monthly costs in self-funded claims and reinsurance isestimated at $ or $ for the year 2011.In addition to the costs associated with reinsurance for the waiver of the major medical maximum,the Fund's Consultant has also estimated costs associated with the removal of the other annualbenefit limitations contained within the Plan relating to chiropractic and therapy services at $ .This brings the total cost of compliance to $ , an increase of over % over the cost ofbenefits prior to the implementation of PPACA.If the expected costs of implementing the annual limit restrictions in 2011 were to be passed ondirectly to covered employees and retirees, the resulting annual contribution increases would beapproximately $ per month per employee/retiree.Contribution rates are set pursuant to Collective Bargaining Agreements, and the Agreementcovering the large majority ofparticipants does not expire until December 31,2013. The rates set inthese agreements address projected Plan costs anticipated without PPACA mandates. Any increasein hourly contributions would have to be agreed to via contract reopeners. It is reasonably expectedthat the employers will not agree to absorb such PPACA-related increases. The bargaining partieswould then have to seek agreement to re-allocate monies from wages to the Health and Welfare Planfringe benefit rate. In short, employees would have to suffer a wage cut to fund the increase.The wage shift, ifagreed to by employers, would be $ per hour. This would constitute a severeincrease in "premium" costs borne by covered employees.The reduction in the wage for covered workers would render the sponsoring labor organization, whoconstantly recruits skilled craftsmen for referral to employers, highly non-competitive in a tight labormarket. Signatory employers would likewise be affected.




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v. ATTESTATIONWe, Alton Ware and JohnH. Smith, Jr., currently serve as the Co-Chairmen ofthe Board ofTrusteesof the NECA-IBEW Local 480 Health and Welfare Plan ("Plan"). Pursuant to Article 1, Section 1.1of the Plan, the Board ofTrustees serves as the Plan Administrator for the (the "Plan"). We herebyattest as follows:

1) the Plan was in force prior to September 23, 2010; and2) the application of restricted annual limits to the Plan would result in a significantdecrease in access to benefits for those currently covered by the Plan, or a significant increase inpremiums paid by those covered by the Plan.

~ W4tA.&- / ~ u ~ .Co-Chairmen ~ __ C O - C h a i r m e n ~ J : ('-




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//T|/...]/NECA-IBEW%20Local%20480%20Health%20&%20Welfare%20Plan/Request%20for%20additional%20info%2011.19.10.htm[08/26/2011 4:03

rom: Scelzo, Kathleen (HHS/OCIIO)ent: Friday, November 19, 2010 10:03 AM

To: '[email protected]'Cc: Habit, Sandra (HHS/OCIIO)ubject: NECA-IBEW Local 480 Waiver Application

mportance: High

Attachments: NECA IBEW Local 480 Waiver Application Questions.docMichele LaMotte,eft a message for you this morning alerting you about an e-mail you would receive from me concerning NECA-IBEW Local 4

pplication for Annual Limits Requirements of the PHS Act Section 2711. Attached above is the document that needs to be

ompleted in order to finalize the application process.

Many thanks for your assistance with this document.

athleen M. Scelzo, RN, MSN

ules Compliance Division

ffice of Insurance Oversight

ffice of Consumer Information and Insurance Oversight (OCIIO)

epartment of Health and Human Services501 Wisconsin Avenue

ethesda, MD

01-492-4121

NECA-IBEW L4:000006



7/20

November 19, 2010

Dear Applicant:

RE: Living Resources

Thank you for your application for the Waiver of the Annual Limits Requirements of

the PHS Act Section 2711. In order to complete your application, please provide the

following information about the Living Resources:

1. Indicate if there are essential benefit limits and the amount for the followingcategories :

Ambulatory: $Emergency (ER): $

Hospitalization: $Laboratory: $Pediatric: $

Maternity: $Mental Health/Substance Abuse: $

Rehabiliative: $Preventive: $Prescription (RX): $

2. (The premium amounts is the total cost to the employer and the employee)Premium(Current)

Premium(renewal)

Premium(if $750,000annual limitwas applied)

% increase if the$750,000 wasimplemented

EE

EE + Child (ifapplicable orother appropriatetier)

EE + Spouse (ifapplicable orother appropriatetier)

Family (ifapplicable or

other appropriatetier)

3. Indicate if there are any deductibles for the plan and the amount.

NECA-IBEW L4:000007



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4. Indicate if there are any copay/coinsurance for the plan for the followingcategories and the amount for the following:

Office Visit Inpatient ER Prescription

5. Indicate if the plan is fully-insured plan or a self-insured plan.6. Indicate if the plan is Group or Individual7. Indicate if this plan has Grandfather Status.

