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    Benefits Analysis

    PART I: Exposure Matrix

    PART II: Inventory of Benefits

    PART III: Benefits Plan Design Analysis

    DREW SCHLOSSER & DAKOTA PLOURDE

    912080225 & 912167259

    RMI 3501 Dr. Drennan

    Fall 2011

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    Part I - Benefits Matrix

    Exposure Analysis for KloterFarms

    Loss Exposure Provided Coverage/Benefits Provided

    Loss of Income: MedicalExpenses

    Overall Medical Expenses Yes Aetna: POS, Health Care FSA

    Dental No Coming 2012

    Vision No N/A

    Prescription Yes Aetna: POS (included drug plan), HealthCare FSA

    Long Term Care No N/A

    Retiree Health Care Yes COBRA, Medicare

    Loss of Income: Death

    Non-Accidental & Non-Occupational

    Yes OASDI, The Hartford: Basic Life

    Accidental Yes OASDI, The Hartford: Basic Life, AD&D

    Occupational Yes OASDI, The Hartford: Basic Life, AD&D

    Loss of Income:Unemployment

    Unemployment Yes Unemployment Insurance

    Loss of Income: Disability

    Non-Occupational: Short-Term Yes OASDI, Sick Time

    Non-Occupational: Long-Term Yes OASDI

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    Occupational: Short-Term Yes OASDI, Workers Compensation

    Occupational: Long-Term Yes OASDI, Workers Compensation

    Loss of Income: Retirement

    Retirement Yes 401(k), Profit Sharing, OASDI

    Other Exposures

    Educational Assistance Yes Tuition Reimbursement

    Work/Life Exposures Yes Employee Discount, Paid Holidays, PaidVacation

    Dependent Care Yes Dependent Day Care FSA

    Property-Liability No N/A

    Legal Expenses No N/A

    Part II: Inventory of Benefits

    Medical Expenses

    Point-of-Service Plan (POS)

    Kloter Farms offers a quality-point-of-service (QPOS) HMO plan to its full-time,

    active employees through Aetna Insurance Company. According to the employee

    handbook distributed by Kloter Farms, full-time employees are defined as those who

    work 2,000 or more hours in a calendar year. In order for these full-time employees to

    be considered active, eligible participants, each employee must incur a 30-day waiting

    period upon employment; additionally, employees will not receive coverage until the first

    day of the following month after the completion of the 30-day waiting period. For

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    POS plans, different deductibles are assessed based on in-network and out-of-network

    utilization. The plans are open-network plans, but assess a higher deductible for out of

    network use as a minor penalty. Listed below are the differentials in deductibles

    amongst each option:

    AETNA POS HMO Participating Providers Non-Participating Providers

    Basic QPOS HMO Individual: $4,500

    Family: $9,000

    Individual: $6,000

    Family: $12,000

    Advanced QPOS HMO

    Individual: $2,500

    Family: $5,000

    Individual: $5,000

    Family: $10,000

    Point-of-Service Plan without HSA

    Kloter Farms also offers a similar QPOS HMO without a HSA that has a lower

    deductible than previous options. The plan is insured and administered by Aetna which

    has an AM Best rating of A (excellent). All full-time salaried employees and their

    dependents are eligible. Dependents are defined as spouses, domestic partners, and

    children up to the age of 19 (25 if full-time student). It is available on a contributory

    basis where Kloter Farm pays 95% of the base medical plan and the employee pays the

    remainder. As previously stated, the deductible for this plan is significantly lower:

    $2,000 Individual, $4,000 Family (if a Participating Provider is used).

    Flexible Spending Account (FSA)

    Kloter Farms self-insures two types of FSAs: Health Care and Dependent Day

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    Care. All full-time employees are eligible to enroll in FSAs which go into effect January

    1st of the year following employment. Both FSAs are self-funded and administered

    using MyBenny. They are funded up front by Kloter and implemented through weekly,

    pre-tax payroll deductions. The maximum amount employees contribute to a FSA for

    2011 is $5,000. The Health Care FSA can be used for payment of deductibles, co-

    payments, prescriptions, etc. It cannot be used for over the counter medicine. The

    Dependent Day Care FSA can be used to pay for day care services for full-time

    employees dependent children.

