IAM District 15 - Redacted HWM

7/27/2019 IAM District 15 - Redacted HWM

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///co-adshare/...20Force/CCIIO%20Waivers%20-%20Torres/DFOI%20Processing%20Team/Mike/IAM%20District%2015/Waiver.htm[10/27/2011 3:12

rom: Marylou Gartland [[email protected]]ent: Tuesday, November 30, 2010 3:26 PM

To: HHS HealthInsurance (HHS)ubject: Waiver

Attachments: D15 Waiver App 2011.pdfhank you.

Marylou GartlandFund Manager

ENEFIT SERVICES185 LEMOINE AVEORT LEE, NJ 0702401-947-8000

[email protected]

IAM D15:000001
mailto:[email protected]:[email protected]


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November 30, 2010

James Mayhew

HHS Office of Consumer Information and Insurance Oversight, Office of OversightRoom 737-F-04200 Independence Ave. SWWashington, DC 20201

Dear Mr. Mayhew:

Please accept this application from the IAMAW District 15 Health Fund plan for a waiver fromthe restricted annual limits set forth in the Interim Final Regulations for the plan year January1, 2011 December 31, 2011. The plan was offered prior to September 23, 2010. This letterand its attachments include the following information as required by OCIIO Sub-RegulatoryGuidance 2010-1: Process for Obtaining Waivers of the Annual Limits Requirements of PHS

Act Section 2711.

The plan provides group health benefits to active participants and their dependents. Thebenefits are self-insured. The Fund is administered by a joint board of employer and uniontrustees and a plan administrator. Participants are offered hospital, medical, prescription drug,dental, optical, and life benefits. In order for a participant to be eligible to have contributionsmade to the Fund on his/her behalf, the participant must work under a collective bargainingagreement, which establishes the contribution amount for the work performed.

Eligible active participants are offered prescription drug coverage with an annual maximum of$ for participants in Tier 1, $ for participants in Tier 2, $ for participants inTier 3, and $ for participants in the Local 447 option. Contributing employers makecontributions to the plan for their employees, and the level of coverage in which participantswill be enrolled is determined by the collective bargaining agreement.

The plan is requesting a waiver of the annual dollar limits applicable to the various prescription

drug plans.

Attestation

I hereby attest to the following: I am the plan administrator of the IAMAW District 15 HealthFund plan. I certify that (1) the plan was in force prior to September 23, 2010 and (2) the

application of restricted annual limits to the plan would result in a significant decrease inaccess to benefits for those currently covered by the plan and a significant increase in

premiums paid by the plans participants and covered dependents.

____________________________________

Lucille HartFund Administrator

IAM D15:000002


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Annual Dollar Limit Waiver Certification

Name of Plan: IAMAW District 15 Health Fund

Plan Year: January 1, 2011December 31, 2011

The Segal Company has reviewed the Plans request for a Waiver of the Restricted AnnualDollar Limits in the Affordable Care Act, and has the following findings.

1. The terms of the plan for which a waiver is sought.

Tiers 1, 2 and 3, and Local 447 have a % copayment at both retail and mail witha minimum copay of the lesser of $ or the cost of the drug and a maximum copayof $ The annual benefit maximums for Tiers 1, 2, 3, and Local 447 are $ , $ $ , and $ respectively.We have attached a benefit summary for your reference (all prescription drug plansare the same except for the annual maximums).

2. The number of individuals covered by the plan submitted.

active eligible employees and approximately dependents ( membersand approximately dependents are not covered by the prescription drug plans).

3. The annual limit(s) and rates applicable to the plan submitted.

The plan currently has the following per person annual maximums on prescriptiondrugs: $ for participants in Tier 1, $ for participants in Tier 2, $ forparticipants in Tier 3, and $ for participants in the Local 447 option. The Planis applying for a waiver of the annual limits requirements of PHS Act Section 2711

in connection with the aforementioned prescription drug dollar limits. Section 2711would require that these limits be raised to $750,000 in 2011.

The Segal Company calculated the estimated January 1, 2011December 31, 2011premium equivalent that would be generated if the annual limits are removed.

Premium equivalent is the cost of a self-insured plan if the plan were insured.

IAM D15:000003


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Premium EquivalentPrescription

DrugTotal Benefit

Expense2011 Monthly Prescription Drug PremiumEquivalent with annual maximums

2011 Monthly Prescription Drug Premium

Equivalent if the annual maximum onPrescription Drugs is increased to $750,000

Increase in dollarsIncrease as percent

4. A brief description of why compliance with the interim final regulations would result ina significant decrease in access to benefits for those currently covered by such plans or

policies, or significant increase in premiums paid by those covered by such plans orpolicies, along with any supporting documentation.

Complying with the restricted annual dollar limits, i.e., increasing the annual limits to

$750,000 for the 2011 plan year would result in a significant decrease in access tobenefits for current participants and dependents and/or a significant increase in

premiums paid by those covered by the plans, for the following reasons:

The additional cost associated with the increase or elimination of the currentmaximums would not be offset by the ability to obtain additional employercontributions due to existing collective bargaining agreements or other employer

economic constraints.

