United Crafts Benefit - Redacted Bates HWM

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From: Moultrie, Cam (HHS/OCIIO) Sent: Monday, November 15, 2010 8:29 PM To: Habit, Sandra (HHS/OCIIO) Subject: FW: Waiver Application for United Crafts Benefits Fund

From: Moultrie, Cam (HHS/OCIIO) Sent: Monday, November 15, 2010 8:11 PM To: 'droslokken@uhy-us.com' Subject: Waiver Application for United Crafts Benefits Fund
EE + Child (if applicable or other appropriate tier) EE + Spouse (if applicable or other appropriate tier) Family (if applicable or other appropriate tier)
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Dear Mr. Roslokken: Thank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section 2711. 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, you 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 lifetime limit on your plan or policy. Plans that previously had a lifetime limit may add an annual limit not less than the lifetime limit without affecting the grandfather status of 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 basis. Please provide the current monthly premium rates and the projected monthly premium rates applicable 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 January Premium 2011 January Premium 2011 January Premium (current level) (renewal) (if $750,000 annual limit was applied)
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In order to complete your application, please provide this information by 5:00 pm, November 16, 2010. We look forward to receiving your completed application. Thank you.
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file:///T|/...0%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Request%20for%20additional%20info%2011.15.10.htm[07/13/2011 1:40:23 PM]
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Cam L. Moultrie Program Analyst Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov
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file:///T|/...0%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Request%20for%20additional%20info%2011.15.10.htm[07/13/2011 1:40:23 PM]
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From: Moultrie, Cam (HHS/OCIIO) Sent: Wednesday, November 17, 2010 12:55 PM To: Roslokken, Dan Cc: Marianne@uciw.org; tlim@idatpa.com; Minetti, Russ; lmoore@idatpa.com; Habit, Sandra (HHS/OCIIO) Subject: RE: Waiver Application for United Crafts Benefits Fund
Mr. Roslokken, Thank you for your response. Can you provide COBRA equivalencies to estimate the cost of premiums for employees, employee + spouse, and employee+family? Thanks again. Cam Moultrie Cam Lynne Moultrie Program Analyst Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov
Clarifying the issue of "premium rates": Please be advised that the health benefits plan sponsored through theUCBF is on a 100% self funded basis. That is, to the extent a medical claim is adjudicated as eligible and payable, the cost thereof is 100% directly funded through the UCBF. Nineteenseparate employer groups contribute monies to fund the health benefits plan. There is no insurance 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, excess loss coverage can be purchased. Typically, the health plan retains the financial risk ofclaimsupto a particular amount per individual (otherwise called the "specific retention"), over which amount the excess loss coverage is responsible for payment.
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file:///T|/...sponse%20[YELLOW]/United%20Crafts%20Benefits%20Fund/2nd%20Request%20for%20additional%20info%2011.17.10.htm[07/13/2011 1:40:24 PM]
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Regarding interim regulation compliance: Based upon personal inquiry and belief, combined withIDA's administration of the self funded health benefit plan sponsored through the UCBF, all interim regulations concerninggrandfathered status are being maintained and are in full compliance therewith.
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Regarding lifetime maximums: Both IDA and the applicantUCBF are aware that annual limits can no longer be employed and shall not be employed.
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Dear Mr. Moultrie, On behalf of the United Crafts Benefits Fund ("UCBF"), I thank you for your office's careful review of the 2711 waiver application and correspondence. Received last night at 8:11pm, the correspondence seeks a reply by 5 pm, today. In a spirit of cooperation and responsiveness, we provide the following:
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From: Roslokken, Dan [mailto:droslokken@uhy-us.com] Sent: Tuesday, November 16, 2010 4:50 PM To: Moultrie, Cam (HHS/OCIIO) Cc: Marianne@uciw.org; tlim@idatpa.com; Minetti, Russ; lmoore@idatpa.com Subject: RE: Waiver Application for United Crafts Benefits Fund
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Due to the limited benefit provided by the UCBF, there had been no role or prior use of excess loss coverage. Within the 2711 Waiver application,to approximate the cost of excess loss coverage that would cover the differential between theUCBF's current fiscal exposure and therestricted 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 $(b)(4) Requested chart materials: Because there is no insured premiumfor the UCBF, the requested data set(s) cannot be provided as requested. and $(b)(4) .
This cost increase is unprecedented in the history of the UCBF. This cost increase cannot be passed onto the nineteen participating employer groups as their contribution rates were established by union contracting and the collective bargaining process.
We are thankful for this opportunity to respond to your Office'srequest for additionalinformation.Had theUCBF been a fully insured plan, the information requested within the chart could have been provided. However, for the reasons described in detail within this response, there is no ready analog to the requested data sets. If there is any need for further information, discussion or clarification, we stand ready to provide your Office with our undivided attention andaccess. Respectfully, and on behalf of the UCBF,
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100% passed on to participating enrollees, which is: Unprecedented, and; Potentially barred by the terms of the underlying collective bargaining agreements, thereby implicating state and federal labor law(s), and; Even if passing the expenses to enrollees is permitted, the cost thereof is likely to provoke massive disenrollment.
Inasmuch that theUCBF is NOT the originator or guarantor of funding (and the ability to collect additional fundingfrom employer groups or the enrollees themselves is likelybarred by collective bargaining agreement terms), theUCBF would no choice butto consider closing the health benefit fund,dis-enrolling allenrollees.
