Roofers Local 96 - Redacted Bates HWM

7/27/2019 Roofers Local 96 - Redacted Bates HWM

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//T|/...0[YELLOW]/Roofers%20Local%20No.%2096%20Health%20and%20Welfare%20Fund/Annual%20Waiver%20Application.txt[08/17/2011 10:18:

rom: Mike Theirl [[email protected]]ent: Monday, November 01, 2010 3:26 PMo: HHS HealthInsurance (HHS)

Cc: [email protected]; [email protected]: Annual Waiver Application

Attachments: hhs.gov waiver application material roofers.pdf

o Whom It May Concern;

lease find enclosed a copy of the Roofers Local #96 Health & Welfare Fund waiver request/application and theupporting documentation.

will also mail an original set of the same material.

lease contact me if you have any questions.

incerely,Mike Theirl, CEBSAdministrator

Wilson-McShane Corporationhone: (952) 854-0795

Direct: (952) 851-3456ax: (952) 854-1632mail: [email protected]

Roofers L96:000001

Document obtained by CompleteColorado.com


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Roofers L96:000002



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Roofers L96:000003



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Roofers L96:000004



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Pages 5 through 23 redacted for the following reasons:- - - - - - - - - - - - - - - - - - - - - - - - - - - -Exemption 4

Roofers L96:000005



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//T|/...fers%20Local%20No.%2096%20Health%20and%20Welfare%20Fund/Request%20for%20additional%20info%2011.16.10.htm[08/17/2011 10:18:

rom: Moultrie, Cam (HHS/OCIIO)ent: Tuesday, November 16, 2010 5:06 PM

To: [email protected]; [email protected]: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application for Roofer Local No. 96 Health and Welfare Fund

ear Mr. Rosene:

hank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section

711. In order to complete your application, please provide the following information:

In your application, your plan(s) or policy(ies) provide a lifetime limit. According to the regulation, y

may not have any lifetime limit on your plan, except in the case of non-essential benefits that are

permitted under Federal or State law. Effective September 23, 2010, you may no longer have a lifetim

limit on your plan or policy. Plans that previously had a lifetime limit may add an annual limit not les

than the lifetime limit without affecting the grandfather status of the plan.

Please confirm whether the plan has lifetime or annual limits on ambulatory, emergency, hospitalization,

aboratory, pediatric, maternity/newborn, mental health/substance abuse, rehabilitative/devices,reventive/wellness, or prescription benefits and identify the corresponding limits.

Please confirm whether the plan is in compliance with the interim final regulations relating to

grandfathered health plans.

Please provide the current monthly premium rates and the projected monthly premium rates applica

to the plan or policy forms if the plan were to comply with the restricted annual benefits. In other

words, we would like a chart that reflects the following information:

2010 JanuaryPremium (currentlevel)

2011 JanuaryPremium (renewal)

2011 JanuaryPremium (if $750,000annual limit wasapplied)

EE

EE + Child (ifapplicable or otherappropriate tier)

EE + Spouse (ifapplicable or otherappropriate tier)

Family (if applicableor other appropriatetier)

n order to complete your application, please provide this information by 5:00 pm, November 17, 2010. We

ook forward to receiving your completed application. Thank you.

Roofers L96:000006



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//T|/...cal%20No.%2096%20Health%20and%20Welfare%20Fund/equest%20for%20additional%20info%20response%2011.16.10.htm[08/17/2011 10:18

rom: Peter M. Rosene [[email protected]]ent: Tuesday, November 16, 2010 8:18 PM

To: Moultrie, Cam (HHS/OCIIO); [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]

ubject: RE: Waiver Application for Roofer Local No. 96 Health and Welfare Fund

rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]

ent: Tuesday, November 16, 2010 4:06 PMo: [email protected]; [email protected]: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application for Roofer Local No. 96 Health and Welfare Fund

ear Mr. Rosene:




may not have any lifetime limit on your plan, except in the case of non-essential benefits that arepermitted under Federal or State law. Effective September 23, 2010, you may no longer have a lifetim


than the lifetime limit without affecting the grandfather status of the plan. The Plan year, in this case

December 1 through November 30. The trustees have eliminated the lifetime maximum, as required b

law, effective with the first day of the plan year following September 23, 2010. Therefore, this plan w

have no lifetime limits as of December 1, 2010. We are asking to have an annual limit that correspon

with our old (and revoked) lifetime limit.