    Prescription Drug Plan

    A prescription drug plan is included in all of the overall medical plans offered by

    Kloter Farms. As previously noted, all of these plans are provided by Aetna which

    receives an AM Best rating of A (excellent). All three options are closed panel plans

    regarding pharmacy and prescription drug coverage, meaning they offer no coverage

    for out-of-network services. In other words, there are no indemnity benefits for the

    employee, since the plan is not open panel. The point-of-service option without a HSA

    includes nodeductible for in-network utilization; however, there is a 3-tier fixed co-

    payment system based on quality level of coverage. By pricing each co-payment

    required by the participating employee at different levels (for different levels of

    coverage), steerage is implemented by the insurer. In the case of the three plans

    offered by Aetna, steerage is invoked in each plans co-pay. This co-payment system

    also encourages the Hesitation Effect, which is great for the insurer when dealing with

    cost containment. The Hesitation Effect involves prescriptions not being filled due to

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    tiers of cost options; for example, some employees covered under this plan may opt for

    a cheaper, generic brand of the same prescription, or even a smaller quantity. Since all

    three plan options do not offer coverage for out-of-network service, the co-payment

    system is only used for participating pharmacies in-network:

    1. POS without HSA

    Benefit Type Participating Non-

    Participating

    Generic Formulary $10 co-pay Not Covered

    Brand Name Formulary $25 co-pay Not Covered

    Generic and Brand Name Non-

    Formulary

    $40 co-pay Not Covered

    Lifestyle Prescription Drugs 20% of Total Cost co-

    pay

    Not Covered

    For both the basic and advanced POS HMO (with a HSA) prescription drug

    coverages, the same co-pays are assessed regarding price; however, the key

    difference from the POS without an HSA is the existence of a deductible. In addition to

    the co-pay, the overall aggregate deductible (listed in the deductible chart above) must

    be exhausted before coverage begins.

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    Loss of Income: Death

    Life Insurance

    Kloter Farms Inc. offers its employees a life insurance policy through The

    Hartford Life and Accident Insurance Company. The schedule of insurance for Kloter

    Farms employees includes two parts: (1) basic life insurance coverage, and (2) basic

    AD&D benefits. The purpose of the schedule specified in the plan controls three

    aspects:

    1. Benefit amounts and maximum limits

    2. Eligibility and effective date requirements

    3. Additional schedule amounts and limits

    These schedule specifications apply to all employees covered by the policy, and

    are presented to each individual covered. Eligible participants (employees as well as

    their dependents) are expected to pay a monthly premium on the first of each month; if

    an employee fails to pay the premium, a 31-day grace period is implemented by The

    Hartford Insurance Company, as specified. If an employee fails to pay the premium on

    the thirty second day past due, the policy automatically terminates and coverage is

    suspended. Premium rates are set for all eligible employees at an equal rate in order to

    pass discrimination testing required by insurance regulation. The premium for Kloter

    Farms basic life insurance policy is $0.20 per month per $1,000 dollars of coverage for

    each individual. For the basic AD&D benefits coverage, a $0.02 charge per employee

    per month is assessed per $1,000 of coverage. Additionally, every Kloter Farms

    employee that has health insurance through the company receives an automatic

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    $10,000 in life insurance coverage, non-optional. This coverage costs two dollars a

    month per employee, which is paid for by Kloter Farms; therefore, it is essentially free to

    each employee and contains a minimal cost for Kloter Farms.

    Retirement

    Kloter Farms contribution to employees 401(k) plans is based on profit

    sharing. It becomes available to employees on January 1st or July 1st of their second

    year of full-time employment. The employee must then maintain 1,000 hours of service

    yearly to sustain eligibility. All employee contributions to their personal 401(k) are 100%

    vested. Kloters contributions are vested after six years of service to the company and

    vary from year to year. The past three years it has contributed 10% of the employees

    pay. The previous fourteen years Kloter had contributed the maximum 15%. The

    amount an employee can contribute is based on the amount Kloter contributes via profit

    sharing and the maximum set by the IRS. In 2011, the limit is $16,500 and in 2012 it

    will be raised to $17,000 (irs.gov).

    Other Exposures

    Tuition Reimbursement

    Tuition and professional training reimbursement is offered by Kloter Farms on a

    case-by-case basis. The company is willing to fully reimburse any educational

    expenses of an employee as long as it pertains directly to the employee s position with

    the company and is applicable. Kloter self-insures this benefit and the qualifications are

    determined by the owners as they see fit.