The Fund, which is on a fixed income based on collective bargaining agreements,would need to cut essential benefits, shift costs to low wage participants

(mechanics, who are the highest paid participants in the Fund, are still fairly lowpaid) who cannot afford to contribute. Because of the economy, the newercontracts have % increases for years beginning after 10/09 and % as of 10/10.

The additional cost associated with the increase or elimination of the current annualmaximums would likely result in material economic hardships that may requireoffsetting reductions in employment or reductions in wages or benefits. Forexample, prescription drug coinsurance paid by participants would have to increase

by at least percentage points (from percent participant coinsurance to overpercent) and the current $ maximum member coinsurance per prescription wouldlikely have to be removed. This would have a disproportionate impact on those

participants that use specialty or other high cost drugs, such as those with MultipleSclerosis, since they would no longer be protected by the co-payment maximum.Their costs would increase exponentially.

Alternatively, members may be required to pay contributions equal to the increasein costs ($ per member per month). Currently participants do not contributetowards the cost of coverage.

IAM D15:000004


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In the absence of new employer/plan sponsor contributions, any required increasesin participant out-of-pocket expenses (e.g. copays, deductibles) would likely causedelayed or foregone medical treatment for a significant portion of the coveredpopulation.

7357297v1/05485.001

IAM D15:000005


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Pages 6 through 9 redacted for the following reasons:- - - - - - - - - - - - - - - - - - - - - - - - - - - -Exemption 4

IAM D15:000006


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///co-adshare/...20-%20Torres/DFOI%20Processing%20Team/Mike/IAM%20District%2015/Request%20for%20info%2012.10.10.htm[10/27/2011 3:12

rom: Scelzo, Kathleen (HHS/OCIIO)ent: Friday, December 10, 2010 2:05 PM

To: '[email protected]'Cc: Habit, Sandra (HHS/OCIIO)ubject: I. A. M. District No. 15 Waiver Application

mportance: High

Attachments: IAM District 15 AL Waiver Applicant Template letter.doc; Waiver Application Form Template.xlsucille,eft you a message this afternoon about getting additional information for the I. A. M. District No. 15 for your Annual Limit Wa

pplication. Attached above are two (2) documents that need to be completed for the annual waiver application. The excel

ttachment has two examples of plans at the start of the document that can be used as a reference in completing the docume

our health plan.

Many thanks for your assistance with these documents.

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 Services

501 Wisconsin Avenue

ethesda, MD

01-492-4121

IAM D15:000007


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October 27, 2011

Dear Applicant:

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

Health Service Act (PHS Act) Section 2711. In order to expedite your application, pleaseprovide the following information:

I. Please complete the entire annual limits spreadsheet attachment. Please return thecompleted spreadsheet to this email address as an attachment. We will only be ableto process spreadsheets that are fully complete (i.e., every cell should contain the

information requested). If a cell on the spreadsheet does not pertain to your plan,

please write None, and/or provide an explanation regarding why you are unable tocomplete that particular cell in a separate document.

II. In addition, please provide the following information: Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in

compliance with grandfathering provisions, pursuant to 45 CFR 147.140?

Confirm whether the plan was created pursuant to the Taft-Hartley Act and the date.In order to complete your application, please provide this information by 5:00 pm, December 13,

2010. Once this information is received and the application is complete, it will be processed bythe Department of Health and Human Services (HHS). As stated in our September 3, 2010 Sub-

Regulatory Guidance, HHS will issue a decision within 30 days of receiving a complete

application. You will receive an e-mail from HHS notifying you of the waiver decision.

Thank you.

Kathleen M. Scelzo, RN, MSNRules Compliance Division

Office of Insurance Oversight

Office of Consumer Information and Insurance Oversight (OCIIO)

Department of Health and Human Services7501 Wisconsin Avenue

Bethesda, MD

301-492-4121

IAM D15:000008


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10/68

ANNUAL LIMIT WAIVER APPLICATION

Ambul ator y Emerg ency Hosp italizatio n Laboratory Pediat ri c

Maternity/

Newborn

Mental Health/

Substance

Abuse

Rehabilitative/

Devices

Preventive/

Wellness

$1,500 None None None None None None None None

None $500 None $1,000 $500 None None None $500

Current Essential Benefits Ann ual Limits (Annu al Limit for Each Essential Benefit)


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ndividual/ Employee

Tier*

Employee

contribution

(if applicable)

Employer

contribution

(if applicable) Total

Employee

contribution

(if applicable)

Employer

contribution


Employee

contribution

(if applicable)

Employer

contribution


Employee $100.00 $600.00 $700.00 $110.00 $650.00 $760.00 $125.00 $800.00 $925.00

Employee +Family $105.00 $1,100.00 $1,205.00 $115.00 $1,150.00 $1,265.00 $150.00 $1,400.00 $1,550.00

Current Monthly Premium Rates or

Premium Equivalent Rates (in dollars)*:

Renewal Monthly Premium Rates or

Premium Equivalent Rates if Waiver Granted

(in dollars)*

Projected Rate Increase that woul d result

from compliance with $750,000 Annual Limit

Restriction (in d ollars) (Average Premium

by Individual)*

* When completing the columns requesting premium rate information, please express the premium rates as a composite rate (ifpremiums are a range based on years of service or age) and by tier (Employee, Employee +Spouse, Employee +Child, Family,etc.) as applicable. If you are an issuer, please provide the premium amount in the column titled, "Total" (Column AN, AQ and AT).


