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Pages 5 through 62 redacted for the following reasons:- - - - - - - - - - - - - - - - - - - - - - - - - - - -Exemption 4

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//T|/...0%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Request%20for%20additional%20info%2011.15.10.htm[07/13/2011 1:40:

rom: Moultrie, Cam (HHS/OCIIO)ent: Monday, November 15, 2010 8:29 PM

To: Habit, Sandra (HHS/OCIIO)ubject: FW: Waiver Application for United Crafts Benefits Fund

rom: Moultrie, Cam (HHS/OCIIO)ent: Monday, November 15, 2010 8:11 PM

o: '[email protected]'ubject: Waiver Application for United Crafts Benefits Fund

ear Mr. Roslokken:

hank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section 2711. In order to

omplete your application, please provide the following information:

In your application, your plan(s) or policy(ies) provide a lifetime limit. According to the regulation, you may not hav

any lifetime limit on your plan, except in the case of non-essential benefits that are permitted under Federal or Stat

law. Effective September 23, 2010, you may no longer have a lifetime limit on your plan or policy. Plans that previo

had a lifetime limit may add an annual limit not less than the lifetime limit without affecting the grandfather status the plan.

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

plans.

Please confirm whether the premium rates you supplied for the plan or policy forms are on a monthly or annual bas

Please provide the current monthly premium rates and the projected monthly premium rates applicable to the plan

policy forms if the plan were to comply with the restricted annual benefits. In other words, we would like a chart th

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)

EE + Spouse (if

applicable or otherappropriate tier)

Family (if applicable or

other appropriate tier)

n order to complete your application, please provide this information by 5:00 pm, November 16, 2010. We look forward t

eceiving your completed application. Thank you.

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am L. Moultrie

rogram Analyst

ffice of Consumer Information and Insurance Oversight

.S. Department of Health and Human Services

301) 492-4174

[email protected]

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//T|/...sponse%20[YELLOW]/United%20Crafts%20Benefits%20Fund/2nd%20Request%20for%20additional%20info%2011.17.10.htm[07/13/2011 1:40

rom: Moultrie, Cam (HHS/OCIIO)ent: Wednesday, November 17, 2010 12:55 PM

To: Roslokken, DanCc: [email protected]; [email protected]; Minetti, Russ; [email protected]; Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for United Crafts Benefits Fund

Mr. Roslokken,

hank you for your response. Can you provide COBRA equivalencies to estimate the cost of premiums for employees,

mployee + spouse, and employee+family?

hanks again.

am Moultrie

am Lynne Moultrie

rogram Analyst



301) [email protected]

rom: Roslokken, Dan [mailto:[email protected]]ent: Tuesday, November 16, 2010 4:50 PMo: Moultrie, Cam (HHS/OCIIO)c: [email protected]; [email protected]; Minetti, Russ; [email protected]: RE: Waiver Application for United Crafts Benefits Fund

ear Mr. Moultrie,

n behalf of the United Crafts Benefits Fund ("UCBF"), I thank you for your office's careful review of the 2711 waiver application

nd correspondence. Received last night at 8:11pm, the correspondence seeks a reply by 5 pm, today. In a spirit of cooperationesponsiveness, we provide the following:

Regarding lifetime maximums: Both IDA and the applicant UCBF are aware that annual limits can no longer be emplo

and shall not be employed.

Regarding interim regulation compliance: Based upon personal inquiry and belief, combined with IDA's administrati

of the self funded health benefit plan sponsored through the UCBF, all interim regulations concerning grandfathered statuare being maintained and are in full compliance therewith.

Clarifying the issue of "premium rates":

Please be advised that the health benefits plan sponsored through the UCBF is on a 100% self funded basis. That

to the extent a medical claim is adjudicated as eligible and payable, the cost thereof is 100% directly funded throuthe UCBF. Nineteen separate employer groups contribute monies to fund the health benefits plan. There is noinsurance carrier. Therefore there is no "premium", per se.