Please confirm whether the plan has lifetime or annual limits on ambulatory, emergency, hospitalizat

laboratory, pediatric, maternity/newborn, mental health/substance abuse, ative/devices,preventive/wellness, or prescription benefits and identify the correspondi This plan never annual limits for essential benefits. The major medical lifetime limit was $ which has beenrevoked with the first day of the plan year following September 23, 2010.


grandfathered health plans. The plan is in full compliance with the interim final regulations relating t


Please provide the current monthly premium rates and the projected monthly premium rates applicab


words, we would like a chart that reflects the following information: This is a composite rate (family

only) plan. No other elections have ever been permitted. The eligibility provisions for the plan are as

follows, which shows the minimum number of hours of collectively bargained work necessary for

coverage:

nitial Eligibility - Collective Bargained Employees

You will become eligible for benefits onRoofers L96:000007



8/109


nitial Eligibility - Non-bargaining Unit Employees

Continuing Eligibility - Collective Bargained Employees

will have the administrator confirm the existing contribution rate by a separate e-mail to you, as I am current

Hawaii teaching at a conference. As we have no ability to increase employer contributions, the premium would remhe same and benefits would have to be slashed in an amount equal to the cost of stop loss insurance. I hope thats responsive to your request; please let me know if you have further inquiries.




EE

EE + Child (ifapplicable or other

appropriate tier)




Roofers L96:000008



9/109



Roofers L96:000009



10/109


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//T|/...l%20No.%2096%20Health%20and%20Welfare%20Fund/Request%20for%20additional%20info%20response%2011.17.10.htm[08/17/2011 10:18:

li is plan never had annual limits for essential benefits. The major medical lifetime limit was$ , which has been revoked with the first day of the plan year following September 23, 2010.

Pl firm whether the plan is in compliance with the interim final regulations relating to



Please provide the current monthly premium rates and the projected monthly premium rates applicabto the plan or policy forms if the plan were to comply with the restricted annual benefits. In other




coverage:




will have the administrator confirm the existing contribution rate by a separate e-mail to you, as I am currentHawaii teaching at a conference. As we have no ability to increase employer contributions, the premium would rem

Roofers L96:000011



12/109

//T|/...l%20No.%2096%20Health%20and%20Welfare%20Fund/Request%20for%20additional%20info%20response%2011.17.10.htm[08/17/2011 10:18:

he same and benefits would have to be slashed in an amount equal to the cost of stop loss insurance. I hope thats responsive to your request; please let me know if you have further inquiries.




EE

EE + Child (if

applicable or otherappropriate tier)





Roofers L96:000012



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//T|/...o.%2096%20Health%20and%20Welfare%20Fund/Request%20for%20additional%20info%20response%20(2)%2011.17.10.htm[08/17/2011 10:18

rom: [email protected]: Wednesday, November 17, 2010 3:54 PM

To: Moultrie, Cam (HHS/OCIIO); Peter M. RoseneCc: Habit, Sandra (HHS/OCIIO); [email protected]

ubject: Re: Waiver Application for Roofer Local No. 96 Health and WelfareFundDear Cam,

ly contribution rate is $ for the bargaining participants. The Non-Bargaining composite monthly rate i

ntact me if you have any further questions for me.hanks,Mike Theirl

ent on the Sprint Now Network from my BlackBerry

rom: "Moultrie, Cam (HHS/OCIIO)" Date: Wed, 17 Nov 2010 13:59:07 -0500To: Peter M. Rosene; [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]


Mr. Rosene,

hank you for your response. I look forward to the contribution rates.

am Moultrie

am Lynne Moultrie

rogram Analyst

ffice of Consumer Information and Insurance Oversight

.S. Department of Health and Human Services

301) 492-4174

[email protected]

rom: Peter M. Rosene [mailto:[email protected]]ent: Tuesday, November 16, 2010 8:18 PMo: Moultrie, Cam (HHS/OCIIO); [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]: RE: Waiver Application for Roofer Local No. 96 Health and Welfare Fund

rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Tuesday, November 16, 2010 4:06 PMo: [email protected]; [email protected]: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application for Roofer Local No. 96 Health and Welfare Fund

ear Mr. Rosene:



Roofers L96:000013



14/109











Please confirm whether the plan has lifetime or annual limits on ambulatory, emergency,hospitalization, laboratory, pediatric, maternity/newborn, mental health/substance abuse,r tive/devices, preventive/wellness, or prescription benefits and identify the correspondingli is plan never had annual limits for essential benefits. The major medical lifetime limit was$ which has been revoked with the first day of the plan year following September 23, 2010.