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    Employee Discount

    Employee discounts on Kloter Farms products are based on the number of years

    the employee has been with the company. The discounts are as follows:

    0-1 years of service 25%

    2-5 years of service 30%

    6-10 years of service 35%

    11+ years of service 40%

    This discount is extended to the employees spouse and other immediate family

    members of employees receive a discount of 25%. The discount cannot apply to gift

    certificates and there is a maximum discount of 25% on all sheds and gazebos.

    Paid Holidays

    All full-time and half-time employees (1,000-1,999 hours per year) receive seven

    paid holidays per year. Holiday pay is defined as eight hours for full-time employees

    and six hours for half-time employees and is a self-funded benefit provided by Kloter. If

    the holiday occurs on a non-working day salaried employees receive a floating paid

    day off. Salaried employees will also receive an additional paid day off if they work on a

    paid holiday (e.g. Labor Day). Hourly-employees that work on a paid holiday are

    compensated for their time and also receive holiday pay. The holidays are: New Years

    Day, Memorial Day, Christmas Day, Thanksgiving Day, Fourth of July, Labor Day, and

    the June Company Picnic (if attending).

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    Sick Time

    Kloter Farms provides five sick days per year to all full-time and half-time

    employees. Sick days can be utilized for an employees personal injury/illness or to

    tend to illness/injury of a family member. The sick pay is self-funded by Kloter and is

    accrued by calendar year. Sick time that is not used during the calendar year can be

    carried forwarded to the next year, up to a maximum of 20 sick days. It should be noted

    that Kloter Farms reserves the right to require medical documentation when an

    employee uses sick time.

    Vacation Time

    Paid vacation time is granted to all full-time and part-time employees and is self-

    funded by Kloter Farms. All vacation time is accrued by calendar year and any unused

    time is forfeited on the January 1st when the balance is renewed. Vacation time must

    be taken in increments of four hours and any employee with more than one year of

    service with the company will be paid for any unused vacation time when their

    employment ends. A new, full-time employee who is employed with Kloter after January

    1st receives vacation time on a pro-rated schedule indicated below:

    Schedule for first partial calendar year:

    Length of Service Number of hours

    90 days 8 hours

    150 days 16 hours

    210 days 24 hours

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    270 days 32 hours

    330 days 40 hours

    The following years are scheduled as such:

    Length of Service Number of hours

    First full calendar year 40 hours

    3 to 5 years 80 hours

    6 to 10 years 120 hours

    11+ years 160 hours

    Half-time employees do not receive vacation time until their second year of

    employment. Vacation time is then calculated by dividing the total number of hours

    worked in the previous calendar year by 50. After five years of service, vacation

    benefits are doubled.

    Part III - Decision Making and Benefits Plan Design Analysis

    Introduction

    Kloter Farms is located in Ellington, Connecticut and has been in business since

    1980. It sells and maintains sheds, gazebos, and home furnishing that are handmade by

    the Amish of Pennsylvania. There are currently twenty-seven employees enrolled in

    Kloters benefits plan with forty-nine dependents, totaling seventy-six covered lives.

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    Our primary contact and interviewee was Peter Welti, who has been president of

    Kloter Farms for one year. Mr. Welti works directly with the companys benefits consultant,

    John Zawadski of Health Consultants Group, and is in charge of making a majority of the

    benefits decisions. In order to better understand the design and goals of Kloter Farms

    employee benefits package, we opened our interview with Mr. Welti by asking him why

    Kloter Farms provides an employee benefits package. His response was as we expected

    to attract and retain valuable and capable employees.

    Overall Design Considerations of Employee Benefits

    Goals

    When implementing a benefits plan, the decision maker must establish criteria in

    order to offer an effective package that satisfies the employee and appeals to the

    employer. Peter Welti cites three key goals when determining benefit implementations or

    alterations:

    1. Overall cost to Kloter Farms

    2. Overall cost to employees

    3. Overall benefits provided

    The overall cost to Kloter Farms is an important factor in regards to benefit planning

    because overspending can lead to issues surrounding financial business capacity and

    overall firm solvency. Recent modifications to the health care plan has allowed Kloter

    Farms to continue financing a majority of the base plan it offers its employees; otherwise,

    Kloter Farms would not have been able to bear the rising costs of its former plan. When

    considering costs to employees, factors such as co-payments, cost sharing, deductibles,

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    and employee contributions must all be taken in to account. At the same time, the quality

    and reliability of the benefits plan must be addressed. A balance encompassing these three

    conditions will result in an affective and sustainable benefits plan.