Role of excess loss coverage.

A common aspect of self funded health plans is that, in order to hedge against catastrophic claim costs, ex

loss coverage can be purchased. Typically, the health plan retains the financial risk of claims upto a particuamount per individual (otherwise called the "specific retention"), over which amount the excess loss coveraresponsible for payment.

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Due to the limited benefit provided by the UCBF, there had been no role or prior use of excess loss coverag

Within the 2711 Waiver application, to approximate the cost of excess loss coverage that would cover the

differential between the UCBF's current fiscal exposure and the restricted annual amount of $750,000.00,excess loss quotations for coverage were obtained.

The "premium" is for excess loss coverage ONLY. It is not for the total plan cost.

The annualized premium for excess loss coverage is between $ and $

Requested chart materials:

Because there is no insured premium for the UCBF, the requested data set(s) cannot be provided as requested.

Further, because the rates for each of the nineteen underlying employer groups are collectively bargained by each

employer and union local, the contribution rates vary for each of the nineteen underlying employers. Thus, there isblended or universal rate for EE, EE + child, EE + Spouse, and/or Family.

Nevertheless, to supplement the waiver submission and further demonstrate the expense of complying with the

$750,000 restricted annual limit to the UCBF, please consider the following:

For the calendar year 2009, the total medical claims cost of the UCBF (excluding life insurance, dental bene

optical and prescription) was $

For the first 10 months of cale 2010, total medical claims cost of the UCBF (excluding life insuranc

dental benefits, optical and prescription benefits) are $ Annualized, this will be $ calendar year 2010.

If the UCBF was to comply with the restricted annual limit of $750,000, excess loss coverage would have to

purchased.

As previously represented (with the quote being submitted in the initial waiver application), the cost

the excess loss coverage would range between $ to $ (USD).

The additional expense of the excess loss covera projected 2011 calendar year UCBF p

costs would be between $ and $ (i.e., current plan costs PLUS excess losscoverage premium).

This additional cost of compliance means an increase between % to %.

This cost increase is unprecedented in the history of the UCBF.

This cost increase cannot be passed onto the nineteen participating employer groups as their

contribution rates were established by union contracting and the collective bargaining process.

As a result of all of the foregoing, if the waiver is not granted, the cost increase will be handled in one of two wa

100% passed on to participating enrollees, which is:

Unprecedented, and;

Potentially barred by the terms of the underlying collective bargaining agreements, thereby implicati

state and federal labor law(s), and;

Even if passing the expenses to enrollees is permitted, the cost thereof is likely to provoke massive

disenrollment.

Inasmuch that the UCBF is NOT the originator or guarantor of funding (and the ability to collect additional

funding from employer groups or the enrollees themselves is likely barred by collective bargaining agreemeterms), the UCBF would no choice but to consider closing the health benefit fund, dis-enrolling all enrollees

We are thankful for this opportunity to respond to your Office's request for additional information. Had the UCBF been a fully insan, the information requested within the chart could have been provided. However, for the reasons described in detail within

esponse, there is no ready analog to the requested data sets. If there is any need for further information, discussion or clarificae stand ready to provide your Office with our undivided attention and access.

espectfully, and on behalf of the UCBF,

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aniel W. Roslokkenanaging Director and General Counsel

DA69 Ramapo Valley Roadakland, New Jersey [email protected]

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

ent: Monday, November 15, 2010 8:11 PMo: Roslokken, Danubject: Waiver Application for United Crafts Benefits Fund

ear Mr. Roslokken:





law. Effective September 23, 2010, you may no longer have a lifetime limit on your plan or policy. Plans that previohad a lifetime limit may add an annual limit not less than the lifetime limit without affecting the grandfather status

the plan.


plans.



policy forms if the plan were to comply with the restricted annual benefits. In other words, we would like a chart threflects the following information:


(current level)


(renewal)


(if $750,000 annual

limit was applied)

EE



tier)

EE + Spouse (ifapplicable or other

appropriate tier)





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mailto:[email protected]:[email protected]


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am L. Moultrie

rogram Analyst



301) 492-4174

[email protected]

Confidentiality and Circular 230 NoticesMPORTANT: If this communication contains statements concerning taxation, those statements are provided for

nformation purposes only, are not intended to constitute tax advice which may be relied upon to avoid penalties

nder any federal, state, local or other tax statutes or regulations, and do not resolve any tax issues in your fav

pon request, we can provide you with express written tax advice after necessary factual development and sub

o such conditions and qualifications as we may deem appropriate in the circumstances.

his electronic mail message and any attached files contain information intended for the exclusive use of the pa

r parties to whom it is addressed and may contain information that is proprietary, privileged, confidential and/o

xempt from disclosure under applicable law. If you are not an intended recipient, you are hereby notified that a

iewing, copying, disclosure or distribution of this information may be subject to legal restriction or sanction. Pleotify the sender, by electronic mail or telephone, of any unintended recipients and delete the original message

without making any copies.

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rom: Roslokken, Dan [[email protected]]ent: Wednesday, November 17, 2010 4:55 PM

To: Moultrie, Cam (HHS/OCIIO)Cc: [email protected]; [email protected]; Minetti, Russ; [email protected]; Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for United Crafts Benefits Fund

Mr. Moultrie,

We are in receipt of your Office's request to provide a COBRA equivalency rate in order to gauge the cost of compliance versus current rate

We appreciate the inquiry and utility of such a measurement.

owever, because the UCBF is comprised of nineteen different contributing employers, there are nineteen different COBRA rates (range of

to $ /month). Thus, this approach may be so cumbersome as to be impractical.

evertheless, we understand and appreciate the practicality for the OCIIO to have a consistent measurement among waiver applicants as t

rojected increase if the plan were comply with the $750,000 annualized cap.

an attempt to provide some measurement of a premium equivalence, we provide the following exercise as an illustrative aid to the OCII

The current annualized plan cost for 2010 is $ Divided among enrollees equals $ per enrollee (annually)

figure is illustrative only inasmuch that it does NOT account for differentials in EE, EE + child, EE + spouse, or family coverage. Nor d

this figure account or represent the actual contribution rates of the underlying employer groups or of enrollees.

In comparison, the projected 2011 calendar year UCBF plan costs will be between $ and $ (i.e., current pla

costs PLUS excess loss coverage premium). Divided among enrollees, this produces a range of $ to $ per enr

Utilizing the 2010 per-enrollee measurement of $ , the projected 2011 costs per enrollee ($ to $ ), represen

a % to a % increase.

This increase can be considered to represent the per enrollee cost of complying with the $750,000.00 annual limit under PPACA.

Because such increases cannot be passed onto the employer groups (because their contribution rates were set by collective bargain

agreements), and the fact that the UCBF is neither the originator nor guarantor of funding, the totality of funding would fall entirely

upon enrollees, likely causing massive disenrollment.

It is due to these consequences that UCBF seeks a waiver of the annual limit restrictions under section 2711.

espectfully, and on behalf of the UCBF,an

aniel W. Roslokken

eneral Counsel and Managing Director

DA

69 Ramapo Valley Road

akland, New Jersey 07436

01.337.0007, x260

[email protected]

rom: Moultrie, Cam (HHS/OCIIO) [[email protected]]ent: Wednesday, November 17, 2010 12:55 PM

o: Roslokken, Danc: [email protected]; [email protected]; Minetti, Russ; [email protected]; Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for United Crafts Benefits Fund

Mr. Roslokken,



hanks again.