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As a result of all of the foregoing, if the waiver is not granted, the cost increase will be handled in one of two ways:
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As previously represented (with the quote being submitted in the initial waiver application), the cost for the excess loss coverage would range between$(b)(4) (USD). to $(b)(4) The additional expense of the excess loss covera projected2011calendar yearUCBF plan costs would be between $(b)(4) and $(b)(4) (i.e., current plan costs PLUS excess loss coverage premium). This additional cost of compliance means an increase between (b)(4) % to (b)(4) %.
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For thecalendar year 2009, the total medical claims cost of theUCBF (excluding life insurance, dental benefits, (b)(4) optical and prescription) was $ For the first 10 months ofcale 2010, total medical claims cost of theUCBF (excluding life insurance, dental benefits, optical and prescription benefits) are $ (b)(4) Annualized, this will be $(b)(4) for calendar year 2010. If theUCBF was to comply with therestricted annual limit of $750,000, excess loss coverage would have to be purchased.
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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 is no blended 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:
Daniel W.Roslokken Managing Director and General Counsel IDA 169 Ramapo Valley Road Oakland, New Jersey 07436 201.337.0007 droslokken@uhy-us.com From: Moultrie, Cam (HHS/OCIIO) [Cam.Moultrie@hhs.gov] Sent: Monday, November 15, 2010 8:11 PM To: Roslokken, Dan Subject: Waiver Application for United Crafts Benefits Fund
Dear Mr. Roslokken: Thank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section 2711. 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, you 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 lifetime limit on your plan or policy. Plans that previously had a lifetime limit may add an annual limit not less than the lifetime limit without affecting the grandfather status of 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 basis. Please provide the current monthly premium rates and the projected monthly premium rates applicable 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 January Premium 2011 January Premium 2011 January Premium (renewal) (if $750,000 annual (current level) 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) In order to complete your application, please provide this information by 5:00 pm, November 16, 2010. We look forward to receiving your completed application. Thank you.
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Cam L. Moultrie Program Analyst Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov
Confidentiality and Circular 230 Notices
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IMPORTANT: If this communication contains statements concerning taxation, those statements are provided for information purposes only, are not intended to constitute tax advice which may be relied upon to avoid penalties under any federal, state, local or other tax statutes or regulations, and do not resolve any tax issues in your favor. Upon request, we can provide you with express written tax advice after necessary factual development and subject to such conditions and qualifications as we may deem appropriate in the circumstances. This electronic mail message and any attached files contain information intended for the exclusive use of the party or parties to whom it is addressed and may contain information that is proprietary, privileged, confidential and/or exempt from disclosure under applicable law. If you are not an intended recipient, you are hereby notified that any viewing, copying, disclosure or distribution of this information may be subject to legal restriction or sanction. Please notify the sender, by electronic mail or telephone, of any unintended recipients and delete the original message without making any copies .
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From: Roslokken, Dan [droslokken@uhy-us.com] Sent: Wednesday, November 17, 2010 4:55 PM To: Moultrie, Cam (HHS/OCIIO) Cc: Marianne@uciw.org; tlim@idatpa.com; Minetti, Russ; lmoore@idatpa.com; Habit, Sandra (HHS/OCIIO) Subject: 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 rates. We appreciate the inquiry and utility of such a measurement. However, because theUCBF is comprised of nineteen different contributing employers, there are nineteen different COBRA rates (range of $(b)(4) to $(b)(4) /month). Thus, this approach may be so cumbersome as to be impractical. Nevertheless, we understand and appreciatethe practicality for theOCIIO to have a consistent measurement among waiver applicants as to the projected increase if the plan were comply with the $750,000 annualized cap. In an attempt to provide some measurement of a premium equivalence, weprovide the following exercise as an illustrative aid to the OCIIO: The current annualized plan cost for 2010 is $(b)(4) Divided among (b)(4) enrollees equals $(b)(4) per enrollee (annually). This figure is illustrative only inasmuch that it does NOT account for differentials in EE,EE + child,EE + spouse, or familycoverage. Nor does this figureaccount or represent the actualcontribution rates of the underlying employer groups or of enrollees. In comparison, the projected2011calendar yearUCBF plan costs will be between $(b)(4) and $(b)(4) (i.e., current plan (b)(4) costs PLUS excess loss coverage premium). Divided among enrollees, this produces a range of $(b)(4) to $(b)(4) per enrollee. Utilizing the2010 per-enrollee measurement of $(b)(4) , the projected 2011 costs per enrollee($(b)(4) to $(b)(4) ), represent a(b)(4) % to a(b)(4) % 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 bargaining agreements), and the fact that theUCBF 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 theseconsequences thatUCBF seeks a waiver of the annual limit restrictions under section 2711.

Respectfully, and on behalf of the UCBF, Dan Daniel W.Roslokken General Counsel and Managing Director IDA 169 Ramapo Valley Road Oakland, New Jersey 07436 201.337.0007,x260 droslokken@uhy-us.com
From: Moultrie, Cam (HHS/OCIIO) [Cam.Moultrie@hhs.gov] Sent: Wednesday, November 17, 2010 12:55 PM To: Roslokken, Dan Cc: Marianne@uciw.org; tlim@idatpa.com; Minetti, Russ; lmoore@idatpa.com; Habit, Sandra (HHS/OCIIO) Subject: RE: Waiver Application for United Crafts Benefits Fund
Mr. Roslokken, Thank you for your response. Can you provide COBRA equivalencies to estimate the cost of premiums for employees, employee + spouse, and employee+family? Thanks again.