Please provide this information by 5:00 pm Monday November 22, 2010. We look

forward to receiving your completed application. Thank you.

Sincerely,

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

301-492-4121

NECA-IBEW L4:000008



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//T|/...%20Local%20480%20Health%20&%20Welfare%20Plan/Request%20for%20additional%20info%20response%2011.22.10.htm[08/26/2011 4:03:5

rom: Michele La Motte [[email protected]]ent: Monday, November 22, 2010 1:17 PM

To: Scelzo, Kathleen (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO)ubject: RE: NECA-IBEW Local 480 Waiver Application

Attachments: NECA IBEW Local 480 Waiver Application Questions from Dept of HHS.pdfear Ms. Scelzo,

have completed and attached the Waiver Application Questions Form that you sent to me this past Friday for the NECA-

BEW Local 480 Health and Welfare Fund.

nce the Plan is self-insured, there are no premiums that are paid for health coverage. However, I have included the

remium information that you required because we calculate the COBRA premium rates on a per capita basis.

lease let me know if there are any additional questions. Thank you for your consideration.

ncerely,

Michele LaMotte

enefits Consultant

HA Consulting LLC


uwanee, GA 30024

78-456-6200 x. 18

78-456-6205 (fax)

rom: Scelzo, Kathleen (HHS/OCIIO) [mailto:[email protected]]

ent: Friday, November 19, 2010 10:03 AMo: Michele La Mottec: Habit, Sandra (HHS/OCIIO)ubject: NECA-IBEW Local 480 Waiver Applicationmportance: High

Michele LaMotte,

eft a message for you this morning alerting you about an e-mail you would receive from me concerning NECA-IBEW Local 4








epartment of Health and Human Services

501 Wisconsin Avenue

ethesda, MD

01-492-4121

NECA-IBEW L4:000009



10/20

//T|/...ocal%20480%20Health%20&%20Welfare%20Plan/Request%20for%20additional%20info%20response%20(2)%2011.22.10.htm[08/26/2011 4:03

rom: Michele La Motte [[email protected]]ent: Monday, November 22, 2010 3:17 PM

To: Scelzo, Kathleen (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO)ubject: RE: NECA-IBEW Local 480 Waiver Application

Attachments: NECA IBEW Local 480 Waiver Application Questions from Dept of HHS.pdfear Ms. Scelzo,

am attaching a revised Waiver Application Questions for the NECA-IBEW Local 480 Health and Welfare Fund in lieu of the

orm I sent two hours ago. The % increase for the premium is % and not %.hanks,

Michele LaMotte

enefits Consultant

HA Consulting LLC


uwanee, GA 30024

78-456-6200 x. 18

78-456-6205 (fax)

rom: Michele La Motteent: Monday, November 22, 2010 1:17 PMo: 'Scelzo, Kathleen (HHS/OCIIO)'c: '[email protected]'ubject: RE: NECA-IBEW Local 480 Waiver Application

ear Ms. Scelzo,

have completed and attached the Waiver Application Questions Form that you sent to me this past Friday for the NECA-

BEW Local 480 Health and Welfare Fund.

nce the Plan is self-insured, there are no premiums that are paid for health coverage. However, I have included the

remium information that you required because we calculate the COBRA premium rates on a per capita basis.

lease let me know if there are any additional questions. Thank you for your consideration.

ncerely,

Michele LaMotte

enefits Consultant

HA Consulting LLC


uwanee, GA 30024

78-456-6200 x. 18

78-456-6205 (fax)