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///co-adshare/...0Waivers%20-%20Torres/DFOI%20Processing%20Team/Mike/IAM%20District%2015/Call%20status%201.19.11.htm[10/27/2011 3:12

rom: Scelzo, Kathleen (HHS/OCIIO)ent: Thursday, January 20, 2011 9:11 AM

To: Habit, Sandra (HHS/OCIIO)ubject: FW: [MARKETING EMAIL]RE: [MARKETING EMAIL]RE: IAM District #15

athleen M. Scelzo, RN, MSNules Compliance Divisionffice of Insurance Oversight

ffice of Consumer Information and Insurance Oversight (OCIIO)epartment of Health and Human Services501 Wisconsin Avenueethesda, MD01-492-4121

rom: Marylou Gartland [mailto:[email protected]]ent: Friday, January 14, 2011 11:48 AMo: Scelzo, Kathleen (HHS/OCIIO)ubject: [MARKETING EMAIL]RE: [MARKETING EMAIL]RE: IAM District #15

k I will call you then - thanks



[email protected]

rom: Scelzo, Kathleen (HHS/OCIIO) [mailto:[email protected]]ent: Friday, January 14, 2011 11:46 AMo: '[email protected]'ubject: RE: [MARKETING EMAIL]RE: IAM District #15

am available at 2:30pm

athleen M. Scelzo, RN, MSNules Compliance Divisionffice of Insurance Oversightffice of Consumer Information and Insurance Oversight (OCIIO)epartment of Health and Human Services501 Wisconsin Avenueethesda, MD01-492-4121

rom: Marylou Gartland [mailto:[email protected]]ent: Friday, January 14, 2011 11:19 AMo: Scelzo, Kathleen (HHS/OCIIO)c: Habit, Sandra (HHS/OCIIO); Lucille Hart (Lucille Hart); Steve Seide; joan rothermelubject: [MARKETING EMAIL]RE: IAM District #15

athleen Just so we understand exactly what you are requesting, can you be available at 2:30 pm to have a call with my

nd the Actuary?

Marylou Gartland

IAM D15:000012


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Fund ManagerENEFIT SERVICES185 LEMOINE AVEORT LEE, NJ 0702401-947-8000

[email protected]

rom: Scelzo, Kathleen (HHS/OCIIO) [mailto:[email protected]]ent: Friday, January 14, 2011 8:51 AMo: '[email protected]'c: Habit, Sandra (HHS/OCIIO)

ubject: RE: IAM District #15

Marylou,n column Q I need the Current Plan Overall Annual Limit (in dollars) for each plan. This would be the annual limits for medicaan such as $750,000:

Tier 1

Tier 2

Tier 3

Tier 4


ules Compliance Divisionffice of Insurance Oversightffice of Consumer Information and Insurance Oversight (OCIIO)epartment of Health and Human Services501 Wisconsin Avenueethesda, MD01-492-4121

rom: Marylou Gartland [mailto:[email protected]]ent: Wednesday, January 12, 2011 11:07 AMo: Scelzo, Kathleen (HHS/OCIIO)

c: Habit, Sandra (HHS/OCIIO); Jeanette Giotta; Lisa Ricciardelli; sonal sanghvi; Steve Seide; Lucille Hart (Lucille Hart); joanothermelubject: RE: IAM District #15

athleen As promised, see attached. Let me know if you have any questions or need any additional information.



[email protected]: Scelzo, Kathleen (HHS/OCIIO) [mailto:[email protected]]ent: Tuesday, January 11, 2011 7:35 AMo: '[email protected]'c: Habit, Sandra (HHS/OCIIO)ubject: RE: IAM District #15

Many thanks,

athleen M. Scelzo, RN, MSNules Compliance Divisionffice of Insurance Oversight

IAM D15:000013
mailto:[email protected]:[email protected]:[email protected]:[email protected]


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ffice of Consumer Information and Insurance Oversight (OCIIO)epartment of Health and Human Services501 Wisconsin Avenueethesda, MD01-492-4121

rom: Marylou Gartland [mailto:[email protected]]ent: Monday, January 10, 2011 4:14 PMo: Scelzo, Kathleen (HHS/OCIIO)

c: Habit, Sandra (HHS/OCIIO); Lucille Hart (Lucille Hart)ubject: RE: IAM District #15

have just been advised that we will hopefully have the information by tomorrow.



