southeastern pipetrades health & welfare - redacted bates hw

7/27/2019 Southeastern Pipetrades Health & Welfare - Redacted Bates HW

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//T|/...20NO%2012600%20Response%20[YELLOW]/Southeastern%20Pipetrades%20Health%20&%20Welfare%20Fund/Waiver.htm[08/09/2011 11:05:

rom: Donny Dowlen [[email protected]]ent: Tuesday, November 09, 2010 11:09 AM

To: HHS HealthInsurance (HHS)ubject: Waiver

Attachments: 119104.pdfncl osed i s document at i on f or t he Sout heast ern Pi pet r ades Heal t h and Wel f are Fund

onny Dowl enout her n Benef i t Admi ni st r at or s

001 Cal dwel l Dr i veoodl et t svi l l e, TN 37072

r i v a cy a n d Co n f i d e n t i a l it y N o t i c e : This message is being sent via secure SSL encryption to protect the privacy of our clients and to ensure

ompliance with HIPAA regulations. Furthermore, this message (including any attached or embedded documents) is intended for the exclusive a

onfidential use of the individual or entity to which it has been addressed, and unless otherwise expressly indicated, is confidential and privilege

formation of Southern Benefit Administrators, Inc. Any dissemination, distribution or copying of the enclosed material is prohibited. If you rece

is transmission in error, please notify us immediately by e-mail at [email protected], and delete the original message. Your cooper

appreciated.

SE Pipe:000001

Document obtained by CompleteColorado.com


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

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//T|/...LOW]/Southeastern%20Pipetrades%20Health%20&%20Welfare%20Fund/Request%20for%20Additional%20Information.htm[08/09/2011 11:06:

rom: Keels, Lisa (HHS/OCIIO)ent: Tuesday, November 23, 2010 5:15 PM

To: [email protected]: Habit, Sandra (HHS/OCIIO)ubject: Annual Limit Waiver Applications - Request for Additional Informationear Mr. Dowlen:

hank you for your applications for the Waiver of the Annual Limits Requirements of the PHS Act Section 2711. This emai

equest for additional information for the following applications:

1. Memphis Construction Benefit Fund

2. Atlanta Plumbers & Steamfitters Fringe Benefit Funds

3. South Central Laborers Health & Welfare Fund

4. Southeastern Pipetrades Health & Welfare Fund

5. Aerospace Contractors Trust

6. Southern Operators Health Fund

7. Sheet Metal Workers National Health Fund

8. Sheet Metal Workers Local No. 177 Health & Welfare Fund

9. Louisiana Electrical Health Fund

I. In order to complete your applications, please provide the following information for all applications mentioned

above:

In each application, you state that a certain number of eligible employees are covered. For each plan, please provid

the total number of individuals covered.

Some applications state that the plans are comprehensive. Please confirm whether each plan listed above is a

comprehensive or limited-benefit plan.

Some of the plans above include lifetime limits. Please confirm that you are removing both overall lifetime limits a

well as lifetime limits on essential health benefits in those plans.

Was each plan listed above in existence prior to March 23rd, 2010? If so, have the trustees elected to comply with the

grandfathering provisions?

For each plan, what was the date of the last collective bargaining agreement pursuant to which each plan was designe

For each plan listed above, please provide the current monthly premium rates and the projected monthly premium

rates applicable to the plan if the plan were to comply with the restricted annual benefits. In other words, we woulike a chart that reflects the following information:

2010 January Premium

(current level)


(renewal)


(if $750,000 annual

limit was applied)

EE

EE + Child (if applicable

or other appropriate

tier)

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//T|/...LOW]/Southeastern%20Pipetrades%20Health%20&%20Welfare%20Fund/Request%20for%20Additional%20Information.htm[08/09/2011 11:06:

EE + Spouse (if

applicable or other

appropriate tier)

Family (if applicable or

other appropriate tier)

II. Please provide additional information for the following plans:

1. Aerospace Contractors Trust: In your cover letter, you state that the annual limit is $ However, t

schedule of benefits states that the annual limit is $ Please confirm which annual limit is correct.

2. Sheet Metal Workers Local No. 177 Health & Welfare Fund: In your cover letter, you state that the plan ha

annual maximum of $ . However, the schedule of benefits does not seem to have an annual limit.

Rather, it seems as though the schedule of benefits has an annual limit of $ for hospitalization

benefits. Please clarify this information.

III. I will be in touch separately about Mid South Carpenters Regional Council Health and Welfare Fund.

n order to complete your applications, please provide this information as soon as possible. We look forward to receiving

ompleted applications.

hank you,

sa Keels

sa M. Keels, J.D.

