wage works - combined redacted-bates hwm

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//T|/...0with%20NO%2012600%20Response%20[YELLOW]/WageWorks/WAIVER%20%20WageWorks%20Inc.%2001919501.htm[07/07/2011 12:08:

rom: Nielsen, Mark ([email protected]) [[email protected]]ent: Tuesday, November 09, 2010 3:29 PM

To: HHS HealthInsurance (HHS)Cc: Hughes, Cheryl Risley ([email protected]); Kelley, Heather ([email protected])ubject: WAIVER: WageWorks, Inc. [019195/01]

Attachments: Annual Limits Waiver Request and Actuarial Certification--Final.pdf

ear Mr. Mayhew,

n behalf of WageWorks, Inc., and its wholly-owned subsidiaries (collectively, "WageWorks"), I am submitting this application foaiver of the restricted annual limit under Public Health Services Act 2711, pursuant to OCIIO Sub-Regulatory Guidance OCI010-1. WageWorks administers defined contributio re ement arrangements ("HRAs") on behalf of its clients, anduch HRAs typically have annual limits ranging from to WageWorks submits this waiver application on behalf oient plans, given that - - as detailed in the attached actuarial projection -- imposition of a $750,000 annual limit would result ingnificant decrease in access to benefits for those covered under the HRAs and a significant increase in employer costsssociated with such coverage.

We appreciate your consideration of WageWork's request. Please let Cheryl Risley Hughes or me know if you have any questr need anything else. Cheryl can be reached at 202.861.0167, and I can be reached at at 202.861.5429.

est regards,

Mark C. Nielsen

Mark C. Nielsen / 1701 PennsylvaniaAve., N.W. /Washington, DC 20006 /Phone: 202-861-5429 /Fax: 202-659-4503

www.Groom.com/ [email protected]

otice: This message is intended only for use by the person or entity to which it is addressed. Because it may contain confidenformation intended solely for the addressee, you are notified that any disclosing, copying, downloading, distributing, or retainin

his message, and any attached files, is prohibited and may be a violation of state or federal law. If you received this message rror, please notify the sender by reply mail, and delete the message and all attached files.

o comply with U.S. Treasury Regulations, we also inform you that, unless expressly stated otherwise, any tax advice containehis communication is not intended to be used and cannot be used by any taxpayer to avoid penalties under the Internal Revenode, and such advice cannot be quoted or referenced to promote or market to another party any transaction or matter addres this communication.

WageWorks:000007
http://www.groom.com/http://www.groom.com/mailto:[email protected]:[email protected]://www.groom.com/


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//T|/...NO%2012600%20Response%20[YELLOW]/WageWorks/Request%20for%20additional%20info%20response%2011.24.10.htm[07/07/2011 12:08

rom: Hughes, Cheryl Risley ([email protected]) [[email protected]]ent: Tuesday, November 23, 2010 5:10 PM

To: Habit, Sandra (HHS/OCIIO)Cc: Jody Dietel; Nielsen, Mark ([email protected])ubject: FW: HRA COBRA Premiums for sample clients

Ms. Habit,

er our telephone conversation yesterday, please find an e-mail from WageWorks below that provides sample COBRA monthly

remiums from two HRAs that are administered by WageWorks.

lease let us know if you have any additional questions regarding this matter.

hank you.

heryl Risley Hughes

Cheryl Risley Hughes / 1701 PennsylvaniaAve., N.W. /Washington, DC 20006 /Phone: 202-861-0167 /Fax: 202-659-450

www.Groom.com / [email protected]

rom: Jody Dietel [mailto:[email protected]]ent: Tuesday, November 23, 2010 5:01 PMo: Hughes, Cheryl Risley ([email protected]); Jody Dietelubject: HRA COBRA Premiums for sample clients

We do not administer COBRA for the majority of clients but have provided COBRA premiums for two sample clie

or the first sample client, the maximum is $ and the COBRA premiums are as follows.

HRA HRA Employee

HRA HRA Employee + Family

HRA HRA

Employee + Spouse

or Child(ren)

or the second sample client, the maximum is $ and the COBRA premiums are as follows.HRA HRA Employee HRA HRA Employee + Family HRA HRA

Employee + Spouse

or Child(ren)

et me know if you need anything else.

ody L. Dietel, CFCIhief Compliance Officerirect: 760.509.0118 | Remote: 760.509.4656| Mobile: 760.505.6875| Fax: 866.672.2688mail:[email protected]

his is a confidential correspondence intended only for the recipient. Further distribution or dissemination is prohibited. Please delete if received in error. No part e construed as tax or legal advice. Unless indicated otherwise, this email does not constitute a "writing" under E-SIGN/UETA, i.e., no contract or agreement is im

intended.