NECA-IBEW L4:000010



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//T|/...ocal%20480%20Health%20&%20Welfare%20Plan/Request%20for%20additional%20info%20response%20(2)%2011.22.10.htm[08/26/2011 4:03

rom: Scelzo, Kathleen (HHS/OCIIO) [mailto:[email protected]]ent: Friday, November 19, 2010 10:03 AMo: Michele La Mottec: Habit, Sandra (HHS/OCIIO)ubject: NECA-IBEW Local 480 Waiver Applicationmportance: High

Michele LaMotte,

eft a message for you this morning alerting you about an e-mail you would receive from me concerning NECA-IBEW Local 4








epartment of Health and Human Services

501 Wisconsin Avenueethesda, MD

01-492-4121

NECA-IBEW L4:000011



12/20

November 19, 2010

Dear Applicant:

RE: NECA-IBEW Local 480 Health and Welfare Plan

Thank you for your application for the Waiver of the Annual Limits Requirements ofthe PHS Act Section 2711. In order to complete your application, please provide thefollowing information about the NECA-IBEW Local 480 Health and Welfare Plan.


The following all count toward the currentper person annual maximum of $ except as otherwise noted:

Ambulatory: $ Emergency (ER): $ Hospitalization: $ Laboratory: $ Pediatric: $

Maternity: $ Mental Health/Substance Abuse:

$ Rehabiliative: $ Preventive: $ Prescription (RX): $


Premium(renewal)

Premium(if $750,000

annual limit

% increase if the$750,000 was

implemented

EE

EE + Child

EE + Spouse

Family


All Deductibles are per person.

Annual Deductible: $ per calendar year.Hospital Admission Deductible: $ per calendar year.Outpatient Surgical Facility Deductible: $ per calendar year.Emergency Room Deductible: $ per visit.Prescription Drug Deductible: $ per calendar year.

NECA-IBEW L4:000012



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4. Indicate if there are any copay/coinsurance for the plan for the following

categories and the amount for the following: Office Visit

If PPO Physician:$ CopayAndcoinsurance forlabwork/minorsurgery in office

If Non-PPO:Deductible, then

coinsurance

Inpatient

If PPO facility:Plan pays % afterthe deductible

If Non-PPO:Plan pays % afterthe deductible

ER


If Non-PPO:Plan pays % afterthe deductible. Or,Plan pays % ifmember lives andreceives treatmentoutside 35 mile

radius of PPOfacility.

Prescription

After the $ deductible,the copays are as follows:Retail Prescriptions:Generic: $ Preferred Brand Name:$ Non-Preferred BrandName: $ Mail Order Prescriptions

(90-day s :Generic: $ Preferred Brand Name:$ Non-Pre BrandName: $

5. Indicate if the plan is fully-insured plan or a self-insured plan.SELF-INSURED

6. Indicate if the plan is Group or IndividualGROUP

7. Indicate if this plan has Grandfather Status.YES, THE PLAN IS GRANDFATHERED.

Please provide this information by 5:00 pm Monday November 22, 2010. We lookforward to receiving your completed application. Thank you.

Sincerely,

Kathleen M. Scelzo, RN, MSNRules Compliance DivisionOffice of Insurance OversightOffice of Consumer Information and Insurance Oversight (OCIIO)Department of Health and Human Services301-492-4121

NECA-IBEW L4:000013



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November 19, 2010

Dear Applicant:

RE: NECA-IBEW Local 480 Health and Welfare Plan

Thank you for your application for the Waiver of the Annual Limits Requirements ofthe PHS Act Section 2711. In order to complete your application, please provide thefollowing information about the NECA-IBEW Local 480 Health and Welfare Plan.


The following all count toward the currentper person annual maximum of $ except as otherwise noted:

Ambulatory: $ Emergency (ER): $ Hospitalization: $ Laboratory: $ Pediatric: $

Maternity: $ Mental Health/Substance Abuse:

$ Rehabiliative: $ Preventive: $ Prescription (RX): $


Premium(renewal)

Premium(if $750,000

annual limit

% increase if the$750,000 was

implemented

EE

EE + Child

EE + Spouse

Family


All Deductibles are per person.

Annual Deductible: $ per calendar year.Hospital Admission Deductible: $ per calendar year.Outpatient Surgical Facility Deductible: $ per calendar year.Emergency Room Deductible: $ per visit.Prescription Drug Deductible: $ per calendar year.