.S. Department of Health & Human Services

ffice of Consumer Information and Insurance Oversightffice of Oversight

[email protected]

01-492-4168

.S. Please note that I will be out of the office for the rest of this week, but I will be available via email tomorrow

Wednesday) morning.

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//T|/...]/Southeastern%20Pipetrades%20Health%20&%20Welfare%20Fund/Request%20for%20Additional%20Information12.7..htm[08/09/2011 11:06:0

rom: Keels, Lisa (HHS/OCIIO)ent: Tuesday, December 07, 2010 12:04 PM

To: Keels, Lisa (HHS/OCIIO); [email protected]: Habit, Sandra (HHS/OCIIO)ubject: RE: Annual Limit Waiver Applications - Request for Additional Informationello again, Donny,

hank you for all your responses thus far. I have one more question for all the plans listed below (and the Mid South

arpenters Regional Council Health and Welfare Fund):

For each plan, what is the date on which the last collective bargaining agreement pursuant to which the plan was

negotiated will expire?

hank you again,

sa

rom: Keels, Lisa (HHS/OCIIO)

ent: Tuesday, November 23, 2010 5:15 PMo: '[email protected]'c: Habit, Sandra (HHS/OCIIO)ubject: Annual Limit Waiver Applications - Request for Additional Information

ear Mr. Dowlen:

hank you for your applications for the Waiver of the Annual Limits Requirements of the PHS Act Section 2711. This emai

equest for additional information for the following applications:

1. Memphis Construction Benefit Fund

2. Atlanta Plumbers & Steamfitters Fringe Benefit Funds

3. South Central Laborers Health & Welfare Fund

4. Southeastern Pipetrades Health & Welfare Fund

5. Aerospace Contractors Trust

6. Southern Operators Health Fund

7. Sheet Metal Workers National Health Fund

8. Sheet Metal Workers Local No. 177 Health & Welfare Fund

9. Louisiana Electrical Health Fund

I. In order to complete your applications, please provide the following information for all applications mentioned

above:

In each application, you state that a certain number of eligible employees are covered. For each plan, please provid

the total number of individuals covered.

Some applications state that the plans are comprehensive. Please confirm whether each plan listed above is a

comprehensive or limited-benefit plan.

Some of the plans above include lifetime limits. Please confirm that you are removing both overall lifetime limits a

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well as lifetime limits on essential health benefits in those plans.

Was each plan listed above in existence prior to March 23rd, 2010? If so, have the trustees elected to comply with the

grandfathering provisions?

For each plan, what was the date of the last collective bargaining agreement pursuant to which each plan was designe

For each plan listed above, please provide the current monthly premium rates and the projected monthly premium

rates applicable to the plan if the plan were to comply with the restricted annual benefits. In other words, we wou

like a chart that reflects the following information:


(current level)


(renewal)


(if $750,000 annual

limit was applied)

EE

EE + Child (if applicable

or other appropriate

tier)

EE + Spouse (if

applicable or other

appropriate tier)

Family (if applicable or

other appropriate tier)

II. Please provide additional information for the following plans:

1. Aerospace Contractors Trust: In your cover letter, you state that the annual limit is $ However, t

schedule of benefits states that the annual limit is $ . Please confirm which annual limit is correct.

2. Sheet Metal Workers Local No. 177 Health & Welfare Fund: In your cover letter, you state that the plan ha

annual maximum of $ However, the schedule of benefits does not seem to have an annual limit.

Rather, it seems as though the schedule of benefits has an annual limit of $ for hospitalization

benefits. Please clarify this information.

III. I will be in touch separately about Mid South Carpenters Regional Council Health and Welfare Fund.

n order to complete your applications, please provide this information as soon as possible. We look forward to receiving

ompleted applications.

hank you,

sa Keels

sa M. Keels, J.D.

.S. Department of Health & Human Services

ffice of Consumer Information and Insurance Oversight

ffice of Oversight

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[email protected]

01-492-4168

.S. Please note that I will be out of the office for the rest of this week, but I will be available via email tomorrow

Wednesday) morning.