Pl firm whether the plan is in compliance with the interim final regulations relating to

grandfathered health plans. The plan is in full compliance with the interim final regulations relating tgrandfathered health plans.






coverage:



Roofers L96:000014



15/109



Any combination of the above may be used to continue eligibility.

will have the administrator confirm the existing contribution rate by a separate e-mail to you, as I am currentHawaii teaching at a conference. As we have no ability to increase employer contributions, the premium would remhe same and benefits would have to be slashed in an amount equal to the cost of stop loss insurance. I hope thats responsive to your request; please let me know if you have further inquiries.



2011 JanuaryPremium (if $750,000annual limit was

applied)EE






Roofers L96:000015



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//T|/...Local%20No.%2096%20Health%20and%20Welfare%20Fund/2nd%20Request%20for%20additional%20info%2011.18.10.htm[08/17/2011 10:18:

rom: Moultrie, Cam (HHS/OCIIO)ent: Thursday, November 18, 2010 11:44 AM

To: [email protected]: Habit, Sandra (HHS/OCIIO)

ubject: RE: Waiver Application for Roofer Local No. 96 Health and WelfareFundlease provide total contribution rates (employee + employer) for 2010, 2011 and 2011 (if $the $750,000 annual limit was

pplied).

am Lynne Moultrierogram Analyst



301) 492-4174

[email protected]

rom: [email protected] [mailto:[email protected]]ent: Wednesday, November 17, 2010 3:54 PMo: Moultrie, Cam (HHS/OCIIO); Peter M. Rosenec: Habit, Sandra (HHS/OCIIO); [email protected]

ubject: Re: Waiver Application for Roofer Local No. 96 Health and WelfareFund

Dear Cam, ly contribution rate is $ for the bargaining participants. The Non-Bargaining composite monthly rate i

ntact me if you have any further questions for me.

hanks,Mike Theirl




Mr. Rosene,


am Moultrie

am Lynne Moultrie

rogram Analyst



301) 492-4174

[email protected]

rom: Peter M. Rosene [mailto:[email protected]]ent: Tuesday, November 16, 2010 8:18 PM

Roofers L96:000016



17/109


o: Moultrie, Cam (HHS/OCIIO); [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]: RE: Waiver Application for Roofer Local No. 96 Health and Welfare Fund


ear Mr. Rosene:












Please confirm whether the plan has lifetime or annual limits on ambulatory, emergency,hospitalization, laboratory, pediatric, maternity/newborn, mental health/substance abuse,r tive/devices, preventive/wellness, or prescription benefits and identify the corresponding

li is plan never had annual limits for essential benefits. The major medical lifetime limit was$ which has been revoked with the first day of the plan year following September 23, 2010.

Pl irm whether the plan is in compliance with the interim final regulations relating to





words, we would like a chart that reflects the following information: This is a composite rate (familyonly) plan. No other elections have ever been permitted. The eligibility provisions for the plan are as


coverage:


Roofers L96:000017



18/109




will have the administrator confirm the existing contribution rate by a separate e-mail to you, as I am currentHawaii teaching at a conference. As we have no ability to increase employer contributions, the premium would rem

he same and benefits would have to be slashed in an amount equal to the cost of stop loss insurance. I hope thats responsive to your request; please let me know if you have further inquiries.




EE






Roofers L96:000018



19/109


Roofers L96:000019



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//T|/...o.%2096%20Health%20and%20Welfare%20Fund/2nd%20request%20for%20additional%20info%20response%2011.18.10.htm[08/17/2011 10:18

rom: [email protected]: Thursday, November 18, 2010 11:59 PM

To: Moultrie, Cam (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO); [email protected]; [email protected]

ubject: Re: Waiver Application for Roofer Local No. 96 Health andWelfareFundCam,

he contribution rates are technically percent employer paid. However the total package is collectively bargain

with the health and welfare contributi mount a component of the participant's fringe fund package. There are noealth and welfare contribution rates yet for 2011, or forward, as that will depend on the allocation determination toach individual fringe benefit. In short, is waiver is not granted, any available collectively bargained amounts tllocated in future years will likely all ( percent) be required to be allocated to the health and welfare fund to rehe damage/hardship of the immediate ination of the lifetime limit to the Fund, including likely money taken ohe participant/employees taxable wage and take home pay for the forseeable future.