[email protected]

rom: Scelzo, Kathleen (HHS/OCIIO) [mailto:[email protected]]ent: Monday, January 10, 2011 3:07 PMo: '[email protected]'c: Habit, Sandra (HHS/OCIIO)ubject: RE: IAM District #15

Marylou, Can you give me a status update on when the spreadsheet will be completed for the Limited Waiver?

athleen M. Scelzo, RN, MSNules Compliance Divisionffice of Insurance Oversightffice of Consumer Information and Insurance Oversight (OCIIO)

epartment of Health and Human Services501 Wisconsin Avenueethesda, MD01-492-4121

rom: Marylou Gartland [mailto:[email protected]]ent: Tuesday, January 04, 2011 10:42 AMo: Scelzo, Kathleen (HHS/OCIIO)c: Habit, Sandra (HHS/OCIIO); Lucille Hart (Lucille Hart)ubject: RE: IAM District #15

athleen are you available at 3pm today for a call with the actuaries regarding the additional information needed for D-



[email protected]

rom: Scelzo, Kathleen (HHS/OCIIO) [mailto:[email protected]]ent: Thursday, December 30, 2010 4:07 PMo: '[email protected]'

IAM D15:000014


15/68


c: Habit, Sandra (HHS/OCIIO)ubject: FW:IAM District #15

Marylou,hanks for talking with me this afternoon,his is the information that it needed to complete the spreadsheet:

Total Number of Individuals Covered by Policy (include all dependents covered) for each tier with subcategory

Tier 1: Single

Tier 1: Family

Current Plan Overall Annual Limit (in dollars): What is the annual limit of the medical plan for each tier?Cost for each tier to the employee and the employer

look forward to talking with you on Tuesday

athleen M. Scelzo, RN, MSNules Compliance Divisionffice of Insurance Oversightffice of Consumer Information and Insurance Oversight (OCIIO)epartment of Health and Human Services501 Wisconsin Avenueethesda, MD

01-492-4121

rom: Marylou Gartland [mailto:[email protected]]ent: Wednesday, December 29, 2010 12:35 PMo: Scelzo, Kathleen (HHS/OCIIO)ubject: FW: D-15 Waiver Application



[email protected]

rom: Marylou Gartland [mailto:[email protected]]ent: Friday, December 17, 2010 2:17 PMo: Kathleen Scelzo ([email protected])c: Lucille Hart (Lucille Hart); joan rothermel ([email protected]); Steve Seide ([email protected]); Lisa [email protected]); Caroline Gordon (Caroline Gordon)ubject: D-15 Waiver Application

athleen

s per your email to Lucille Hart on December 10, 2010, we have attached the additional information that you requested.

lease be further advised that the plan was in existence prior to March 23, 2010 and is in compliance with grandfatheringrovisions, pursuant to 45 CFR 147.140. Also, this is to confirm that the plan was created pursuant to the Taft-Hartley Act effe

ebruary 21, 1951. I will be on vacation until December 29th, so if you need anything please contact me at that time. Also, ple aware that there are three tabs on the spreadsheet.

IAM D15:000015


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[email protected]

ucille,

eft you a message this afternoon about getting additional information for the I. A. M. District No. 15 for your Annual Limit Wapplication. Attached above are two (2) documents that need to be completed for the annual waiver application. The excelttachment has two examples of plans at the start of the document that can be used as a reference in completing the documeour health plan.


athleen M. Scelzo, RN, MSNules Compliance Divisionffice of Insurance Oversightffice of Consumer Information and Insurance Oversight (OCIIO)epartment of Health and Human Services501 Wisconsin Avenueethesda, MD01-492-4121

IAM D15:000016


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///co-adshare/...aivers%20-%20Torres/DFOI%20Processing%20Team/Mike/IAM%20District%2015/Correspondence%2012.30.10.htm[10/27/2011 3:12

rom: Scelzo, Kathleen (HHS/OCIIO)ent: Thursday, December 30, 2010 12:50 PM

To: '[email protected]'Cc: Habit, Sandra (HHS/OCIIO)ubject: RE: D15 waiver

Marylou,

Many thanks for the document! Soory I did not get back to you soon but I was pulled to work on a project. I will look at the

ocument in the early afternoon.

athleen M. Scelzo, RN, MSNules Compliance Division


ffice of Consumer Information and Insurance Oversight (OCIIO)

epartment of Health and Human Services


ethesda, MD

01-492-4121

rom: Marylou Gartland [mailto:[email protected]]ent: Thursday, December 30, 2010 11:19 AM

o: Scelzo, Kathleen (HHS/OCIIO)c: Lucille Hart (Lucille Hart)ubject: D15 waiver

athleen I am assuming that since I did not hear from you this morning by phone, that you received the email and there

o current questions?

appy New Year .



[email protected]

IAM D15:000017


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///co-adshare/...0Waivers%20-%20Torres/DFOI%20Processing%20Team/Mike/IAM%20District%2015/Corresondence%201.11.11.htm[10/27/2011 3:12

rom: Scelzo, Kathleen (HHS/OCIIO)ent: Tuesday, January 11, 2011 7:34 AM

To: Habit, Sandra (HHS/OCIIO)ubject: FW: IAM District #15




ffice of Consumer Information and Insurance Oversight (OCIIO)epartment of Health and Human Services


ethesda, MD

01-492-4121

rom: Marylou Gartland [mailto:[email protected]]ent: Monday, January 10, 2011 3:15 PMo: Scelzo, Kathleen (HHS/OCIIO)ubject: RE: IAM District #15

athleen I checked with the actuaries this morning and they have not gotten back to me as of yet I will forward them ymail again. Sorry about that



[email protected]

rom: Scelzo, Kathleen (HHS/OCIIO) [mailto:[email protected]]ent: Monday, January 10, 2011 3:07 PM

o: '[email protected]'c: Habit, Sandra (HHS/OCIIO)ubject: RE: IAM District #15








ethesda, MD

01-492-4121



IAM D15:000018


19/68




[email protected]



Marylou,

hanks for talking with me this afternoon,

his is the information that it needed to complete the spreadsheet:


Tier 1: Single

Tier 1: Family

Current Plan Overall Annual Limit (in dollars): What is the annual limit of the medical plan for each tier?