NECA-IBEW L4:000014



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4. Indicate if there are any copay/coinsurance for the plan for the following

categories and the amount for the following: Office Visit

If PPO Physician:$ CopayAnd %coinsurance forlabwork/minorsurgery in office

If Non-PPO:Deductible, then

% coinsurance

Inpatient


If Non-PPO:Plan pays afterthe deductible

ER


If Non-PPO:Plan pays % afterthe deductible. Or,Plan pays % ifmember lives andreceives treatmentoutside 35 mile

radius of PPOfacility.

Prescription

After the $ deductible,the copays are as follows:Retail Prescriptions:Generic: $ Preferred Brand Name:$ Non-Preferred BrandName: $ Mail Order Prescriptions

(90-day supply):Generic: $ Preferred Brand Name:$ Non-Preferred BrandName: $

5. Indicate if the plan is fully-insured plan or a self-insured plan.SELF-INSURED

6. Indicate if the plan is Group or IndividualGROUP

7. Indicate if this plan has Grandfather Status.YES, THE PLAN IS GRANDFATHERED.

Please provide this information by 5:00 pm Monday November 22, 2010. We lookforward to receiving your completed application. Thank you.

Sincerely,

Kathleen M. Scelzo, RN, MSNRules Compliance DivisionOffice of Insurance OversightOffice of Consumer Information and Insurance Oversight (OCIIO)Department of Health and Human Services301-492-4121

NECA-IBEW L4:000015



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//T|/...20Response%20[YELLOW]/NECA-IBEW%20Local%20480%20Health%20&%20Welfare%20Plan/Approval%2012.14.10.htm[08/26/2011 4:03

rom: Botwinick, Alexandra (HHS/OCIIO)ent: Tuesday, December 14, 2010 12:08 PM

To: '[email protected]'ubject: Waiver of the Annual Limits Requirements of PHS Act Section 2711

mportance: High

ollow Up Flag: Follow up

lag Status: Red

Attachments: Updated Jan 1 Approval Letter .pdf

ood Afternoon,

hank you for submitting an application for a Waiver of the Annual Limits Requirements of the PHS Act

ection 2711 for NECA-IBEW Local 480 Health and Welfare Plan. HHS has reviewed your application an

made its determination. Please see the attached letter.

lease confirm receipt of this letter by replying to this e-mail.

lease let me know if I can be of further assistance.

incerely,

Alexandra Botwinick

ffice of Oversight

HHS/[email protected]

NECA-IBEW L4:000016

mailto:[email protected]:[email protected]


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NECA-IBEW L4:000017



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NECA-IBEW L4:000018



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Waiver of the Annual Limits Requirements of PHS Act Section 2711

//T|/...-IBEW%20Local%20480%20Health%20&%20Welfare%20Plan/Confirmation%20of%20Approval%20letter%2012-14-2010.htm[08/26/2011 4:03

rom: Michele La Motte [[email protected]]ent: Wednesday, December 15, 2010 8:46 PM

To: Botwinick, Alexandra (HHS/OCIIO)ubject: RE: Waiver of the Annual Limits Requirements of PHS Act Section 2711

ollow Up Flag: Follow uplag Status: Blue

have received your email and attachment on NECA-IBEW Local 480 Health and Welfare Fund. Thank you very much.

Michele LaMotte

-- -Original Message--- --

rom: Botwinick, Alexandra (HHS/OCIIO) [mailto:[email protected]]

ent: Tue 12/14/2010 12:08 PM

o: Michele La Motte

ubject: Waiver of the Annual Limits Requirements of PHS Act Section 2711

ood Afternoon,

hank you for submitting an application for a Waiver of the Annual Limits Requirements of the PHS Act Section 2711 for NECA-IBEW Loca

80 Health and Welfare Plan. HHS has reviewed your application and made its determination. Please see the attached letter.

lease confirm receipt of this letter by replying to this e-mail.

lease let me know if I can be of further assistance.

incerely,

lexandra Botwinick

ffice of Oversight

HS/OCIIO

[email protected]

NECA-IBEW L4:000019

mailto:[email protected]:[email protected]:[email protected]


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Waiver of the Annual Limits Requirements of PHS Act Section 2711


neca ibew local 4 - redacted bates hwm

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