WageWorks:000008
http://www.groom.com/mailto:[email protected]:[email protected]:[email protected]://www.wageworks.com/mailto:[email protected]://www.groom.com/


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//T|/...NO%2012600%20Response%20[YELLOW]/WageWorks/Request%20for%20additional%20info%20response%2011.24.10.htm[07/07/2011 12:08

otice: This message is intended only for use by the person or entity to which it is addressed. Because it may contain confiden

formation intended solely for the addressee, you are notified that any disclosing, copying, downloading, distributing, or retainin

his message, and any attached files, is prohibited and may be a violation of state or federal law. If you received this message

rror, please notify the sender by reply mail, and delete the message and all attached files.

o comply with U.S. Treasury Regulations, we also inform you that, unless expressly stated otherwise, any tax advice containe

his communication is not intended to be used and cannot be used by any taxpayer to avoid penalties under the Internal Reven

ode, and such advice cannot be quoted or referenced to promote or market to another party any transaction or matter addres

this communication.

WageWorks:000009


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//T|/...lications%20with%20NO%2012600%20Response%20[YELLOW]/WageWorks/Approval%20letter%20sent%2012-6-2010.htm[07/07/2011 12:08

rom: Botwinick, Alexandra (HHS/OCIIO)ent: Monday, December 06, 2010 8:57 AM

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

mportance: High

Attachments: Updated Jan 1 Approval Letter .pdf

ood Morning,

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

ection 2711 for Wage Works, Inc. HHS has reviewed your application and made its determination. Please

he attached letter.

lease confirm receipt of this letter by replying to this e-mail address with a copy to [email protected]

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

incerely,

Alexandra Botwinick

ffice of Oversight

HHS/[email protected]

WageWorks:000010
mailto:[email protected]:[email protected]


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//T|/...ith%20NO%2012600%20Response%20[YELLOW]/WageWorks/confirmation%20of%20approval%20letter%2012-6-2010.htm[07/07/2011 12:08

rom: Nielsen, Mark ([email protected]) [[email protected]]ent: Monday, December 06, 2010 9:18 AM

To: Botwinick, Alexandra (HHS/OCIIO)Cc: Jody Dietel; OCIIO Oversight; Hughes, Cheryl Risley ([email protected])

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

ollow Up Flag: Follow uplag Status: Red

ear Ms. Botwinick,

hank you for your email, confirming HHS's approval of Wage Work, Inc.'s annual limit waiver request. We very much apprecia

he Department's decision, and the courtesies that have been extended to us throughout this process.

est regards,

Mark C. Nielsen

Mark C. Nielsen / 1701 PennsylvaniaAve., N.W. /Washington, DC 20006 /Phone: 202-861-5429 /Fax: 202-659-4503

www.Groom.com/ [email protected]

rom: Botwinick, Alexandra (HHS/OCIIO) [mailto:[email protected]]ent: Monday, December 06, 2010 8:57 AMo: Nielsen, Mark ([email protected])ubject: Waiver of the Annual Limits Requirements of PHS Act Section 2711mportance: High

ood Morning,

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

ection 2711 for Wage Works, Inc. HHS has reviewed your application and made its determination. Please

he attached letter.

lease confirm receipt of this letter by replying to this e-mail address with a copy to [email protected]

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

incerely,

Alexandra Botwinick

ffice of Oversight

HHS/[email protected]

WageWorks:000011
http://www.groom.com/http://www.groom.com/mailto:[email protected]:[email protected]:[email protected]:[email protected]://www.groom.com/


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//T|/...ith%20NO%2012600%20Response%20[YELLOW]/WageWorks/confirmation%20of%20approval%20letter%2012-6-2010.htm[07/07/2011 12:08

otice: This message is intended only for use by the person or entity to which it is addressed. Because it may contain confiden

formation intended solely for the addressee, you are notified that any disclosing, copying, downloading, distributing, or retainin

his message, and any attached files, is prohibited and may be a violation of state or federal law. If you received this message

rror, please notify the sender by reply mail, and delete the message and all attached files.

o comply with U.S. Treasury Regulations, we also inform you that, unless expressly stated otherwise, any tax advice containe

his communication is not intended to be used and cannot be used by any taxpayer to avoid penalties under the Internal Reven

ode, and such advice cannot be quoted or referenced to promote or market to another party any transaction or matter addres

this communication.