Cost for each tier to the employee and the employer








ethesda, MD

01-492-4121




[email protected]


athleen


IAM D15:000019


20/68


lease be further advised that the plan was in existence prior to March 23, 2010 and is in compliance with grandfathering

rovisions, pursuant to 45 CFR 147.140. Also, this is to confirm that the plan was created pursuant to the Taft-Hartley Act effe

ebruary 21, 1951. I will be on vacation until December 29th, so if you need anything please contact me at that time. Also, pl

e aware that there are three tabs on the spreadsheet.



[email protected]

ucille,

eft you a message this afternoon about getting additional information for the I. A. M. District No. 15 for your Annual Limit Wa



our health plan.








ethesda, MD

01-492-4121

IAM D15:000020


21/68


rom: Scelzo, Kathleen (HHS/OCIIO)ent: Thursday, December 30, 2010 4:07 PM

To: '[email protected]'Cc: Habit, Sandra (HHS/OCIIO)ubject: FW:IAM District #15

Attachments: IAM 15 Waiver Application Form Template (3).XLSMarylou,




Tier 1: Single

Tier 1: Family






ffice of Insurance Oversightffice of Consumer Information and Insurance Oversight (OCIIO)



ethesda, MD

01-492-4121




[email protected]


athleen





IAM D15:000021


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ENEFIT SERVICES185 LEMOINE AVE

ORT LEE, NJ [email protected]

ucille,




our health plan.








ethesda, MD

01-492-4121

IAM D15:000022


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///co-adshare/.../DFOI%20Processing%20Team/Mike/IAM%20District%2015/Request%20for%20phone%20conference%201.4.11.htm[10/27/2011 3:12

rom: Marylou Gartland [[email protected]]ent: Tuesday, January 04, 2011 10:42 AM

To: Scelzo, Kathleen (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO); Lucille Hart (Lucille Hart)ubject: RE: IAM District #15athleen are you available at 3pm today for a call with the actuaries regarding the additional information needed for D-

Marylou Gartland


[email protected]

rom: Scelzo, Kathleen (HHS/OCIIO) [mailto:[email protected]]ent: Thursday, December 30, 2010 4:07 PMo: '[email protected]'c: Habit, Sandra (HHS/OCIIO)ubject: FW:IAM District #15

Marylou,

hanks for talking with me this afternoon,his is the information that it needed to complete the spreadsheet:


Tier 1: Single

Tier 1: Family





ules Compliance Divisionffice of Insurance Oversight




ethesda, MD

01-492-4121




[email protected]

rom: Marylou Gartland [mailto:[email protected]]

IAM D15:000023


24/68

///co-adshare/.../DFOI%20Processing%20Team/Mike/IAM%20District%2015/Request%20for%20phone%20conference%201.4.11.htm[10/27/2011 3:12

ent: Friday, December 17, 2010 2:17 PMo: Kathleen Scelzo ([email protected])c: Lucille Hart (Lucille Hart); joan rothermel ([email protected]); Steve Seide ([email protected]); Lisa [email protected]); Caroline Gordon (Caroline Gordon)ubject: D-15 Waiver Application

athleen







ORT LEE, NJ 0702401-947-8000

[email protected]

ucille,




our health plan.








ethesda, MD

01-492-4121

IAM D15:000024


25/68

///co-adshare/...0Waivers%20-%20Torres/DFOI%20Processing%20Team/Mike/IAM%20District%2015/Correspondence%201.4.11.htm[10/27/2011 3:12

rom: Marylou Gartland [[email protected]]ent: Tuesday, January 04, 2011 9:50 AM

To: Scelzo, Kathleen (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO); Lucille Hart (Lucille Hart)ubject: RE: IAM District #15hanks Kathleen for the information. I have forwarded to the actuaries that completed the waiver application and awaitin

me that they would be available to speak to us.

hanks again for your help in this matter.



[email protected]



Marylou,




Tier 1: Single

Tier 1: Family










ethesda, MD

01-492-4121




IAM D15:000025


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///co-adshare/...0Waivers%20-%20Torres/DFOI%20Processing%20Team/Mike/IAM%20District%2015/Correspondence%201.4.11.htm[10/27/2011 3:12

ORT LEE, NJ 0702401-947-8000

[email protected]


athleen








[email protected]

ucille,




our health plan.








ethesda, MD

01-492-4121

IAM D15:000026


27/68

///co-adshare/...Waivers%20-%20Torres/DFOI%20Processing%20Team/Mike/IAM%20District%2015/Status%20check%201.7.11.htm[10/27/2011 3:12

rom: Scelzo, Kathleen (HHS/OCIIO)ent: Friday, January 07, 2011 2:45 PM

To: '[email protected]'Cc: Habit, Sandra (HHS/OCIIO)ubject: RE: IAM District #15

mportance: HighMarylou,

am calling to check on the status on the spreadsheet for the Limited Waiver Application for IAM District #15. When do you th

ou will have it back to me?







ethesda, MD

01-492-4121





ORT LEE, NJ 0702401-947-8000

[email protected]


Marylou,




Tier 1: Single

Tier 1: Family







ffice of Consumer Information and Insurance Oversight (OCIIO)IAM D15:000027


28/68




ethesda, MD

01-492-4121




[email protected]


athleen








[email protected]

ucille,




our health plan.