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file:///T|/...se%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Request%20for%20additional%20info%20response%2011.17.10.htm[07/13/2011 1:40:25 PM]
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Cam Moultrie Cam Lynne Moultrie Program Analyst Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov
Dear Mr. Moultrie,
Regarding lifetime maximums: Both IDA and the applicantUCBF are aware that lifetime limits can no longer be employed and shall not be employed.
Clarifying the issue of "premium rates":
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A common aspect of self funded health plans is that, in order to hedge against catastrophic claim costs, excess loss coverage can be purchased. Typically, the health plan retains the financial risk ofclaimsupto a particular amount per individual (otherwise called the "specific retention"), over which amount the excess loss coverage is responsible for payment. Due to the limited benefit provided by the UCBF, there had been no role or prior use of excess loss coverage.
Within the 2711 Waiver application,to approximate the cost of excess loss coverage that would cover the differential between theUCBF's current fiscal exposure and therestricted 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 $(b)(4) and $(b)(4) (USD).
Requested chart materials: Because there is no insured premiumfor 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 is no blended or universal rate for EE, EE + child, EE + Spouse, and/or Family.
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Please be advised that the health benefits plan sponsored through theUCBF is on a 100% self funded basis. That is, to the extent a medical claim is adjudicated as eligible and payable, the cost thereof is 100% directly funded through the UCBF. Nineteenseparate employer groups contribute monies to fund the health benefits plan. There is no insurance carrier. Therefore there is no "premium", per se. Role of excess loss coverage.
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On behalf of the United Crafts Benefits Fund ("UCBF"), I thank you for your office's careful review of the 2711 waiver application and correspondence. Received last night at 8:11pm, the correspondence seeks a reply by 5 pm, today. In a spirit of cooperation and responsiveness, we provide the following:
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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 thecalendar year 2009, the total medical claims cost of theUCBF (excluding life insurance, dental benefits, optical and prescription) was $(b)(4) For the first 10 months ofcalendar year 2010, total medical claims cost of theUCBF (excluding life insurance, dental benefits, optical and prescription benefits) are $(b)(4) Annualized, this will be $(b)(4) for calendar year 2010. If theUCBF was to comply with therestricted annual limit of $750,000, excess loss coverage would have to be purchased. As previously represented (with the quote being submitted in the initial waiver application), the cost for to $(b)(4) the excess loss coverage would range between$(b)(4) (USD). The additional expense of the excess loss covera e projected2011calendar yearUCBF plan costs would be between $(b)(4) and $(b)(4) (i.e., current plan costs PLUS excess loss coverage premium). (b)(4) This additional cost of compliance means an increase between % to (b)(4) %. 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 ways: 100% passed on to participating enrollees, which is: Unprecedented, and;
Daniel W.Roslokken Managing Director and General Counsel IDA 169 Ramapo Valley Road Oakland, New Jersey 07436 201.337.0007 droslokken@uhy-us.com
From: Moultrie, Cam (HHS/OCIIO) [Cam.Moultrie@hhs.gov] Sent: Monday, November 15, 2010 8:11 PM To: Roslokken, Dan Subject: Waiver Application for United Crafts Benefits Fund
Dear Mr. Roslokken:

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Respectfully, and on behalf of the UCBF,
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We are thankful for this opportunity to respond to your Office'srequest for additionalinformation.Had theUCBF been a fully insured plan, the information requested within the chart could have been provided. However, for the reasons described in detail within this response, there is no ready analog to the requested data sets. If there is any need for further information, discussion or clarification, we stand ready to provide your Office with our undivided attention andaccess.
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Inasmuch that theUCBF is NOT the originator or guarantor of funding (and the ability to collect additional fundingfrom employer groups or the enrollees themselves is likelybarred by collective bargaining agreement terms), theUCBF would no choice butto consider closing the health benefit fund,dis-enrolling allenrollees.
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Potentially barred by the terms of the underlying collective bargaining agreements, thereby implicating 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.
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Thank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section 2711. 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, you 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 lifetime limit on your plan or policy. Plans that previously had a lifetime limit may add an annual limit not less than the lifetime limit without affecting the grandfather status of 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 basis. Please provide the current monthly premium rates and the projected monthly premium rates applicable 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 January Premium 2011 January Premium 2011 January Premium (renewal) (if $750,000 annual (current level) 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) In order to complete your application, please provide this information by 5:00 pm, November 16, 2010. We look forward to receiving your completed application. Thank you. Cam L. Moultrie Program Analyst Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov
IMPORTANT: If this communication contains statements concerning taxation, those statements are provided for information purposes only, are not intended to constitute tax advice which may be relied upon to avoid penalties
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under any federal, state, local or other tax statutes or regulations, and do not resolve any tax issues in your favor. Upon request, we can provide you with express written tax advice after necessary factual development and subject to such conditions and qualifications as we may deem appropriate in the circumstances. This electronic mail message and any attached files contain information intended for the exclusive use of the party or parties to whom it is addressed and may contain information that is proprietary, privileged, confidential and/or exempt from disclosure under applicable law. If you are not an intended recipient, you are hereby notified that any viewing, copying, disclosure or distribution of this information may be subject to legal restriction or sanction. Please notify the sender, by electronic mail or telephone, of any unintended recipients and delete the original message without making any copies .