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15/50


am Moultrie

am Lynne Moultrie

rogram Analyst



301) 492-4174

[email protected]


ear Mr. Moultrie,

n behalf of the United Crafts Benefits Fund ("UCBF"), I thank you for your office's careful review of the 2711 waiver applicationnd correspondence. Received last night at 8:11pm, the correspondence seeks a reply by 5 pm, today. In a spirit of cooperationesponsiveness, we provide the following:

Regarding lifetime maximums: Both IDA and the applicant UCBF are aware that lifetime limits can no longer be empl












differential between the UCBF's current fiscal exposure and the restricted annual amount of $750,000.00,

excess loss quotations for coverage were obtained.


The annualized premium for excess loss coverage is between $ and $ (USD





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For the first 10 months of calendar year 2010, total medical claims cost of the UCBF (excluding life insuranc



purchased.



The additional expense of the excess loss covera e projected 2011 calendar year UCBF p








Unprecedented, and;




disenrollment.








rom: Moultrie, Cam (HHS/OCIIO) [[email protected]]ent: Monday, November 15, 2010 8:11 PMo: Roslokken, Danubject: Waiver Application for United Crafts Benefits Fund

ear Mr. Roslokken:

UCrafts:000016


17/50







had a lifetime limit may add an annual limit not less than the lifetime limit without affecting the grandfather status

the plan.


plans.





2010 January Premium(current level)

2011 January Premium(renewal)

2011 January Premium(if $750,000 annual

limit was applied)

EE



tier)

EE + Spouse (if

applicable or other

appropriate tier)

Family (if applicable orother appropriate tier)



am L. Moultrie

rogram Analystffice of Consumer Information and Insurance Oversight


301) 492-4174

[email protected]



UCrafts:000017


18/50








iewing, copying, disclosure or distribution of this information may be subject to legal restriction or sanction. Ple

otify the sender, by electronic mail or telephone, of any unintended recipients and delete the original message


UCrafts:000018


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//T|/...YELLOW]/United%20Crafts%20Benefits%20Fund/2nd%20request%20for%20additional%20info%20response%2011.18.10.htm[07/13/2011 1:40

rom: Moultrie, Cam (HHS/OCIIO)ent: Thursday, November 18, 2010 4:21 PM

To: Habit, Sandra (HHS/OCIIO)ubject: FW: Waiver Application for United Crafts Benefits Fund

am Lynne Moultrie


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

[email protected]

rom: Moultrie, Cam (HHS/OCIIO)ent: Thursday, November 18, 2010 4:19 PMo: 'Roslokken, Dan'ubject: RE: Waiver Application for United Crafts Benefits Fund

What is the projected 2011 cost per enrollee if UCBF is granted a waiver from the ACA annual limit reguirement?

am Lynne Moultrieffice of Consumer Information and Insurance Oversight


301) 492-4174

[email protected]

rom: Roslokken, Dan [mailto:[email protected]]ent: Wednesday, November 17, 2010 4:55 PMo: Moultrie, Cam (HHS/OCIIO)c: [email protected]; [email protected]; Minetti, Russ; [email protected]; Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for United Crafts Benefits Fund

Mr. Moultrie,













Utilizing the 2010 per-enrollee measurement of $2,881.88, the projected 2011 costs per enrollee ($ to $ ), represen


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an

aniel W. Roslokken


DA



01.337.0007, x260

[email protected]


ent: Wednesday, November 17, 2010 12:55 PMo: Roslokken, Danc: [email protected]; [email protected]; Minetti, Russ; [email protected]; Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for United Crafts Benefits Fund

Mr. Roslokken,



hanks again.

am Moultrie

am Lynne Moultrie

rogram Analyst



301) 492-4174

[email protected]


ear Mr. Moultrie,



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to the extent a medical claim is adjudicated as eligible and payable, the cost thereof is 100% directly funded throu

the UCBF. Nineteen separate employer groups contribute monies to fund the health benefits plan. There is noinsurance carrier. Therefore there is no "premium", per se.

