IAM D15:000028


29/68







ethesda, MD

01-492-4121

IAM D15:000029


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///co-adshare/...%20Torres/DFOI%20Processing%20Team/Mike/IAM%20District%2015/Status%20check%20response%201.10.11.htm[10/27/2011 3:12

rom: Marylou Gartland [[email protected]]ent: Monday, January 10, 2011 4:14 PM

To: Scelzo, Kathleen (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO); Lucille Hart (Lucille Hart)ubject: RE: IAM District #15have just been advised that we will hopefully have the information by tomorrow.

Marylou Gartland


[email protected]









ethesda, MD

01-492-4121

rom: Marylou Gartland [mailto:[email protected]]

ent: Tuesday, January 04, 2011 10:42 AMo: Scelzo, Kathleen (HHS/OCIIO)c: Habit, Sandra (HHS/OCIIO); Lucille Hart (Lucille Hart)ubject: RE: IAM District #15



ENEFIT SERVICES185 LEMOINE AVEORT LEE, NJ 07024

[email protected]


Marylou,




IAM D15:000030


31/68


Tier 1: Single

Tier 1: Family









ethesda, MD

01-492-4121




[email protected]

rom: Marylou Gartland [mailto:[email protected]]ent: Friday, December 17, 2010 2:17 PM

o: Kathleen Scelzo ([email protected])c: Lucille Hart (Lucille Hart); joan rothermel ([email protected]); Steve Seide ([email protected]); Lisa [email protected]); Caroline Gordon (Caroline Gordon)ubject: D-15 Waiver Application

athleen








[email protected]

IAM D15:000031


32/68


ucille,




our health plan.








ethesda, MD

01-492-4121

IAM D15:000032


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///co-adshare/...%20-%20Torres/DFOI%20Processing%20Team/Mike/IAM%20District%2015/Update%20on%20status%201.10.11.htm[10/27/2011 3:12

rom: Scelzo, Kathleen (HHS/OCIIO)ent: Monday, January 10, 2011 3:07 PM








ethesda, MD

01-492-4121





[email protected]

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

ent: Thursday, December 30, 2010 4:07 PMo: '[email protected]'c: Habit, Sandra (HHS/OCIIO)ubject: FW:IAM District #15

Marylou,




Tier 1: Single

Tier 1: Family










ethesda, MD

01-492-4121

IAM D15:000033


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[email protected]


athleen








[email protected]

ucille,




our health plan.







IAM D15:000034


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ethesda, MD

01-492-4121

IAM D15:000035


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///co-adshare/...%20Torres/DFOI%20Processing%20Team/Mike/IAM%20District%2015/Correspondence%20response%201.11.11.htm[10/27/2011 3:12

rom: Scelzo, Kathleen (HHS/OCIIO)ent: Tuesday, January 11, 2011 7:35 AM


Many thanks,






ethesda, MD

01-492-4121

rom: Marylou Gartland [mailto:[email protected]]ent: Monday, January 10, 2011 4:14 PMo: Scelzo, Kathleen (HHS/OCIIO)c: Habit, Sandra (HHS/OCIIO); Lucille Hart (Lucille Hart)ubject: RE: IAM District #15




[email protected]

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

ent: Monday, January 10, 2011 3:07 PMo: '[email protected]'c: Habit, Sandra (HHS/OCIIO)ubject: RE: IAM District #15








ethesda, MD01-492-4121



IAM D15:000036


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[email protected]


Marylou,




Tier 1: Single

Tier 1: Family










ethesda, MD

01-492-4121



ENEFIT SERVICES

185 LEMOINE AVEORT LEE, NJ 0702401-947-8000

[email protected]


athleen

IAM D15:000037


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[email protected]

ucille,


pplication. Attached above are two (2) documents that need to be completed for the annual waiver application. The excelttachment has two examples of plans at the start of the document that can be used as a reference in completing the docume

our health plan.








ethesda, MD

01-492-4121

IAM D15:000038


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///co-adshare/...rres/DFOI%20Processing%20Team/Mike/IAM%20District%2015/Correspondence%20response%20(2)%201.11.11.htm[10/27/2011 3:12

rom: Marylou Gartland [[email protected]]ent: Tuesday, January 11, 2011 4:47 PM

To: Scelzo, Kathleen (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO)ubject: RE: IAM District #15athleen the information is not quite finished Fund Counsel needs to review it also I will have it to you either tomorr

f there is no snow emergency) or on Thursday. Sorry for the delay, but these things take time and must be reviewed by a

nvolved.