    Demographics

    Being an extremely family oriented company, Kloter Farm considers dependent

    coverage a top priority. Previously, the company considered the implementation of a dental

    plan for covered employees and dependents; however, due to the high cost considerations

    and limited number of children covered as dependents, Kloter Farms rejected adding this

    coverage.

    In our initial analysis of Kloter Farms benefits package, we observed that a majority

    of the plans benefits pertained only to full-time employees. Prior to our interview with Mr.

    Welti, we assumed that this was intentionally done to discourage part-time employment;

    contrarily, Mr. Welti informed us that this was done to reduce the total number of employees

    covered under the benefits plan. Additionally, part-time employees at Kloter Farms receive

    a higher hourly rate to compensate the lack of available benefits.

    Funding and Financing Decisions

    Kloter Farms is selective in choosing which areas of benefits to self-fund, and which

    areas to finance through a third party. It chooses to fully insure any risk that can lead to a

    catastrophic loss for employees, such as health care, life insurance, and accidental death

    and dismemberment (AD&D) coverage. All of these areas represent risk that Kloter Farms

    could not possibly self-insure because of the potential they have to incur astronomical

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    losses. For a company of its size, these losses could undoubtedly threaten Kloters

    solvency.

    On the other hand, like most companies, Kloter Farms self-insures a majority of its

    benefits that are low risk or have set nominal costs. The company elects to self-insure: sick

    time, vacation, holidays, tuition reimbursement, and 401(k) contributions. All of these

    benefits are either low risk or set amounts which Kloter Farms can easily plan for in

    advance. In the case of 401(k) contributions, which are offered on a profit sharing basis,

    the amount Kloter contributes is adjustable yearly. In this regard, 401(k) contributions can

    never directly threaten the companys financial standing.

    Issues and Considerations in the Design of Health Benefits

    History

    For the majority of Kloter Farms existence, the firm provided its employees with

    plans that offered first dollar coverage. These cash benefits required no deductible and had

    a minor co-pay of ten dollars for doctor visits and fifteen dollars for prescription

    drugs. According to Peter Welti, most employees were satisfied with these health benefits

    provided by the company; however, by 2006, premiums for these plans were increasing

    extremely rapidly. Kloter Farms opted instead to offer its employees and their dependents

    a choice of POS HMO plans through Aetna. This decision was based on the

    recommendation of Kloters benefits consultant at the time. These POS HMO plans are

    consumer directed health plans (CDHP) that have high deductibles and are compatible with

    a health savings account (HSA). The two specific reasons Kloter Farms president and

    insurance broker chose to offer these health options are: (1) Kloter Farms former heath

    care plan became too costly and (2) the POS HMO options will remain steadily containable

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    and cost efficient for both employees and Kloter Farms over time (Welti). Mr. Welti

    explained that, without switching to a CDHP, Kloter Farms would not be able to continue

    contributing 95% of the cost for the employees base health plan. If they had not changed

    coverage, the previous plan would now cost double what it did in 2006 (Welti).

    Cost Containment

    Marginal cost versus marginal benefits is a very important factor when selecting a

    cost-efficient health care plan. Mr. Welti stresses the significance of overall cost to Kloter

    Farms employees and their dependents as well as the marginal cost to the firm. Three

    methods Kloter Farms plan practices in order to reduce costs are offering employees a high

    deductible plan option, using coinsurance, and requiring employees to make co-payments

    for service benefits. These methods force employees to act as responsible consumers

    when utilizing health care because they are forced to weigh the benefits they receive

    against the true cost (NBGH). The base POS HMO option with a HSA includes a high

    deductible of $4,500-$6,000 for individual plans and $9,000-$12,000 for family plans

    depending on in network or out of network utilization. This large deductible offers

    employees a lower annual premium, but does not offer coverage until the deductible is

    met. A second cost saving method exercised by Kloter Farms is coinsurance for out of

    network care by employees; in network treatment requires no coinsurance paid by the

    employee, but out of network utilization comes with a 30% co-insurance stipulation. The

    new CDHP also attempts to contain cost by requiring higher co-payments than the previous

    plan. The co-payments can range from $10-$150 depending on services required and

    network utilization. Co-payments, high deductibles, and coinsurance all help subsidize

    Kloter Farms overall costs for health benefits.