For the first 10 months of calendar year 2010, total medical claims cost of the UCBF (excluding life insurancdental benefits, optical and prescription benefits) are $ Annualized, this will be $ calendar year 2010.


purchased.



The additional expense of the excess loss coverage, means the projected 2011 calendar year UCBF p




This cost increase cannot be passed onto the nineteen participating employer groups as theircontribution rates were established by union contracting and the collective bargaining process.



Unprecedented, and;




disenrollment.


funding from employer groups or the enrollees themselves is likely barred by collective bargaining agreemeUCrafts:000021


22/50


terms), the UCBF would no choice but to consider closing the health benefit fund, dis-enrolling all enrollees




aniel W. Roslokken

anaging Director and General CounselDA69 Ramapo Valley Roadakland, New Jersey [email protected]


ear Mr. Roslokken:







the plan.


plans.






(current level)


(renewal)


(if $750,000 annual

limit was applied)

EE



tier)

EE + Spouse (if

applicable or other

appropriate tier)

UCrafts:000022


23/50






am L. Moultrie

rogram Analyst



301) 492-4174

[email protected]

Confidentiality and Circular 230 Notices

MPORTANT: If this communication contains statements concerning taxation, those statements are provided fornformation purposes only, are not intended to constitute tax advice which may be relied upon to avoid penalties










UCrafts:000023


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//T|/...012600%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/2nd%20Request%20for%20info%2011.30.10.htm[07/13/2011 1:40

rom: Moultrie, Cam (HHS/OCIIO)ent: Tuesday, November 30, 2010 3:26 PM

To: Roslokken, DanCc: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for United Crafts Benefits Fund (11/23)an,

hank you for your responses. Can you provide the COBRA equivalency rates?

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: Roslokken, Dan [mailto:[email protected]]ent: Tuesday, November 23, 2010 5:19 PMo: Moultrie, Cam (HHS/OCIIO)c: [email protected]; [email protected]; [email protected]; Minetti, Russubject: RE: Waiver Application for United Crafts Benefits Fund (11/23)

r. Moultrie,

n receipt of your email, an explanation for the delay in response is appropriate. Last Thursday, I was hospitalized until yesterdaith a severe Deep Vein Thrombosis. Now discharged but working remotely, I attend to your office's inquiry.

our office seeks a per enrollee cost if the UCBF is granted a waiver. Once again, because there are nineteen different employeroups within the UCBF, there are nineteen different answers (contribution rates having been set by collective bargaininggreements). Thus, the answer requested is not simple to obtain.

owever, acknowledging the utility of a per enrollee cost with a waiver, we believe the question can be approached and addres the following manner:

Take the current annualized plan cost for 2010: $ .

Multiply the plan cost by % to account for expected medical trend, equals an expected 2011 medical spend of : $

Divided among enrollees equals $ per enrollee (annually).

n comparison, the projected 2011 calendar year UCBF plan costs per enrollee without a wai be between $ a (i.e., current plan costs PLUS excess loss coverage premium). Divided among enrollees, this n

$ per enrollee. This means in practical terms that denial of the waiv drive per enrollee costs upy % .

While we provide the above calculations for your office's consideration, we again caution that because each of the nineteen participating

mployer groups have different contribution arrangements set by collective bargaining agreements, that the above calculations may not

ecessarily typify actual experience. Also qualifying these calculations is that they do not account for differentials in EE, EE + child, EE + spo

r family coverage (the reason for both caveats having been set forth at length in the initial submission and subsequent email corresponden

UCrafts:000024


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We trust this information is responsive to your inquiry.


an

aniel W. Roslokken


DA



01.337.0007, x260

[email protected]

rom: Moultrie, Cam (HHS/OCIIO) [[email protected]]ent: Thursday, November 18, 2010 4:19 PMo: Roslokken, Danubject: RE: Waiver Application for United Crafts Benefits Fund


am Lynne Moultrieffice of Consumer Information and Insurance Oversight


301) 492-4174

[email protected]