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From: Moultrie, Cam (HHS/OCIIO) Sent: Thursday, November 18, 2010 4:21 PM To: Habit, Sandra (HHS/OCIIO) Subject: FW: Waiver Application for United Crafts Benefits Fund
Cam Lynne Moultrie Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov
From: Moultrie, Cam (HHS/OCIIO) Sent: Thursday, November 18, 2010 4:19 PM To: 'Roslokken, Dan' Subject: 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 rates. We appreciate the inquiry and utility of such a measurement. However, because theUCBF is comprised of nineteen different contributing employers, there are nineteen different COBRA rates (range of $(b)(4) to $(b)(4) /month). Thus, this approach may be so cumbersome as to be impractical. Nevertheless, we understand and appreciatethe practicality for theOCIIO to have a consistent measurement among waiver applicants as to the projected increase if the plan were comply with the $750,000 annualized cap. In an attempt to provide some measurement of a premium equivalence, weprovide the following exercise as an illustrative aid to the OCIIO: The current annualized plan cost for 2010 is $(b)(4) Divided among (b)(4) enrollees equals $(b)(4) per enrollee (annually). This figure is illustrative only inasmuch that it does NOT account for differentials in EE,EE + child,EE + spouse, or familycoverage. Nor does this figureaccount or represent the actualcontribution rates of the underlying employer groups or of enrollees. In comparison, the projected2011calendar yearUCBF plan costs will be between $(b)(4) and $(b)(4) costs PLUS excess loss coverage premium). Divided among (b)(4) enrollees, this produces a range of $(b)(4) Utilizing the2010 per-enrollee measurement of $2,881.88, the projected 2011 costs per enrollee($(b)(4) a(b)(4) % to a(b)(4) % increase. (i.e., current plan to $ per enrollee.
(b)(4)
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From: Roslokken, Dan [mailto:droslokken@uhy-us.com] Sent: Wednesday, November 17, 2010 4:55 PM To: Moultrie, Cam (HHS/OCIIO) Cc: Marianne@uciw.org; tlim@idatpa.com; Minetti, Russ; lmoore@idatpa.com; Habit, Sandra (HHS/OCIIO) Subject: RE: Waiver Application for United Crafts Benefits Fund
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What is the projected 2011 cost per enrollee if UCBF is granted a waiver from the ACA annual limit reguirement? Cam Lynne Moultrie Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov
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to $(b)(4)
), represent
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file:///T|/...YELLOW]/United%20Crafts%20Benefits%20Fund/2nd%20request%20for%20additional%20info%20response%2011.18.10.htm[07/13/2011 1:40:26 PM]
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 bargaining agreements), and the fact that theUCBF 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 theseconsequences thatUCBF seeks a waiver of the annual limit restrictions under section 2711.

Dear Mr. Moultrie,
On behalf of the United Crafts Benefits Fund ("UCBF"), I thank you for your office's careful review of the 2711 waiver application and correspondence. Received last night at 8:11pm, the correspondence seeks a reply by 5 pm, today. In a spirit of cooperation and responsiveness, we provide the following: Regarding lifetime maximums: Both IDA and the applicantUCBF are aware that lifetime limits can no longer be employed
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and shall not be employed.
Clarifying the issue of "premium rates": Please be advised that the health benefits plan sponsored through theUCBF is on a 100% self funded basis. That is, to the extent a medical claim is adjudicated as eligible and payable, the cost thereof is 100% directly funded through the UCBF. Nineteenseparate employer groups contribute monies to fund the health benefits plan. There is no insurance 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, excess loss coverage can be purchased. Typically, the health plan retains the financial risk ofclaimsupto a particular amount per individual (otherwise called the "specific retention"), over which amount the excess loss coverage is responsible for payment. Due to the limited benefit provided by the UCBF, there had been no role or prior use of excess loss coverage. Within the 2711 Waiver application,to approximate the cost of excess loss coverage that would cover the differential between theUCBF's current fiscal exposure and therestricted 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 $(b)(4)
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and $(b)(4)
(USD).
Requested chart materials:
Because there is no insured premiumfor 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 is no blended 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 thecalendar year 2009, the total medical claims cost of theUCBF (excluding life insurance, dental benefits, optical and prescription) was $(b)(4) For the first 10 months ofcalendar year 2010, total medical claims cost of theUCBF (excluding life insurance, dental benefits, optical and prescription benefits) are $(b)(4) Annualized, this will be $(b)(4) for calendar year 2010. If theUCBF was to comply with therestricted annual limit of $750,000, excess loss coverage would have to be purchased. As previously represented (with the quote being submitted in the initial waiver application), the cost for the excess loss coverage would range between$(b)(4) (USD). to $(b)(4) The additional expense of the excess loss coverage,means the projected2011calendar yearUCBF plan costs would be between $(b)(4) and $(b)(4) (i.e., current plan costs PLUS excess loss coverage premium). This additional cost of compliance means an increase between (b)(4) % to (b)(4) %. 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 ways: 100% passed on to participating enrollees, which is: Unprecedented, and; Potentially barred by the terms of the underlying collective bargaining agreements, thereby implicating 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 theUCBF is NOT the originator or guarantor of funding (and the ability to collect additional fundingfrom employer groups or the enrollees themselves is likelybarred by collective bargaining agreement
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This cost increase is unprecedented in the history of the UCBF.
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terms), theUCBF would no choice butto consider closing the health benefit fund,dis-enrolling allenrollees.