lease contact me if you have any further questions. I have also cc'd Fund Counsel Pete Rosene in the event that heas any additional information to add to your inquiry.

incerely,Mike Theirl, CEBS


rom: "Moultrie, Cam (HHS/OCIIO)" Date: Thu, 18 Nov 2010 11:44:21 -0500To: [email protected]: Habit, Sandra (HHS/OCIIO)

ubject: RE: Waiver Application for Roofer Local No. 96 Health and WelfareFund

lease provide total contribution rates (employee + employer) for 2010, 2011 and 2011 (if $the $750,000 annual limit was

pplied).

am Lynne Moultrie

rogram Analyst



301) 492-4174

[email protected]

rom: [email protected] [mailto:[email protected]]ent: Wednesday, November 17, 2010 3:54 PM

o: Moultrie, Cam (HHS/OCIIO); Peter M. Rosenec: Habit, Sandra (HHS/OCIIO); [email protected]: Re: Waiver Application for Roofer Local No. 96 Health and WelfareFund

Dear Cam, rly contribution rate is $ for the bargaining participants. The Non-Bargaining composite monthly rate i

ontact me if you have any further questions for me.

hanks,Mike Theirl

Roofers L96:000020



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Please confirm whether the plan has lifetime or annual limits on ambulatory, emergency,hospitalization, laboratory, pediatric, maternity/newborn, mental health/substance abuse,r tive/devices, preventive/wellness, or prescription benefits and identify the correspondingli is plan never had annual limits for essential benefits. The major medical lifetime limit was$ which has been revoked with the first day of the plan year following September 23, 2010.









coverage:




Any combination of the above may be used to continue eligibility.

Roofers L96:000022



23/109






EE






Roofers L96:000023



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//T|/...0Local%20No.%2096%20Health%20and%20Welfare%20Fund/3rd%20reqeust%20for%20additional%20info%2011.19.10.htm[08/17/2011 10:18:

rom: Moultrie, Cam (HHS/OCIIO)ent: Friday, November 19, 2010 11:01 AM

To: [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]

ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFundan you provide COBRA equivalency rates?

am Lynne Moultrie

ffice of Consumer Information and Insurance Oversight.S. Department of Health and Human Services

301) 492-4174

[email protected]

rom: [email protected] [mailto:[email protected]]ent: Thursday, November 18, 2010 11:59 PMo: Moultrie, Cam (HHS/OCIIO)c: Habit, Sandra (HHS/OCIIO); [email protected]; [email protected]: Re: Waiver Application for Roofer Local No. 96 Health andWelfareFund

Cam,

he contribution rates are technically percent employer paid. However the total package is collectively bargainwith the health and welfare contributi mount a component of the participant's fringe fund package. There are noealth and welfare contribution rates yet for 2011, or forward, as that will depend on the allocation determination toach individual fringe benefit. In short, is waiver is not granted, any available collectively bargained amounts tllocated in future years will likely all ( percent) be required to be allocated to the health and welfare fund to rehe damage/hardship of the immediate e ination of the lifetime limit to the Fund, including likely money taken ohe participant/employees taxable wage and take home pay for the forseeable future.







pplied).

am Lynne Moultrie

rogram Analyst



301) 492-4174

[email protected] L96:000024



25/109


rom: [email protected] [mailto:[email protected]]ent: Wednesday, November 17, 2010 3:54 PMo: Moultrie, Cam (HHS/OCIIO); Peter M. Rosenec: Habit, Sandra (HHS/OCIIO); [email protected]: Re: Waiver Application for Roofer Local No. 96 Health and WelfareFund


. ontact me if you have any further questions for me.hanks,

Mike Theirl




Mr. Rosene,


am Moultrie

am Lynne Moultrie

rogram Analyst



301) 492-4174

[email protected]



ear Mr. Rosene:


711. In order to complete your application, please provide the following information:Roofers L96:000025



26/109


27/109




2010 JanuaryPremium (current

level)


2011 JanuaryPremium (if $750,000

annual limit wasapplied)

EE



Family (if applicableor other appropriate

tier)



Roofers L96:000027



28/109

//T|/...96%20Health%20and%20Welfare%20Fund/3rd%20request%20for%20additional%20info%20correspondence%2011.19.10.htm[08/17/2011 10:18

rom: Peter M. Rosene [[email protected]]ent: Friday, November 19, 2010 11:24 AM

To: Moultrie, Cam (HHS/OCIIO); [email protected]: Habit, Sandra (HHS/OCIIO)

ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFundwill immediately forward this to our actuary; the problem we have is that the benefit schedule will need to be slashed

ramatically if we do not get the waiver. That is because we will have no additional source of employer funding due to th

BA, and if we deduct the money from the workers wage package, we will lose our grandfathered status. Therefore, slash

medical benefits for participants is the only way that we can balance the budget. The COBRA equivalency is difficult to knot this juncture, because we have not started slashing benefits before knowing if we will get the waiver.

will see if the actuary can give any other thoughts,

hanks,

ete Rosene

eneral Counsel

rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Friday, November 19, 2010 10:01 AMo: [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFund

an you provide COBRA equivalency rates?

am Lynne Moultrie



301) 492-4174

[email protected]


Cam,

he contribution rates are technically percent employer paid. However the total package is collectively bargain

with the health and welfare contributi mount a component of the participant's fringe fund package. There are noealth and welfare contribution rates yet for 2011, or forward, as that will depend on the allocation determination toach individual fringe benefit. In short, is waiver is not granted, any available collectively bargained amounts tllocated in future years will likely all ( percent) be required to be allocated to the health and welfare fund to rehe damage/hardship of the immediate ination of the lifetime limit to the Fund, including likely money taken ohe participant/employees taxable wage and take home pay for the forseeable future.


incerely,

Roofers L96:000028



29/109


Mike Theirl, CEBS





pplied).

am Lynne Moultrie

rogram Analyst



301) 492-4174

[email protected]




hanks,Mike Theirl




Mr. Rosene,


am Moultrie

am Lynne Moultrie

rogram Analyst



Roofers L96:000029



30/109


301) 492-4174

[email protected]



ear Mr. Rosene:












Please confirm whether the plan has lifetime or annual limits on ambulatory, emergency, hospitalizatlaboratory, pediatric, maternity/newborn, mental health/substance abuse, ative/devices,preventive/wellness, or prescription benefits and identify the correspondi . This plan never annual limits for essential benefits. The major medical lifetime limit was $ , which has beenrevoked with the first day of the plan year following September 23, 2010.









coverage:

Roofers L96:000030



31/109








EEEE + Child (ifapplicable or otherappropriate tier)



Roofers L96:000031



32/109




Roofers L96:000032



33/109

//T|/...ELLOW]/Roofers%20Local%20No.%2096%20Health%20and%20Welfare%20Fund/Additional%20response%2011.19.10.htm[08/17/2011 10:18:

rom: Peter M. Rosene [[email protected]]ent: Friday, November 19, 2010 8:22 AM

To: [email protected]; Moultrie, Cam (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO)

ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFundam,

dditionally, the trustees will need to reject contributions that come from employee wages if the amounts would cause a

f grandfathered status for the plan. In the end, only severe benefits cuts are available to this plan if it is to maintainrandfathered status.

eter Rosene

eneral Counsel


Cam,

he contribution rates are technically percent employer paid. However the total package is collectively bargainwith the health and welfare contributi mount a component of the participant's fringe fund package. There are noealth and welfare contribution rates yet for 2011, or forward, as that will depend on the allocation determination toach individual fringe benefit. In short, is waiver is not granted, any available collectively bargained amounts tllocated in future years will likely all ( percent) be required to be allocated to the health and welfare fund to rehe damage/hardship of the immediate ination of the lifetime limit to the Fund, including likely money taken ohe participant/employees taxable wage and take home pay for the forseeable future.







pplied).

am Lynne Moultrie

rogram Analyst



301) 492-4174Roofers L96:000033



34/109


[email protected]


Dear Cam,

ly contribution rate is $ for the bargaining participants. The Non-Bargaining composite monthly rate i

ontact me if you have any further questions for me.hanks,

Mike Theirl


rom: "Moultrie, Cam (HHS/OCIIO)" Date: Wed, 17 Nov 2010 13:59:07 -0500To: Peter M. Rosene; [email protected]

Cc: Habit, Sandra (HHS/OCIIO); [email protected]: RE: Waiver Application for Roofer Local No. 96 Health and Welfare Fund

Mr. Rosene,


am Moultrie

am Lynne Moultrie

rogram Analyst



301) 492-4174

[email protected]



ear Mr. Rosene:

hank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act SectionRoofers L96:000034