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    One would expect these changes would create some animosity from employees

    towards the company but Mr. Welti assured us that this was not the case. He went on to

    clarify that the bulk of Kloters covered employees simply choose the plan that costs them

    the least. The fact that the company was able to continue providing a contribution of 95%

    was enough to keep the majority of covered employees content. He also noted that he

    does not believe a majority of employees truly understand their health plan until it becomes

    needed. This indicates that communication of all benefits could use serious improvement.

    Dental

    In the upcoming year, Kloter Farms plans to add dental to its health benefits

    plan. We previously indicated that the company had rejected the idea in the past but due to

    increased demand by employees, Kloter has decided to begin offering the

    coverage. Although the company will not be able to make any contributions to this

    coverage, dental will be available on an employee-pay-all basis beginning in 2012.

    Issues and Considerations in the Design of Non-Health Benefits

    Communication

    As previously expressed, Kloter Farms communication could use improvement. Mr.

    Welti noted that a majority of the companys employees do not fully understand their

    benefits plan until they personally need it. Kloters communication is outsourced through

    the companys benefits consultant, John Zawadski. Mr. Zawadski works for the firm, Health

    Consultants Group, and handles the majority of Kloter Farms benefits communication and

    assists in the design. Kloter Farms does not have a Summary Plan Description (SPD) or

    similar communication devise. Instead, Mr. Zawadski meets with the employees annually

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    during the companys enrollment period. He convenes one-on-one with each employee and

    discusses their options thoroughly to find the best set of benefits particular to their individual

    needs. He also addresses any questions or concerns they may have.

    Although Kloter Farms has had very few issues or complaints regarding the

    companys benefits package, Mr. Zawadski is available year round to handle any problems

    that may arise. The few complications Kloter Farms employees have had were in regard to

    co-payments. The issue was absolved by Mr. Zawadski who contacted the insurance

    company and clarified the misunderstanding between the two parties.

    Short-Term and Long-Term Disability

    In addition to the dental plan previously mentioned, Kloter Farms is also installing

    short-term and long-term disability coverage in its benefits offering for the coming

    year. These disability options will be accessible on an employee-pay-all basis via weekly

    payroll deductions. Kloter is providing five or six different plans for its employees to choose

    from, depending on their unique needs and desires.

    The decision to begin offering disability and dental was a result of an employee

    survey conducted by Kloter Farms. The survey asked employees which areas of their

    benefits plan they would like improved and if there were any desired coverages not being

    provided. They found that dental and disability coverage were the two areas most

    requested. Although Kloter does not currently have the ability to contribute to these

    coverages, it is able to make both available to all of its employees.

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    Regulatory Compliance

    ERISA

    Fiduciary responsibility, discrimination testing, and plan communication are all

    requirements Kloter Farms must address under ERISA (Cogan). Discrimination is easily

    handled by only contributing a set amount95% of the base health plans cost. If an

    employee wished to have a richer health plan, they are required to cover the additional cost

    on their own. This design means that Kloter Farms does not discriminate by offering the

    same amount of contribution to all employees for any plan. It also offers a set amount of life

    insurance ($10,000) to all covered employees.

    By offering an HMO POS plan, Kloter Farms takes care of its fiduciary

    responsibility. Although it has switched to a CDHP, employees still have the freedom to

    choose any provider they wish by deciding to stay in network or go out of network.

    The communication of the plan is handled by holding an annual meeting with Koters

    employees as well as one-on-one meetings with the companys consultant.

    PPACA

    Under PPACA, Kloter Farms misses eligibility for the small business health

    insurance tax credit by only two covered lives. In order to qualify for the tax credit, the

    employer must have fewer than twenty-five covered employees, pay at least 50% of

    employees health insurance cost, and have an average salary of less than $50,000

    (Peterson). Kloter Farms fulfills all of these except for having twenty-seven covered

    employees. The tax credit would be equal to 35% of the employers contribution to health

    insurance (Peterson).

    Kloter Farms FSAs will be affected by PPACA in the coming years. Starting in

    2013, the maximum amount an employee can deposit in an FSA will be reduced to

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    $2,500. Currently, the maximum is set at $5,000.