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//T|/...LOW]/Southeastern%20Pipetrades%20Health%20&%20Welfare%20Fund/Requst%20for%20info%20response%2012.7.10.htm[08/09/2011 11:06

rom: Donny Dowlen [[email protected]]ent: Tuesday, December 07, 2010 3:10 PM

To: Keels, Lisa (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO)ubject: RE: Annual Limit Waiver Applications - Request for Additional Informationisa, note the responses below. Let me know if you need anything else.

e want to emphasize that complying with annual limits would significantly increase the cost the plan participants as noted below, and would significantly decrease access to benefits forhose currently covered. The eligibility rules of the plan would have to be revised in order

und the expected increase.

onny Dowlen

rom: Keels, Lisa (HHS/OCIIO) [mailto:[email protected]]ent: Tuesday, November 23, 2010 4:15 PMo: [email protected]: Habit, Sandra (HHS/OCIIO)ubject: Annual Limit Waiver Applications - Request for Additional Information

Dear Mr. Dowlen:

hank you for your applications for the Waiver of the Annual Limits Requirements of the PHS Act Section 2711. mail is a request for additional information for the following application:

Southeastern Pipetrades Health & Welfare Fund

In order to complete your applications, please provide the following information for all applicationsmentioned above:

You state that a certai ber of eligible employees are covered. Please provide the total number ofindividuals covered

Please confirm whether the plan listed above is a comprehensive or limited-benefit plan.ased on our conversation last week, the plan would be considered a limited benefit plan.

Please confirm that you are removing both overall the lifetime limit as well as lifetime limits on essential heabenefits.

e are removing the overall lifetime limit as well as the lifetime limits on essential benefit

Was the plan listed above in existence prior to March 23rd, 2010? If so, have the trustees elected to comply he grandfathering provisions?

he plan was in existence prior to March 23, 2010 and the trustees have elected to comply withhe grandfathering provisions.

What is the expiration date of the last collective bargaining agreement pursuant to which the plan was design

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//T|/...LOW]/Southeastern%20Pipetrades%20Health%20&%20Welfare%20Fund/Requst%20for%20info%20response%2012.7.10.htm[08/09/2011 11:06

ay, 2011

lease provide the current monthly premium rate and the projected monthly premium rate applicable to the plan if tlan were to comply with the restricted annua nefits.

1. The premium rate for 2011 is $ 2. The cost in 2011 in the absenc annual limits3. The cost in 2011 to comply with annual limits is

n order to complete your applications, please provide this information as soon as possible. We look forward toeceiving your completed applications.

hank you,isa Keels

isa M. Keels, J.D.U.S. Department of Health & Human ServicesOffice of Consumer Information and Insurance OversightOffice of Oversight

[email protected]

.S. Please note that I will be out of the office for the rest of this week, but I will be available via email tomorrowWednesday) morning.






appreciated.

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//T|/...nse%20[YELLOW]/Southeastern%20Pipetrades%20Health%20&%20Welfare%20Fund/Requst%20for%20info%2012.9.10.htm[08/09/2011 11:06

rom: Donny Dowlen [[email protected]]ent: Thursday, December 09, 2010 9:53 AM

To: Keels, Lisa (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO)ubject: FW: Annual Limit Waiver Applications - Request for Additional Informationisa, just so there is no misunderstanding, I want to document clarification concerning myesponses to your question below regarding premium and cost information. In #1 we are providihe premium expected for 2011. In #2, we are providing the estimated plan cost if it does notave to comply with the $750,000 annual limit. In #3, we are providing the estimated plan cosf it has to comply with the $750,000 annual limit. I know you understand this, but we want t

ake sure that others who review this application have the same understanding. Thank you.

onny Dowlen

rom: Donny Dowlen [mailto:[email protected]]ent: Tuesday, December 07, 2010 2:10 PMo: 'Keels, Lisa (HHS/OCIIO)'c: 'Habit, Sandra (HHS/OCIIO)'ubject: RE: Annual Limit Waiver Applications - Request for Additional Information

isa, note the responses below. Let me know if you need anything else.

e want to emphasize that complying with annual limits would significantly increase the cost t

he plan participants as noted below, and would significantly decrease access to benefits forhose currently covered. The eligibility rules of the plan would have to be revised in order und the expected increase.

onny Dowlen

rom: Keels, Lisa (HHS/OCIIO) [mailto:[email protected]]ent: Tuesday, November 23, 2010 4:15 PMo: [email protected]: Habit, Sandra (HHS/OCIIO)ubject: Annual Limit Waiver Applications - Request for Additional Information

Dear Mr. Dowlen:

hank you for your applications for the Waiver of the Annual Limits Requirements of the PHS Act Section 2711. mail is a request for additional information for the following application:

Southeastern Pipetrades Health & Welfare Fund

In order to complete your applications, please provide the following information for all applicationsmentioned above:

You state that a certain number of eligible employees are covered. Please provide the total number ofindividuals covered

Please confirm whether the plan listed above is a comprehensive or limited-benefit plan.ased on our conversation last week, the plan would be considered a limited benefit plan.