35/109












Please confirm whether the plan has lifetime or annual limits on ambulatory, emergency, hospitalizatlaboratory, pediatric, maternity/newborn, mental health/substance abuse, tative/devices,preventive/wellness, or prescription benefits and identify the correspondi . This plan never annual limits for essential benefits. The major medical lifetime limit was $ , which has beenrevoked with the first day of the plan year following September 23, 2010.









coverage:



Roofers L96:000035



36/109




2010 January

Premium (currentlevel)

2011 January

Premium (renewal)

2011 January

Premium (if $750,000annual limit wasapplied)

EE



Family (if applicable

or other appropriatetier)



Roofers L96:000036



37/109

//T|/...YELLOW]/Roofers%20Local%20No.%2096%20Health%20and%20Welfare%20Fund/Request%20for%20info%2012.2.10.htm[08/17/2011 10:18

rom: Moultrie, Cam (HHS/OCIIO)ent: Thursday, December 02, 2010 7:13 PM

To: Peter M. Rosene; [email protected]: Habit, Sandra (HHS/OCIIO)

ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFundi,

ave you received a response from your actuary?

lease note that we cannot process your application until we have received all of the necessary information. You will rece

decision within 30 days of when we receive all of the requested information. We look forward to receiving your comple

pplication.

am Lynne Moultrie



301) 492-4174

[email protected]

INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:

his information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribu

copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.

rom: Peter M. Rosene [mailto:[email protected]]ent: Friday, November 19, 2010 11:24 AMo: Moultrie, Cam (HHS/OCIIO); [email protected]

c: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFund

will immediately forward this to our actuary; the problem we have is that the benefit schedule will need to be slashed



medical benefits for participants is the only way that we can balance the budget. The COBRA equivalency is difficult to kno

t this juncture, because we have not started slashing benefits before knowing if we will get the waiver.


hanks,

ete Rosene

eneral Counsel


Roofers L96:000037



38/109



am Lynne Moultrie



301) 492-4174

[email protected]


Cam,

he contribution rates are technically percent employer paid. However the total package is collectively bargainwith the health and welfare contributi mount a component of the participant's fringe fund package. There are noealth and welfare contribution rates yet for 2011, or forward, as that will depend on the allocation determination to

ach individual fringe benefit. In short, if this waiver is not granted, any available collectively bargained amounts tollocated in future years will likely all ( percent) be required to be allocated to the health and welfare fund to rehe damage/hardship of the immediate e ination of the lifetime limit to the Fund, including likely money taken ohe participant/employees taxable wage and take home pay for the forseeable future.







pplied).

am Lynne Moultrierogram Analyst



301) 492-4174

[email protected]

rom: [email protected] [mailto:[email protected]]ent: Wednesday, November 17, 2010 3:54 PMo: Moultrie, Cam (HHS/OCIIO); Peter M. Rosene

Roofers L96:000038



39/109


c: Habit, Sandra (HHS/OCIIO); [email protected]: Re: Waiver Application for Roofer Local No. 96 Health and WelfareFund



hanks,Mike Theirl




Mr. Rosene,


am Moultrie

am Lynne Moultrie

rogram Analyst



301) 492-4174

[email protected]


rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Tuesday, November 16, 2010 4:06 PMo: [email protected]; [email protected]

c: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application for Roofer Local No. 96 Health and Welfare Fund

ear Mr. Rosene:





Roofers L96:000039



40/109









Please confirm whether the plan has lifetime or annual limits on ambulatory, emergency,hospitalization, laboratory, pediatric, maternity/newborn, mental health/substance abuse,r ive/devices, preventive/wellness, or prescription benefits and identify the correspondingli is plan never had annual limits for essential benefits. The major medical lifetime limit was$ which has been revoked with the first day of the plan year following September 23, 2010.









coverage:



Continuing Eligibility - Collective Bargained EmployeesRoofers L96:000040



41/109


42/109


43/109

//T|/...oofers%20Local%20No.%2096%20Health%20and%20Welfare%20Fund/Request%20for%20info%20response%2012.7.10.htm[08/17/2011 10:18:




rom: Peter M. Rosene [mailto:[email protected]]ent: Friday, November 19, 2010 11:24 AM

o: Moultrie, Cam (HHS/OCIIO); [email protected]: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFund

will immediately forward this to our actuary; the problem we have is that the benefit schedule will need to be slashed



medical benefits for participants is the only way that we can balance the budget. The COBRA equivalency is difficult to kno

t this juncture, because we have not started slashing benefits before knowing if we will get the waiver.