Mr. Moultrie,








The current annualized plan cost for 2010 is $ . Divided among enrollees equals $ per enrollee (annually)




costs PLUS excess loss coverage premium). Divided among enrollees, this produces a range of $4,665.53 to $4,779.94 per enr

Utilizing the 2010 per-enrollee measurement of $ , the projected 2011 costs per enrollee ($ to $ ), represen



UCrafts:000025


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an

aniel W. Roslokken


DA



01.337.0007, x260

[email protected]

rom: Moultrie, Cam (HHS/OCIIO) [[email protected]]ent: Wednesday, November 17, 2010 12:55 PMo: Roslokken, Danc: [email protected]; [email protected]; Minetti, Russ; [email protected]; Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for United Crafts Benefits Fund

Mr. Roslokken,



hanks again.

am Moultrie

am Lynne Moultrie

rogram Analyst



301) 492-4174

[email protected]


ear Mr. Moultrie,





of the self funded health benefit plan sponsored through the UCBF, all interim regulations concerning grandfathered statu

UCrafts:000026


27/50


are being maintained and are in full compliance therewith.























purchased.As previously represented (with the quote being submitted in the initial waiver application), the cost


The additional expense of the excess loss coverage, means the pr alendar year UCBF p








Unprecedented, and;




disenrollment.




UCrafts:000027


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DA69 Ramapo Valley Roadakland, New Jersey 07436

[email protected]


ear Mr. Roslokken:







the plan.


plans.






(current level)


(renewal)


(if $750,000 annual

limit was applied)

EE



tier)

EE + Spouse (if

applicable or other

appropriate tier)



UCrafts:000028


29/50




am L. Moultrie

rogram Analyst

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

301) 492-4174

[email protected]












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rom: Roslokken, Dan [[email protected]]ent: Tuesday, November 30, 2010 4:35 PM

To: Moultrie, Cam (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO); [email protected]; Minetti, Russ; [email protected]: RE: Waiver Application for United Crafts Benefits Fund (11/30)am,

We wish to be responsive to the question and respectfully suggest that the COBRA question had been addressed on November

hat the question resurfaces has caused us to look anew on the issue. Perhaps the following clarification can be helpful to bothffices.

The UCBF is 100% self fu fore, there are no set premium rates as may exist in a fully insured context.The UCBF is comprised of different employer groups. Each of these employer groups has reached different terregarding health care ntribution rates.Of note, EACH of the employer groups provides health benefits to ACTIVE enrollees on a 100% basis, with noemployee contribution

Thus, in a technical sense, the current 2010 EE direct cost for health coverage is $0.00; If the waiver is granted fo2011, the EE direct cost for coverage should remain at $0.00.However, if the waiver is NOT granted, the EE coverage would have to encompass absorbing the coof the excess loss coverage (Apopproximately $ divided by enrollees = $ per enrollee cLiterally, EEs would go from zero contribution t enrollee.

In contrast, COBRA rates are primarily paid by qualified b iaries. Nevertheless, once again due to the diffe

collective bargaining agreements, some of the COBRA rates are subsidized by employers. This means there different COBRA rates. Because there are no universal COBRA rates, our email reply of November 17th and No 23rd can be said to represent the arithmetic mean of COBRA rates (i.e., total costs divided by all enrollees) to produce aCOBRA equivalency rate, with and without a waiver.