[email protected]

rom: Scelzo, Kathleen (HHS/OCIIO) [mailto:[email protected]]ent: Tuesday, January 11, 2011 7:35 AM


Many thanks,







ethesda, MD

01-492-4121



Marylou GartlandFund ManagerENEFIT SERVICES185 LEMOINE AVEORT LEE, NJ 0702401-947-8000

[email protected]


IAM D15:000039


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ethesda, MD

01-492-4121





[email protected]


Marylou,hanks for talking with me this afternoon,



Tier 1: Single

Tier 1: Family










ethesda, MD

01-492-4121

rom: Marylou Gartland [mailto:[email protected]]ent: Wednesday, December 29, 2010 12:35 PMo: Scelzo, Kathleen (HHS/OCIIO)

IAM D15:000040


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ubject: FW: D-15 Waiver Application


ENEFIT SERVICES185 LEMOINE AVEORT LEE, NJ 07024

[email protected]


athleen







[email protected]

ucille,




our health plan.








ethesda, MD

01-492-4121

IAM D15:000041


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IAM D15:000042


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///co-adshare/...rres/DFOI%20Processing%20Team/Mike/IAM%20District%2015/Reqeust%20for%20info%20response%201.12.11.htm[10/27/2011 3:1

rom: Marylou Gartland [[email protected]]ent: Wednesday, January 12, 2011 11:07 AM

To: Scelzo, Kathleen (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO); Jeanette Giotta; Lisa Ricciardelli; sonal sanghvi; Steve Seide; Lucille Hart (LucilHart); joan rothermelubject: RE: IAM District #15

Attachments: FinalIAM 15 Waiver Application Form Template REVISED-Final.XLS; FinalIAM District 15 Healt

und Attachment A-revised by Fund Counsel.docathleen As promised, see attached. Let me know if you have any questions or need any additional information.



[email protected]

rom: Scelzo, Kathleen (HHS/OCIIO) [mailto:[email protected]]ent: Tuesday, January 11, 2011 7:35 AM


Many thanks,







ethesda, MD

01-492-4121



Marylou Gartland


[email protected]


IAM D15:000043


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ethesda, MD

01-492-4121





[email protected]


Marylou,

hanks for talking with me this afternoon,his is the information that it needed to complete the spreadsheet:


Tier 1: Single

Tier 1: Family









ethesda, MD

01-492-4121


IAM D15:000044


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[email protected]: Marylou Gartland [mailto:[email protected]]ent: Friday, December 17, 2010 2:17 PMo: Kathleen Scelzo ([email protected])c: Lucille Hart (Lucille Hart); joan rothermel ([email protected]); Steve Seide ([email protected]); Lisa [email protected]); Caroline Gordon (Caroline Gordon)ubject: D-15 Waiver Application

athleen








[email protected]

ucille,




our health plan.








ethesda, MD

01-492-4121

IAM D15:000045


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IAM D15:000046


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IAM District 15 Health FundApplication for Waiver of the Annual Limits Requirement of the Public Health Service Act, Section 2711

1

IAM District 15 Health Fund

Waiver Application Plan Year January 1, 2011

Attachment A

Compliance Implications - Brief description of why compliance with the Interim

Final Regulations would result in a significant decrease in access to benefits for

those currently covered by such plans or policies, or significant increase in

premiums paid by those covered by such plans or policies, along with supporting

documentation.

The Funds compliance with the restricted annual dollar limits contained in the InterimFinal Regulations would result in a significant decrease in access to benefits for currentparticipants for the following reasons:

The additional cost associated with the increase in the maximum annual benefitcannot be offset by the ability to obtain additional employer contributions due toexisting collective bargaining agreements. Because of the economy, the newercontracts have % increases for years beginning after 10/09 and % as of 10/10.

Many of these employers are automobile dealerships, which have been in dire straitsand in many cases are closing their doors. Even if additional employer contributionswere feasible, the added costs would be highly burdensome in this highly competitiveindustry, which would result in further job losses, and as a result, fewer employeesworking sufficient hours to either obtain or retain benefit eligibility.

The Fund, which is on a fixed income based on collective bargaining agreements,would need to cut essential benefits, shift costs to low wage participants (mechanics,who are the highest paid participants in the Fund, are still fairly low paid) who cannotafford to contribute.

If the expected costs of implementing the annual limit restrictions in 2011 were to bepassed on directly to covered employees, the resulting annual contribution increaseswould range from $ to $ approximately, per employee per month in 2011.Currently participants do no tribute towards the cost of coverage. Manyemployees would reject coverage rather than contribute to the cost.

To finance the increased costs, the Plan would likely have to include a combination ofsubstantial benefit reductions and increased employee costs:

Prescription drug coinsurance paid by participants would have to increase by at leastpercentage points (from percent participant coinsurance to over percent) andcurrent $ maximum mber coinsurance per prescription woul kely have to

be removed. is would have a disproportionate impact on those participants that usespecialty or other high cost drugs, such as those with Multiple Sclerosis, since theywould no longer be protected by the maximum. Their costs would increaseexponentially.