hanks,

ete Rosene

eneral Counsel



am Lynne Moultrie



301) 492-4174

[email protected]

rom: [email protected] [mailto:[email protected]]ent: Thursday, November 18, 2010 11:59 PM

o: Moultrie, Cam (HHS/OCIIO)c: Habit, Sandra (HHS/OCIIO); [email protected]; [email protected]: Re: Waiver Application for Roofer Local No. 96 Health andWelfareFund

Cam,

he contribution rates are technically percent employer paid. However the total package is collectively bargainwith the health and welfare contributi mount a component of the participant's fringe fund package. There are noealth and welfare contribution rates yet for 2011, or forward, as that will depend on the allocation determination toach individual fringe benefit. In short, is waiver is not granted, any available collectively bargained amounts tllocated in future years will likely all ( percent) be required to be allocated to the health and welfare fund to re

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he damage/hardship of the immediate elimination of the lifetime limit to the Fund, including likely money taken ofhe participant/employees taxable wage and take home pay for the forseeable future.







pplied).

am Lynne Moultrie

rogram Analyst



301) 492-4174

[email protected]

rom: [email protected] [mailto:[email protected]]ent: Wednesday, November 17, 2010 3:54 PMo: Moultrie, Cam (HHS/OCIIO); Peter M. Rosene

c: Habit, Sandra (HHS/OCIIO); [email protected]: Re: Waiver Application for Roofer Local No. 96 Health and WelfareFund



hanks,Mike Theirl




Mr. Rosene,


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coverage:









EE


Roofers L96:000046



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appropriate tier)





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//T|/...ELLOW]/Roofers%20Local%20No.%2096%20Health%20and%20Welfare%20Fund/Request%20for%20info%2012.13.10.htm[08/17/2011 10:18:

rom: Moultrie, Cam (HHS/OCIIO)ent: Monday, December 13, 2010 3:00 PM

To: Peter M. Rosene; [email protected]; 'Helmer, Michael'Cc: Habit, Sandra (HHS/OCIIO)

ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFundappreciate the information, but what I am looking for is either 1) the average contributions per employee (per month), o

he COBRA equivalency rates. Please use the following table as a guide:

2010 JanuaryContributions/Premium(current level)

2011 JanuaryContribution/Premium(renewal)

2011 JanuaryContribution/Premium(if $750,000 annuallimit was applied)

EE




hank you for your attention to this matter.

am

am Lynne Moultrie



301) 492-4174

[email protected]




rom: Peter M. Rosene [mailto:[email protected]]ent: Tuesday, December 07, 2010 4:13 PMo: Moultrie, Cam (HHS/OCIIO); [email protected]; 'Helmer, Michael'c: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFund

Dear Cam,

hank you for your patience. I am providing information from our actuary that I think gets to the heart of wou are looking for; before that, please recall for this Taft-Hartley Multi-Employer Plan, that the employer

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ontributions are constrained by the collective bargaining agreements that were in effect on September 23010. Because of this, no further employer contributions would be available. Any increased costs mustither come by virtue of benefit reductions or from the workers pay as additional co-insurance for premiumither scenario assures loss of Grandfathered Status.

Our Actuary, Mr. Michael Helmer, E.A., from the Segal Company provided the following:

f the Fund doe get the waiver the ave to cut benefits. If the Fund cuts benefits it'll lose GF stat

which will cost $ equates to $ PMPM which se pretty harsh for a group of employees thurrently contrib $ per hour to That's an extra hours a month of employment to pay fohe additional cost br t about by ACA in an economic en ment that sees shedding eligibility becauhe lack of work won't sustain the hours necessary to pro he current membership coverage. The botne is that we're asking for a waiver from the additional $ PMPM for a group of relatively low wagemployees.

Please let me know if you need anything further.

Peter RoseneGeneral Counsel

rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Thursday, December 02, 2010 6:13 PMo: Peter M. Rosene; [email protected]: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFund

i,



decision within 30 days of when we receive all of the requested information. We look forward to receiving your comple

pplication.

am Lynne Moultrie



301) 492-4174

[email protected]




rom: Peter M. Rosene [mailto:[email protected]]ent: Friday, November 19, 2010 11:24 AMo: Moultrie, Cam (HHS/OCIIO); [email protected]

Roofers L96:000049



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51/109





pplied).