In summary:COBRA arithmetic mean with a waiver: $ COBRA arithmetic mean without a waive $ to $

We rely upon the original waiver, in addition to the email replies o ber 1 and 23rd in support of theseprojections.

n an attempt to bring this matter to satisfactory conclusion for both of our offices, I suggest a telelphone conversation to discusny remaining issues. I will reach out to your office this afternoon to seek an appropriate time for same. I look forward to speakith you.


an

aniel W. Roslokken


DA



01.337.0007, x260

[email protected]


ent: Tuesday, November 30, 2010 3:26 PMo: Roslokken, Danc: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for United Crafts Benefits Fund (11/23)

an,


am Lynne Moultrie


UCrafts:000030


31/50



301) 492-4174

[email protected]





r. Moultrie,


our office seeks a per enrollee cost if the UCBF is granted a waiver. Once again, because there are nineteen different employeroups within the UCBF, there are nineteen different answers (contribution rates having been set by collective bargaininggreements). Thus, the answer requested is not simple to obtain.


Take the current annualized plan cost for 2010: $



, the projected 2011 calendar year UCBF plan costs per enrollee without a waiver will be between $ a (i.e., current plan costs PLUS excess loss coverage premium). Divided among 2,017 enrollees, this no $ per enrollee. This means in practical terms that denial of the waiver will drive per enrollee costs up

y % .




r family coverage (the reason for both caveats having been set forth at length in the initial submission and subsequent email corresponden

We trust this information is responsive to your inquiry.


an

aniel W. Roslokken


DA



UCrafts:000031


32/50


01.337.0007, x260

[email protected]

rom: Moultrie, Cam (HHS/OCIIO) [[email protected]]ent: Thursday, November 18, 2010 4:19 PMo: Roslokken, Danubject: RE: Waiver Application for United Crafts Benefits Fund


am Lynne Moultrie



301) 492-4174

[email protected]


Mr. Moultrie,



owever, because the UCBF is comprised of nineteen different contributing employers, there are different COBRA rates (range of










Utilizing the 2010 per-enrollee measurement of $ the projected 2011 costs per enrollee ($ to $ ), represen








an

aniel W. Roslokken


UCrafts:000032


33/50


DA



01.337.0007, x260

[email protected]

rom: Moultrie, Cam (HHS/OCIIO) [[email protected]]ent: Wednesday, November 17, 2010 12:55 PMo: Roslokken, Danc: [email protected]; [email protected]; Minetti, Russ; [email protected]; Habit, Sandra (HHS/OCIIO)

ubject: RE: Waiver Application for United Crafts Benefits Fund

Mr. Roslokken,



hanks again.

am Moultrie

am Lynne Moultrie

rogram Analyst



301) 492-4174

[email protected]

rom: Roslokken, Dan [mailto:[email protected]]ent: Tuesday, November 16, 2010 4:50 PMo: Moultrie, Cam (HHS/OCIIO)

c: [email protected]; [email protected]; Minetti, Russ; [email protected]: RE: Waiver Application for United Crafts Benefits Fund

ear Mr. Moultrie,











loss coverage can be purchased. Typically, the health plan retains the financial risk of claims upto a particuamount per individual (otherwise called the "specific retention"), over which amount the excess loss covera

UCrafts:000033


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responsible for payment.

















purchased.



The additional expense of the excess loss covera e pr calendar year UCBF p








Unprecedented, and;




disenrollment.








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ear Mr. Roslokken:







the plan.


plans.






(current level)


(renewal)


(if $750,000 annual

limit was applied)

EE



tier)

EE + Spouse (if

applicable or other

appropriate tier)





am L. Moultrie

rogram Analyst


UCrafts:000035


36/50



301) 492-4174

[email protected]



nder any federal, state, local or other tax statutes or regulations, and do not resolve any tax issues in your favpon request, we can provide you with express written tax advice after necessary factual development and sub








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//T|/...O%2012600%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Additional%20info%20(2)%2011.30.10.htm[07/13/2011 1:40

rom: Roslokken, Dan [[email protected]]ent: Tuesday, November 30, 2010 5:55 PM

To: Moultrie, Cam (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO); [email protected]; Minetti, Russ; [email protected]: RE: Waiver Application for United Crafts Benefits Fund (11/30)am ,

ruly appreciative of the opportunity to speak with you this afternoon, I understand that the final figure which your Office seeks is the curr

010 equivalency rates. Keeping in mind the caveats previously expressed, namely that such equivalency rates represent an arthimetic mea

NLY, we provide the following:

Inasmuch that the Active coverage is 100% paid by employer contributions, the current 2010 EE active coverage rate is $0.00.