Respectfully, and on behalf of the UCBF, Daniel W.Roslokken Managing Director and General Counsel IDA 169 Ramapo Valley Road Oakland, New Jersey 07436 201.337.0007 droslokken@uhy-us.com
Dear Mr. Roslokken: Thank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section 2711. 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, you 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 lifetime limit on your plan or policy. Plans that previously had a lifetime limit may add an annual limit not less than the lifetime limit without affecting the grandfather status of 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 basis. Please provide the current monthly premium rates and the projected monthly premium rates applicable 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 January Premium 2011 January Premium 2011 January Premium (renewal) (if $750,000 annual (current level) limit was applied) EE EE + Child (if applicable or other appropriate tier) EE + Spouse (if applicable or other appropriate tier)
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Family (if applicable or other appropriate tier)
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In order to complete your application, please provide this information by 5:00 pm, November 16, 2010. We look forward to receiving your completed application. Thank you. Cam L. Moultrie Program Analyst Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov
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From: Moultrie, Cam (HHS/OCIIO) Sent: Tuesday, November 30, 2010 3:26 PM To: Roslokken, Dan Cc: Habit, Sandra (HHS/OCIIO) Subject: RE: Waiver Application for United Crafts Benefits Fund (11/23)
Dan, Thank you for your responses. Can you provide the COBRA equivalency rates? Cam Lynne Moultrie Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW: This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
Multiply the plan cost by Divided among (b)(4)
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Mr. Moultrie, Inreceipt of your email, an explanation for the delay in response is appropriate. Last Thursday, I was hospitalized until yesterday with a severe Deep Vein Thrombosis. Now discharged but working remotely, I attend to your office's inquiry. Your office seeks a per enrollee cost if theUCBF is granted a waiver. Once again, because there are nineteen different employer groups within the UCBF, there are nineteen different answers (contribution rates having been set by collective bargaining agreements). Thus, the answer requested is not simple to obtain. However, acknowledging the utility of a per enrollee cost with a waiver, we believe the question can be approached and addressed in the following manner: Take the current annualized plan cost for 2010: $(b)(4) . % to account for expected medical trend, equals an expected 2011 medical spend of : $(b)(4) per enrollee (annually). enrollees equals$(b)(4)
In comparison, the projected2011calendar yearUCBF plan costs per enrollee without a wai be between $(b)(4) and (b)(4) (b)(4) $ (i.e., current plan costs PLUS excess loss coverage premium). Divided among enrollees, this nge o (b)(4) $(b)(4) per enrollee. This means in practical terms that denial of the waiv drive per enrollee costs up by %. While we provide the above calculations for your office's consideration, we again caution that because each of the nineteen participating employer groupshave different contribution arrangements set by collective bargaining agreements, that the above calculations may not necessarily typify actual experience. Also qualifying these calculations is thatthey do not account for differentials in EE,EE + child,EE + spouse, or familycoverage (the reason for both caveats having been set forth at length in the initial submission and subsequent email correspondence).
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file:///T|/...012600%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/2nd%20Request%20for%20info%2011.30.10.htm[07/13/2011 1:40:27 PM]
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From: Roslokken, Dan [mailto:droslokken@uhy-us.com] Sent: Tuesday, November 23, 2010 5:19 PM To: Moultrie, Cam (HHS/OCIIO) Cc: Marianne@uciw.org; tlim@idatpa.com; lmoore@idatpa.com; Minetti, Russ Subject: RE: Waiver Application for United Crafts Benefits Fund (11/23)
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We trust this information is responsive toyour inquiry.
Respectfully, and on behalf of the UCBF, Dan Daniel W.Roslokken General Counsel and Managing Director IDA 169 Ramapo Valley Road Oakland, New Jersey 07436 201.337.0007,x260 droslokken@uhy-us.com From: Moultrie, Cam (HHS/OCIIO) [Cam.Moultrie@hhs.gov] Sent: Thursday, November 18, 2010 4:19 PM To: Roslokken, Dan Subject: RE: Waiver Application for United Crafts Benefits Fund
Mr. Moultrie,
However, because theUCBF is comprised of nineteen different contributing employers, there are nineteen different COBRA rates (range of $(b)(4) to $ (b)(4) /month). Thus, this approach may be so cumbersome as to be impractical.
Nevertheless, we understand and appreciatethe practicality for theOCIIO to have a consistent measurement among waiver applicants as to the projected increase if the plan were comply with the $750,000 annualized cap.
In an attempt to provide some measurement of a premium equivalence, weprovide the following exercise as an illustrative aid to the OCIIO: The current annualized plan cost for 2010 is $(b)(4) . Divided among (b)(4) enrollees equals $(b)(4) per enrollee (annually). This figure is illustrative only inasmuch that it does NOT account for differentials in EE,EE + child,EE + spouse, or familycoverage. Nor does this figureaccount or represent the actualcontribution rates of the underlying employer groups or of enrollees. In comparison, the projected2011calendar yearUCBF plan costs will be between $(b)(4) and $(b)(4) (i.e., current plan (b)(4) costs PLUS excess loss coverage premium). Divided among enrollees, this produces a range of $4,665.53 to $4,779.94 per enrollee. Utilizing the2010 per-enrollee measurement of $(b)(4) , the projected 2011 costs per enrollee($(b)(4) to $(b)(4) ), represent (b)(4) (b)(4) 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.
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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 rates. We appreciate the inquiry and utility of such a measurement.