am Lynne Moultrie

rogram Analyst



301) 492-4174

[email protected]

rom: [email protected] [mailto:[email protected]]ent: Wednesday, November 17, 2010 3:54 PM

o: Moultrie, Cam (HHS/OCIIO); Peter M. Rosenec: Habit, Sandra (HHS/OCIIO); [email protected]: Re: Waiver Application for Roofer Local No. 96 Health and WelfareFund



hanks,Mike Theirl




Mr. Rosene,


am Moultrie

am Lynne Moultrie

rogram Analyst



301) 492-4174

[email protected]

Roofers L96:000051



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ear Mr. Rosene:




may not have any lifetime limit on your plan, except in the case of non-essential benefits that arepermitted under Federal or State law. Effective September 23, 2010, you may no longer have a lifetim







Please confirm whether the plan has lifetime or annual limits on ambulatory, emergency,

h ation, laboratory, pediatric, maternity/newborn, mental health/substance abuse,r tive/devices, preventive/wellness, or prescription benefits and identify the correspondingli is plan never had annual limits for essential benefits. The major medical lifetime limit was$ which has been revoked with the first day of the plan year following September 23, 2010.









coverage:


Roofers L96:000052



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EE


appropriate tier)




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Roofers L96:000054



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//T|/...ofers%20Local%20No.%2096%20Health%20and%20Welfare%20Fund/Request%20for%20info%20response%2012.14.10.htm[08/17/2011 10:18:

rom: Helmer, Michael [[email protected]]ent: Tuesday, December 14, 2010 11:00 AM

To: Moultrie, Cam (HHS/OCIIO); 'Peter M. Rosene'; '[email protected]'Cc: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFund

Per Month 2010 JanuaryContributions/Premium(current level)


2011 JanuaryContribution/Premium(if $750,000 annual

Composite

Good morning Cam -Above are projected COBRA rates as follows:

Current rate $ Projected 2011 COBRA rate under current plan designProjected 2011 COBRA rate without Waiver approval $

Currently the COBRA rates are developed using a composite strategy where everyone pay sa tegardless of single, 2 party or family status or age. The increase shown above from the $ to $

ncludes the purchase of stoploss to account for the added risk to the plan should the plan be a eor the Waiver.

you need any additional information, please let me know.

hank you

Michael Helmer EA, MAAA

rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Monday, December 13, 2010 2:00 PMo: Peter M. Rosene; [email protected]; Helmer, Michaelc: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFund

appreciate the information, but what I am looking for is either 1) the average contributions per employee (per month), o

he COBRA equivalency rates. Please use the following table as a guide:

2010 JanuaryContributions/Premium(current level)


2011 JanuaryContribution/Premium(if $750,000 annual

limit was applied)EE




Roofers L96:000055



56/109


hank you for your attention to this matter.

am

am Lynne Moultrie


.S. Department of Health and Human Services301) 492-4174

[email protected]




rom: Peter M. Rosene [mailto:[email protected]]ent: Tuesday, December 07, 2010 4:13 PMo: Moultrie, Cam (HHS/OCIIO); [email protected]; 'Helmer, Michael'c: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFund

Dear Cam,

hank you for your patience. I am providing information from our actuary that I think gets to the heart of wou are looking for; before that, please recall for this Taft-Hartley Multi-Employer Plan, that the employerontributions are constrained by the collective bargaining agreements that were in effect on September 23010. Because of this, no further employer contributions would be available. Any increased costs mustither come by virtue of benefit reductions or from the workers pay as additional co-insurance for premiumither scenario assures loss of Grandfathered Status.

Our Actuary, Mr. Michael Helmer, E.A., from the Segal Company provided the following:

f the Fund doe get the waiver the ave to cut benefits. If the Fund cuts benefits it'll lose GF statwhich will cost $ equates to $ PMPM which se pretty harsh for a group of employees thurrently contrib $ per hour to H&W. That's an extra hours a month of employment to pay fohe additional cost brought about by ACA in an economic environment that sees shedding eligibility becau

he lack of work won't sustain the hours necessary to provide the current membership coverage. The botne is that we're asking for a waiver from the additional $ PMPM for a group of relatively low wagemployees.

Please let me know if you need anything further.

Peter RoseneGeneral Counsel

Roofers L96:000056



57/109


rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Thursday, December 02, 2010 6:13 PMo: Peter M. Rosene; [email protected]: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Roofer Local No. 96 Health andWelfareFund

i,



decision within 30 days of when we receive all of the requested information. We look forw

Roofers Local 96 - Redacted Bates HWM

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