In contrast, the COBRA rate (annualized arithmetic mean) for 2010 is $ . We trust this information is responsive to your Off

request and need.

for any reason there are any remaining questions or concerns, please do not hesitate to contact me directly (201.337.0007, extension 260

as a pleasure to speak with you. Thank you for this opportunity to provide this information.


an

aniel W. Roslokken


DA



01.337.0007, x260

[email protected]

rom: Roslokken, Dan

ent: Tuesday, November 30, 2010 4:35 PMo: Moultrie, Cam (HHS/OCIIO)c: Habit, Sandra (HHS/OCIIO); [email protected]; Minetti, Russ; [email protected]: RE: Waiver Application for United Crafts Benefits Fund (11/30)

am,

We wish to be responsive to the question and respectfully suggest that the COBRA question had been addressed on November

hat the question resurfaces has caused us to look anew on the issue. Perhaps the following clarification can be helpful to bothffices.

The UCBF is 100% self fu fore, there are no set premium rates as may exist in a fully insured context.The UCBF is comprised of different employer groups. Each of these employer groups has reached different ter

regarding health care ben ntribution rates.Of note, EACH of the employer groups provides health benefits to ACTIVE enrollees on a 100% basis, with noemployee contribution

Thus, in a technical sense, the current 2010 EE direct cost for health coverage is $0.00; If the waiver is granted fo2011, the EE direct cost for coverage should remain at $0.00.However, if the waiver is NOT granted, the E for coverag ld have to encompass absorbing the coof the excess loss coverage (Approximately $ , divided by enrollees = $ per enrollee cosLiterally, EEs would go from zero contributio er enrollee.

In contrast, COBRA rates are primarily paid by qualified b iaries. Nevertheless, once again due to the diffecollective bargaining agreements, some of the COBRA rates are subsidized by employers. This means there eendifferent COBRA rates. Because there are no universal COBRA rates, our email reply of November 17th and November23rd can be said to represent the arithmetic mean of COBRA rates (i.e., total costs divided by all enrollees) to produce aCOBRA equivalency rate, with and without a waiver.

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In summary:COBRA arithmetic mean with a waiver: $ COBRA arithmetic mean without a waiver $ to $

We rely upon the original waiver, in addition to the email replies o ber 1 and 23rd in support of theseprojections.

n an attempt to bring this matter to satisfactory conclusion for both of our offices, I suggest a telelphone conversation to discusny remaining issues. I will reach out to your office this afternoon to seek an appropriate time for same. I look forward to speakith you.

espectfully, and on behalf of the UCBF,an

aniel W. Roslokken


DA



01.337.0007, x260

[email protected]

rom: Moultrie, Cam (HHS/OCIIO) [[email protected]]ent: Tuesday, November 30, 2010 3:26 PM

o: Roslokken, Danc: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for United Crafts Benefits Fund (11/23)

an,


am Lynne Moultrie



301) [email protected]





r. Moultrie,


our office seeks a per enrollee cost if the UCBF is granted a waiver. Once again, because there are different employe

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roups within the UCBF, there are different answers (contribution rates having been set by collective bargaininggreements). Thus, the answer requested is not simple to obtain.


Take the current annualized plan cost for 2010: $ .



the projected 2011 calendar year UCBF plan costs per enrollee without a wai be between $ a (i. t plan costs PLUS excess loss coverage premium). Divided among enrollees, this no $ per enrollee. This means in practical terms that denial of the waiv drive per enrollee costs up

y % .




r family coverage (the reason for both caveats having been

united crafts benefit - redacted bates hwm

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