Please confirm that you are removing both overall the lifetime limit as well as lifetime limits on essential hea

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//T|/...nse%20[YELLOW]/Southeastern%20Pipetrades%20Health%20&%20Welfare%20Fund/Requst%20for%20info%2012.9.10.htm[08/09/2011 11:06

benefits.e are removing the overall lifetime limit as well as the lifetime limits on essential benefit

Was the plan listed above in existence prior to March 23rd, 2010? If so, have the trustees elected to comply he grandfathering provisions?

he plan was in existence prior to March 23, 2010 and the trustees have elected to comply withhe grandfathering provisions.

What is the expiration date of the last collective bargaining agreement pursuant to which the plan was design

ay, 2011

lease provide the current monthly premium rate and the projected monthly premium rate applicable to the plan if tlan were to comply with the restricted annu efits.

1. The premium rate for 2011 is2. The cost in 2011 in the absen annual limits3. The cost in 2011 to comply with annual limits is

n order to complete your applications, please provide this information as soon as possible. We look forward toeceiving your completed applications.

hank you,isa Keels

isa M. Keels, J.D.U.S. Department of Health & Human ServicesOffice of Consumer Information and Insurance OversightOffice of Oversight

[email protected]

.S. Please note that I will be out of the office for the rest of this week, but I will be available via email tomorrowWednesday) morning.



onfidential use of the individual or entity to which it has been addressed, and unless otherwise expressly indicated, is confidential and privilegeformation of Southern Benefit Administrators, Inc. Any dissemination, distribution or copying of the enclosed material is prohibited. If you rece


appreciated.

SE Pipe:000013



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//T|/...Response%20[YELLOW]/Southeastern%20Pipetrades%20Health%20&%20Welfare%20Fund/RE%20Waiver%2012.14.10.htm[08/09/2011 11:06

rom: Keels, Lisa (HHS/OCIIO)ent: Tuesday, December 14, 2010 3:09 PM

To: Donny DowlenCc: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiverhank you, Donny. I hope you have a happy holiday season as well!

ll the best,

sa

rom: Donny Dowlen [mailto:[email protected]]ent: Tuesday, December 14, 2010 1:00 PMo: Keels, Lisa (HHS/OCIIO)c: [email protected]: Waiver

isa, I just received approval on eight of the applications that you were reviewing for ourompany. I just want to thank you for your assistance in this process. I know you guys areuried in applications and we just want to thank you for the prompt and courteous service youave these applications. I hope you have a happy holiday season.

onny Dowlen

r i v a cy a n d Co n f i d e n t i a l i t y N o t i c e : This message is being sent via secure SSL encryption to protect the priv

f our clients and to ensure compliance with HIPAA regulations. Furthermore, this message (including any attac

r embedded documents) is intended for the exclusive and confidential use of the individual or entity to which

as been addressed, and unless otherwise expressly indicated, is confidential and privileged information of

outhern Benefit Administrators, Inc. Any dissemination, distribution or copying of the enclosed material is

rohibited. If you receive this transmission in error, please notify us immediately by e-mail at

[email protected], and delete the original message. Your cooperation is appreciated.

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//T|/...0%20Response%20[YELLOW]/Southeastern%20Pipetrades%20Health%20&%20Welfare%20Fund/Approval%2012.14.10.htm[08/09/2011 11:06

rom: Botwinick, Alexandra (HHS/OCIIO)ent: Tuesday, December 14, 2010 12:36 PM

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

mportance: High

ollow Up Flag: Follow up

lag Status: Red

Attachments: Updated Jan 1 Approval Letter .pdf

ood Afternoon,

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

ection 2711 for Southeastern Pipetrades Health & Welfare Fund. HHS has reviewed your application a

made its determination. Please see the attached letter.

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

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

incerely,

Alexandra Botwinick

ffice of Oversight

HHS/[email protected]

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mailto:[email protected]:[email protected]


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rom: Donny Dowlen [[email protected]]ent: Tuesday, December 14, 2010 1:04 PM

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

rom: Botwinick, Alexandra (HHS/OCIIO) [mailto:[email protected]]ent: Tuesday, December 14, 2010 11:36 AMo: '[email protected]'ubject: Waiver of the Annual Limits Requirements of PHS Act Section 2711mportance: High

ood Afternoon,

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

ection 2711 for Southeastern Pipetrades Health & Welfare Fund. HHS has reviewed your application a

made its determination. Please see the attached letter.

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

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

incerely,

Alexandra Botwinick

ffice of Oversight

HHS/[email protected]






appreciated.

mailto:[email protected]:[email protected]

southeastern pipetrades health & welfare - redacted bates hw

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