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Because such increases cannot be passed onto the employer groups (because their contribution rates were set by collective bargaining agreements), and the fact that theUCBF 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 theseconsequences thatUCBF seeks a waiver of the annual limit restrictions under section 2711.

Dear Mr. Moultrie, On behalf of the United Crafts Benefits Fund ("UCBF"), I thank you for your office's careful review of the 2711 waiver application and correspondence. Received last night at 8:11pm, the correspondence seeks a reply by 5 pm, today. In a spirit of cooperation and responsiveness, we provide the following: Regarding lifetime maximums: Both IDA and the applicantUCBF are aware that lifetime limits can no longer be employed and shall not be employed.
Regarding interim regulation compliance: Based upon personal inquiry and belief, combined withIDA's administration of the self funded health benefit plan sponsored through the UCBF, all interim regulations concerninggrandfathered status
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are being maintained and are in full compliance therewith.
Clarifying the issue of "premium rates": Please be advised that the health benefits plan sponsored through theUCBF is on a 100% self funded basis. That is, to the extent a medical claim is adjudicated as eligible and payable, the cost thereof is 100% directly funded through the UCBF. Nineteenseparate employer groups contribute monies to fund the health benefits plan. There is no insurance 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, excess loss coverage can be purchased. Typically, the health plan retains the financial risk ofclaimsupto a particular amount per individual (otherwise called the "specific retention"), over which amount the excess loss coverage is responsible for payment. Due to the limited benefit provided by the UCBF, there had been no role or prior use of excess loss coverage.
The annualized premium for excess loss coverage is between $(b)(4)
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Within the 2711 Waiver application,to approximate the cost of excess loss coverage that would cover the differential between theUCBF's current fiscal exposure and therestricted 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. and $(b)(4) (USD).
Because there is no insured premiumfor 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 is no blended 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 thecalendar year 2009, the total medical claims cost of theUCBF (excluding life insurance, dental benefits, optical and prescription) was $(b)(4) For the first 10 months ofcalendar year 2010, total medical claims cost of theUCBF (excluding life insurance, dental benefits, optical and prescription benefits) are $(b)(4) Annualized, this will be $(b)(4) for calendar year 2010. If theUCBF was to comply with therestricted annual limit of $750,000, excess loss coverage would have to be purchased. As previously represented (with the quote being submitted in the initial waiver application), the cost for the excess loss coverage would range between$(b)(4) (USD). to $(b)(4) The additional expense of the excess loss coverage,means the pr alendar yearUCBF plan costs would be between $(b)(4) and $(b)(4) (i.e., current plan costs PLUS excess loss coverage premium). This additional cost of compliance means an increase between (b)(4) % to (b)(4) %. 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 ways: 100% passed on to participating enrollees, which is: Unprecedented, and; Potentially barred by the terms of the underlying collective bargaining agreements, thereby implicating 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 theUCBF is NOT the originator or guarantor of funding (and the ability to collect additional fundingfrom employer groups or the enrollees themselves is likelybarred by collective bargaining agreement terms), theUCBF would no choice butto consider closing the health benefit fund,dis-enrolling allenrollees.
We are thankful for this opportunity to respond to your Office'srequest for additionalinformation.Had theUCBF been a fully insured plan, the information requested within the chart could have been provided. However, for the reasons described in detail within this
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response, there is no ready analog to the requested data sets. If there is any need for further information, discussion or clarification, we stand ready to provide your Office with our undivided attention andaccess.
Dear Mr. Roslokken: Thank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section 2711. 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, you 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 lifetime limit on your plan or policy. Plans that previously had a lifetime limit may add an annual limit not less than the lifetime limit without affecting the grandfather status of 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 basis. Please provide the current monthly premium rates and the projected monthly premium rates applicable 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 January Premium 2011 January Premium 2011 January Premium (renewal) (if $750,000 annual (current level) 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)
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From: Roslokken, Dan [droslokken@uhy-us.com] Sent: Tuesday, November 30, 2010 4:35 PM To: Moultrie, Cam (HHS/OCIIO) Cc: Habit, Sandra (HHS/OCIIO); Marianne@uciw.org; Minetti, Russ; tlim@idatpa.com Subject: RE: Waiver Application for United Crafts Benefits Fund (11/30)