    Future Recommendations

    Kloter Farms offers its employees and their dependents a broad, comprehensive

    spectrum of coverage and benefits. Although they offer a variety of benefits ranging from

    necessary coverage options (health care) to life cycle benefits such as HSA options and

    paid time off, there are a few gaps that Kloter Farms can address to further improve the

    system that is already in place. The two areas of improvement encompass plan

    communication and staff adjustments.

    Communication Improvements

    One advantage to administering a benefit plan to a smaller firm is the ease of

    administrative burden. For example, communicating a plan to a company with twenty

    employees will be significantly less difficult for administration than a company that has over

    a thousand employees. Kloter Farms does a great job communicating plan enrollment

    periods, changes to the benefits package, and options employees and their dependents

    have; they even hold a mandatory annual meeting to make sure every employee knows

    exactly what options they have in order to eliminate any discrepancies. Since Kloter has

    just twenty-seven employees (and forty-nine dependents), it is not detrimental to the

    companys output to hold this annual meeting during work, and saves the administration

    time. Additionally, Kloter Farms personal consultant, John Zawadski (Penn Field

    Consultants), sits down with each individual employee, one-on-one, who opts for

    coverage. This is very effective, but to even further improve efficiency and overall plan

    effectiveness, Kloter Farms should consider drafting a written summary plan description

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    (SPD), so employees can receive a copy of the plan offerings in writing. This SPD should

    be distributed at work to each employee, as well as made available online for employees to

    view at any time. This way, employees can always access information regarding enrollment

    period dates and see exactly what Kloter Farms offers in terms of coverage and

    benefits. Along with offering a SPD, it is important for the companys broker and plan

    administrators to notify all employees of any changes to the SPD, whether employees are

    covered or not. By giving each employee a copy of the SPD in addition to the annual

    communications meeting, plan participation may increase, and at the very least employees

    will be better informed of what Kloter Farms offers its employees in terms of coverage and

    benefits.

    Administration Suggestions

    In addition to distributing a Summary Plan Description to employees, Kloter Farms

    can further benefit its organization and benefits administration by hiring a risk

    manager. When we spoke with Peter Welti initially, he told us he would contact the

    companys broker for additional information we were seeking. After three days, the broker

    had still not responded with the requested information; furthermore, Mr. Welti was initially

    uncertain of how his own benefits worked until he actually needed them, even though he

    makes the majority of the decisions regarding what benefits Kloter Farms offers

    employees. Adding a risk manager to partner with Peter Welti would improve plan

    organization, and bolster the team of individuals that decides what benefits to offer. This

    risk manager could also assess risk within the organization, and suggest ways to prevent

    future perils and shortcomings within the plan design. If the company is not open to hiring a

    new employee at the executive position, they could alternatively choose to pass the

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    administration aspects of the plan off to a third party administrator, or an insurer who

    performs administrative services only. Implementing either of these two options would

    improve plan communication and ease the burden of performing duties that comply with

    ERISA (fiduciary responsibilities, communication requirements, reporting requirements such

    as Form 5500, etc.).

    Conclusion

    In Kloter Farms thirty one years of existence, its benefit options have changed

    drastically. After using first dollar coverage with no deductible for the majority of its time as

    an entity, Kloter Farms changed its health benefit options to CDHP products five years ago

    due to exponential cost increases. Decision makers who administer these benefits to

    employees and their dependents continue to improve coverage gaps, and plan to add

    dental coverage in the next calendar year. In addition to health and life insurance benefits,

    the firm offers extensive benefits such as- AD&D, short and long term disability, paid time

    off for holidays, sick days, tuition reimbursement, and 401(k) profit sharing. Offering

    employees these benefits will retain valuable, capable personnel within the firm and keep

    them happy. Improving these coverage options and offering competitive benefits will also

    attract top talent to Kloter Farms, further improving the quality of the staff, which in turn

    improves the company name. Constant revision and analysis of the current plan will

    continue to strengthen the total package offered by Kloter Farms, and improve overall

    employee satisfaction. Kloter Farms begins with the individuals who work within the

    organization. Attracting and retaining valuable, capable employees will yield future success

    for years to come.

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    "Consumer-Directed Health Care: The Employer Perspective." National Business Group on Health (2011):

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    Peterson, Chris L., and Hinda Chaikind. "Summary of Small Business Health Insurance Tax Credit Under

    PPACA (P.L. 111-148)." Congressional Research Service. 4 Apr. 2010. Web. 9 Dec. 2011.

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    Welti, Peter. Personal interview. 6 December, 2011.