WageWorks:000012


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///co-adshare/...12600%20Response%20[YELLOW]/WageWorks/Request%20for%20additional%20info%20response%2011.19.10.txt[07/07/2011 12:09

rom: Hughes, Cheryl Risley ([email protected]) [[email protected]]ent: Friday, November 19, 2010 11:17 AMo: Habit, Sandra (HHS/OCIIO)

Cc: Jody Dietel; Nielsen, Mark ([email protected])ubject: Waiver Application - WageWorks

Attachments: [email protected]

Ms. Habit,

We are writing to respond to your e-mail of November 18, 2010 regarding the Waiver Application for WageWorks

. We cannot provide premium information at this time because, as discussed below, employers do not pay premiuor these plans.

n the application, WageWorks requests a waiver of the annual limits requirements of PHS Act Section 2711 for heeimbursement arrangements ("HRAs") that are administered by WageWorks. An HRA is an employer-fundedrrangement that reimburses employees for certain medical expenses incurred by the employee or their family.ssentially, it is a defined contribution medical plan, funded with a set amount each year by the employer; a partici

may be reimbursed for certain medical expenses up to the account balance. An HRA is not a typical employer

rovided health plan -- it is not insured and is always funded entirely by the employer. In other words, there are nomployer premiums associated with an HRA nor are there employee premiums (other than COBRA premiums inertain cases).

he typical employer contributions for the HRAs administered by WageWorks range generally betwee andper year. If these plans are required to maintain a plan with a $750,000 per year limit (up to ae), none of these employers will be able to continue to offer these Plans.

he most conservative estimate from our actuaries indicates that removing the limits will cause these plans to eitherecome insolvent and be eliminated, (2) reduce or eli nat overage of other benefits, such as dental and vision, o3) increase employer costs by an estimated range of to %, with the potential risk of a much higher increase in

he event of a large claim.

lease see our waiver application for a more detailed letter from WageWorks' actuary ment is significantncrease in cost to employers if those annual limits were increased to $750,000 from $ to $ .. The HRAs sponsored by WageWorks do not have any separate annual limits on essential benefits. Any limit pln an HRA will apply to all benefits covered under the HRA.

lease let us know if we can provide you with additional assistance or answer any additional questions you may havegarding this matter.

hank you.

Cheryl Risley Hughes

cid:[email protected]]

Cheryl Risley Hughes / 1701 Pennsylvania Ave., N.W. / Washington, DC 20006 / Phone: 202-861-0167 / Fax: 20259-4503 / www.Groom.com / [email protected]

_______________________________

WageWorks:000013


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rom: Habit, Sandra (HHS/OCIIO) o: Nielsen, Mark ([email protected])ent: Thu Nov 18 15:07:28 2010ubject: Waiver Application - WageWorks

Mr. Nielsen,

hank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section 2711. Irder to complete your application, please provide the following information:

I understand that there are 416 plans so a range of this data would be most helpful*

lease provide the current monthly premium rates and the projected monthly premium rates applicable to the plan oolicy forms if the plan were to comply with the restricted annual benefits. In other words, we would like a chart teflects the following information:

010 January Premium (current level)

011 January Premium (renewal)

011 January Premium (if $750,000 annual limit was applied)

E

E + Child (if applicable or other appropriate tier)

E + Spouse (if applicable or other appropriate tier)

amily (if applicable or other appropriate tier)

WageWorks:000014


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ndicate if there are essential benefit limits and the amount for the following categories:

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

Laboratory: $Pediatric: $

Maternity: $Mental Health/Substance Abuse: $Rehabilitative: $Preventive: $Prescription (RX): $

n order to complete your application, please provide this information by 5:00 pm, November 19, 2010. We look

orward to receiving your completed application. Thank you.

andy

andra HabitQuality AnalystOffice of Consumer Information and Insurance Oversight

[email protected]

NFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW: This information hot been publicly disclosed and may be privileged and confidential. It is for internal government use only and musot be disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorizedisclosures may result in prosecution to the full extent of the law.

_______________________________

Notice: This message is intended only for use by the person or entity to which it is addressed. Because it may contonfidential information intended solely for the addressee, you are notified that any disclosing, copying, downloadiistributing, or retaining of this message, and any attached files, is prohibited and may be a violation of state or fedaw. If you received this message in error, please notify the sender by reply mail, and delete the message and allttached files.

o comply with U.S. Treasury Regulations, we also inform you that, unless expressly stated otherwise, any tax adviontained in this communication is not intended to be used and cannot be used by any taxpayer to avoid penalties

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nder the Internal Revenue Code, and such advice cannot be quoted or referenced to promote or market to anotherarty any transaction or matter addressed in this communication.

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wage works - combined redacted-bates hwm

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