Cam, We wish to be responsive to the question and respectfully suggest thatthe COBRA question had been addressed on November 17th. That the question resurfaces has caused us to look anew on the issue. Perhaps the following clarification can be helpful to both our offices. 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 (b)(4) different employer groups. Each of these employer groups has reached different terms regarding health care ntribution rates. Of note, EACH of the (b)(4) employer groups provides health benefits to ACTIVE enrollees on a 100% basis, with no employee contribution Thus, in a technical sense, the current 2010 EE direct cost for health coverage is $0.00; If the waiver is granted for 2011, 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 cost of the excess loss coverage (Apopproximately $(b)(4) divided by (b)(4) enrollees = $(b)(4) per enrollee cost). Literally, EEs would go from zero contribution t (b)(4) enrollee. In contrast, COBRA rates are primarily paid by qualified b iaries. Nevertheless, once again due to the (b)(4) different (b)(4) 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 23rdcan be said to represent thearithmetic mean of COBRA rates (i.e., total costs divided by all enrollees) to produce a COBRA equivalency rate, with and without a waiver. Insummary: COBRA arithmetic mean with a waiver: $(b)(4) COBRA arithmetic mean without a waive $(b)(4) to $(b)(4) We rely upon the original waiver,in addition to the email replies o ber 1 and23rd in support of these projections. In an attempt to bring this matter to satisfactory conclusion for both of our offices, I suggest a telelphone conversation to discuss any remaining issues. I will reach out to your office this afternoon to seek an appropriate time for same. I look forward to speaking with you. Respectfully, and on behalf of the UCBF, Dan Daniel W.Roslokken General Counsel and Managing Director IDA 169 Ramapo Valley Road Oakland, New Jersey 07436 201.337.0007,x260 droslokken@uhy-us.com From: Moultrie, Cam (HHS/OCIIO) [Cam.Moultrie@hhs.gov] Sent: Tuesday, November 30, 2010 3:26 PM To: Roslokken, Dan Cc: Habit, Sandra (HHS/OCIIO) Subject: RE: Waiver Application for United Crafts Benefits Fund (11/23)
Dan, Thank you for your responses. Can you provide the COBRA equivalency rates? Cam Lynne Moultrie Office of Consumer Information and Insurance Oversight
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file:///T|/...th%20NO%2012600%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Additional%20info%2011.30.10.htm[07/13/2011 1:40:28 PM]
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U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov

Mr. Moultrie,
Inreceipt of your email, an explanation for the delay in response is appropriate. Last Thursday, I was hospitalized until yesterday with a severe Deep Vein Thrombosis. Now discharged but working remotely, I attend to your office's inquiry. Your office seeks a per enrollee cost if theUCBF is granted a waiver. Once again, because there are nineteen different employer groups within the UCBF, there are nineteen different answers (contribution rates having been set by collective bargaining agreements). Thus, the answer requested is not simple to obtain. However, acknowledging the utility of a per enrollee cost with a waiver, we believe the question can be approached and addressed in the following manner: Take the current annualized plan cost for 2010: $(b)(4) Divided among (b)(4) enrollees equals$(b)(4)
I $(b)(4) o (b)(4) by
While we provide the above calculations for your office's consideration, we again caution that because each of the nineteen participating employer groupshave different contribution arrangements set by collective bargaining agreements, that the above calculations may not necessarily typify actual experience. Also qualifying these calculations is thatthey do not account for differentials in EE,EE + child,EE + spouse, or familycoverage (the reason for both caveats having been set forth at length in the initial submission and subsequent email correspondence).
Respectfully, and on behalf of the UCBF, Dan Daniel W.Roslokken General Counsel and Managing Director IDA 169 Ramapo Valley Road Oakland, New Jersey 07436
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, the projected2011calendar yearUCBF plan costs per enrollee without a waiver will be between $ and (i.e., current plan costs PLUS excess loss coverage premium). Divided among 2,017 enrollees, this nge o $(b)(4) per enrollee. This means in practical terms that denial of the waiver will drive per enrollee costs up %.
(b)(4)
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% to account for expected medical trend, equals an expected 2011 medical spend of : $(b)(4) per enrollee (annually).
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201.337.0007,x260 droslokken@uhy-us.com
From: Moultrie, Cam (HHS/OCIIO) [Cam.Moultrie@hhs.gov] Sent: Thursday, November 18, 2010 4:19 PM To: Roslokken, Dan Subject: RE: Waiver Application for United Crafts Benefits Fund
Mr. Moultrie,
Because such increases cannot be passed onto the employer groups (because their contribution rates were set by collective bargaining agreements), and the fact that theUCBF 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 theseconsequences thatUCBF seeks a waiver of the annual limit restrictions under section 2711.

Respectfully, and on behalf of the UCBF, Dan Daniel W.Roslokken General Counsel and Managing Director
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In an attempt to provide some measurement of a premium equivalence, weprovide the following exercise as an illustrative aid to the OCIIO: The current annualized plan cost for 2010 is $(b)(4) Divided among (b)(4) enrollees equals $(b)(4) per enrollee (annually). This figure is illustrative only inasmuch that it does NOT account for differentials in EE,EE + child,EE + spouse, or familycoverage. Nor does this figureaccount or represent the actualcontribution rates of the underlying employer groups or of enrollees. In comparison, the projected2011calendar yearUCBF plan costs will be between $(b)(4) and $(b)(4) (i.e., current plan (b)(4) (b)(4) (b)(4) costs PLUS excess loss coverage premium). Divided among enrollees, this produces a range of $ to $ per enrollee. Utilizing the2010 per-enrollee measurement of $(b)(4) the projected 2011 costs per enrollee($(b)(4) to $(b)(4) ), represent a(b)(4) % to a(b)(4) % increase. This increase can be considered to represent the per enrollee cost of complying with the $750,000.00 annual limit under PPACA.
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However, because theUCBF is comprised of nineteen different contributing employers, there are (b)(4) $(b)(4) to $(b)(4) /month). Thus, this approach may be so cumbersome as to be impractical.