In the absence of new employer/plan sponsor contributions, any required increases inparticipant out of pocket expenses (e.g. copays, deductibles) would likely cause

IAM D15:000047


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IAM District 15 Health FundApplication for Waiver of the Annual Limits Requirement of the Public Health Service Act, Section 2711

2

delayed or foregone medical treatment for a significant portion of the coveredpopulation.

Note that Tier 3 offers single-only coverage. The current negotiated contributionrates are already inadequate to cover the benefits provided.

We also wish to confirm the following:

This is to confirm that the Plan was in existence prior to March 23, 2010 and is incompliance with grandfathering provisions, pursuant to 45 CFR 147.140.

This is to confirm that the plan was created pursuant to the Taft-Hartley Act effectiveFebruary 21, 1951.

IAM D15:000048


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Ann ual

Limit Waiver

Request

App lic ant

Name

Policy Name

(use a new

row for each

policy

application)

App lic ant

(Plan/ Policy

Situs) City

App lic ant

(Plan/

Policy

Situs)

State

Plan/ Policy

Effective Date

(mm/dd/yyyy)

Contact

Name

Street

Add ress City State Zip Code

Phone

Number

(including

area code)

Email

Add ress

Type

Cover

(e.g., L

Benefit,

Rx only,

IAM District

15 Health

Fund Tier 1 Brooklyn NY 01/01/2011 Lucille Hart

2185

LeMoine Ave Fort Lee NJ 07024

201-947-

8000

lucille.hart@

benserconj.c

om RX O

IAM District

15 Health


2185


201-947-

8000

lucille.hart@

benserconj.c

om RX OIAM District

15 Health 2185 201-947-

lucille.hart@

benserconj.c

Fund Tier 2 Brooklyn NY 01/01/2011 Lucille Hart LeMoine Ave Fort Lee NJ 07024 8000

.

om RX OIAM District

15 Health


2185


201-947-

8000

lucille.hart@

benserconj.c

om RX O

IAM District

15 Health


2185


201-947-

8000

lucille.hart@

benserconj.c

om RX O

IAM District

15 Health


2185


201-947-

8000

lucille.hart@

benserconj.c

om RX O

IAM District

15 Health


2185


201-947-

8000

lucille.hart@

benserconj.c

om RX O

IAM District

15 Health


2185


201-947-

8000

lucille.hart@

benserconj.c

om RX O


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Ambulator y Emergency Hosp italizat ion Labo rato ry Pediat ric

Maternity/

Newborn

Mental Health/

Substance

Abuse

Rehabilitative/

Devices

Preventive/

Wellness Presc

Current Essential Benefits Ann ual Limits (Annual Limit fo r Each Essential Benefit)


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ndividual/ Employee

Tier*

Employee

contribution

(if applicable)

Employer

contribution


Employee

contribution

(if applicable)

Employer

contribution


Employee

contribution

(if applicable)

Employer

contribution


Pro

tha

comp

Ann

(i

Pre

(Diff

a

Employee

Employee +Family

Projected Rate Increase that would result

from compliance with $750,000 Annual

Limit Restriction (in dollars) (Average

Premium by Individual)*

Current Monthly Premium Rates or

Premium Equivalent Rates (in dollars)*:

Renewal Monthly Premium Rates or

Premium Equivalent Rates if Waiver

Granted (in dollars)*

Employee

Employee +Family

Employee

Employee +Family

Employee

Employee

* When completing the columns requesting premium rate information, please express the premium rates as a composite rate (ifpremiums are a range based on years of service or age) and by tier (Employee, Employee +Spouse, Employee +Child, Family,etc.) as applicable. If you are an issuer, please provide the premium amount in the column titled, "Total" (Column AN, AQ and AT).


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Ann ual

Limit Waiver

Request

App lic ant

Name

Policy Name

(use a new

row for each

policy

application)

App lic ant

(Plan/ Policy

Situs) City

App lic ant

(Plan/

Policy

Situs)

State

Plan/ Policy

Effective Date

(mm/dd/yyyy)

Contact

Name

Street

Add ress City State Zip Code

Phone

Number

(including

area code)

Email

Add ress

Type

Cover

(e.g., L

Benefit,

Rx only,

IAM District

15 Health


2185


201-947-

8000

lucille.hart@

benserconj.c

om RX O

IAM District

15 Health


2185


201-947-

8000

lucille.hart@

benserconj.c

om RX OIAM District

15 Health 2185 201-947-

lucille.hart@

benserconj.c

Fund Tier 3 Brooklyn NY 01/01/2011 Lucille Hart LeMoine Ave Fort Lee NJ 07024 8000

.

om RX OIAM District

15 Health

Fund

Tier 4: Local

447 Brooklyn NY 01/01/2011 Lucille Hart

2185


201-947-

8000

lucille.hart@

benserconj.c

om RX O

PRA Disclosure Statement

According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless it displays a valid OMB control number. The validnformation collection is 0938-1105. The time required to complete this information collection is estimated to average ( 8 hours) or ( 240 minutes) per response, including thesearch existing data resources, gather the data needed, and complete and review the information collection. If you have comments concerning the accuracy of the time estimmproving this form, please write to: CMS, 7500 Security Boulevard, Attn: PRA Reports Clear

IAM District 15 - Redacted HWM

Documents

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