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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 rates. We appreciate the inquiry and utility of such a measurement. different COBRA rates (range of
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IDA 169 Ramapo Valley Road Oakland, New Jersey 07436 201.337.0007,x260 droslokken@uhy-us.com From: Moultrie, Cam (HHS/OCIIO) [Cam.Moultrie@hhs.gov] Sent: Wednesday, November 17, 2010 12:55 PM To: Roslokken, Dan Cc: Marianne@uciw.org; tlim@idatpa.com; Minetti, Russ; lmoore@idatpa.com; Habit, Sandra (HHS/OCIIO) Subject: RE: Waiver Application for United Crafts Benefits Fund
Dear Mr. Moultrie,
Clarifying the issue of "premium rates": Please be advised that the health benefits plan sponsored through theUCBF is on a 100% self funded basis. That is, to the extent a medical claim is adjudicated as eligible and payable, the cost thereof is 100% directly funded through the UCBF. Nineteenseparate employer groups contribute monies to fund the health benefits plan. There is no insurance 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, excess loss coverage can be purchased. Typically, the health plan retains the financial risk ofclaimsupto a particular amount per individual (otherwise called the "specific retention"), over which amount the excess loss coverage is
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On behalf of the United Crafts Benefits Fund ("UCBF"), I thank you for your office's careful review of the 2711 waiver application and correspondence. Received last night at 8:11pm, the correspondence seeks a reply by 5 pm, today. In a spirit of cooperation and responsiveness, we provide the following: Regarding lifetime maximums: Both IDA and the applicantUCBF are aware that lifetime limits can no longer be employed and shall not be employed.
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responsible for payment. Due to the limited benefit provided by the UCBF, there had been no role or prior use of excess loss coverage. Within the 2711 Waiver application,to approximate the cost of excess loss coverage that would cover the differential between theUCBF's current fiscal exposure and therestricted 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 $(b)(4) and $(b)(4) (USD).
Requested chart materials: Because there is no insured premiumfor 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 is no blended 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 thecalendar year 2009, the total medical claims cost of theUCBF (excluding life insurance, dental benefits, optical and prescription) was $(b)(4) For the first 10 months ofcalendar year 2010, total medical claims cost of theUCBF (excluding life insurance, dental benefits, optical and prescription benefits) are $(b)(4) Annualized, this will be $(b)(4) for calendar year 2010. If theUCBF was to comply with therestricted annual limit of $750,000, excess loss coverage would have to be purchased. As previously represented (with the quote being submitted in the initial waiver application), the cost for the excess loss coverage would range between$(b)(4) (USD). to $(b)(4) The additional expense of the excess loss covera e pr calendar yearUCBF plan costs would be between $(b)(4) and $(b)(4) (i.e., current plan costs PLUS excess loss coverage premium). This additional cost of compliance means an increase between (b)(4) % to (b)(4) %. 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 ways: 100% passed on to participating enrollees, which is: Unprecedented, and; Potentially barred by the terms of the underlying collective bargaining agreements, thereby implicating 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 theUCBF is NOT the originator or guarantor of funding (and the ability to collect additional fundingfrom employer groups or the enrollees themselves is likelybarred by collective bargaining agreement terms), theUCBF would no choice butto consider closing the health benefit fund,dis-enrolling allenrollees.
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Dear Mr. Roslokken: Thank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section 2711. 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, you 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 lifetime limit on your plan or policy. Plans that previously had a lifetime limit may add an annual limit not less than the lifetime limit without affecting the grandfather status of 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 basis. Please provide the current monthly premium rates and the projected monthly premium rates applicable 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 January Premium 2011 January Premium 2011 January Premium (renewal) (if $750,000 annual (current level) 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) In order to complete your application, please provide this information by 5:00 pm, November 16, 2010. We look forward to receiving your completed application. Thank you. Cam L. Moultrie Program Analyst Office of Consumer Information and Insurance Oversight
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U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov
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From: Roslokken, Dan [droslokken@uhy-us.com] Sent: Tuesday, November 30, 2010 5:55 PM To: Moultrie, Cam (HHS/OCIIO) Cc: Habit, Sandra (HHS/OCIIO); Marianne@uciw.org; Minetti, Russ; tlim@idatpa.com Subject: RE: Waiver Application for United Crafts Benefits Fund (11/30)
Cam , Truly appreciative of the opportunity to speak with you this afternoon, I understand that the final figure which your Office seeks is the current 2010 equivalency rates. Keeping in mind the caveats previously expressed, namely that such equivalency rates representan arthimetic mean ONLY, 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 $(b)(4) . We trust this information is responsive to your Office's request and need.

If for any reason there are any remaining questions or concerns, please do not hesitate to contact me directly (201.337.0007, extension 260). It was a pleasure to speak with you. Thank you for this opportunity to provide this information.
Dan
Daniel W. Roslokken General Counsel and Managing Director IDA 169 Ramapo Valley Road Oakland, New Jersey 07436 201.337.0007, x260 droslokken@uhy-us.com
From: Roslokken, Dan Sent: Tuesday, November 30, 2010 4:35 PM To: Moultrie, Cam (HHS/OCIIO) Cc: Habit, Sandra (HHS/OCIIO); Marianne@uciw.org; Minetti, Russ; tlim@idatpa.com Subject: RE: Waiver Application for United Crafts Benefits Fund (11/30) Cam, We wish to be responsive to the question and respectfully suggest thatthe COBRA question had been addressed on November 17th. That the question resurfaces has caused us to look anew on the issue. Perhaps the following clarification can be helpful to both our offices. 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 (b)(4) different employer groups. Each of these employer groups has reached different terms regarding health care ben ntribution rates. Of note, EACH of the (b)(4) employer groups provides health benefits to ACTIVE enrollees on a 100% basis, with no employee contribution Thus, in a technical sense, the current 2010 EE direct cost for health coverage is $0.00; If the waiver is granted for 2011, 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 cost of the excess loss coverage (Approximately $(b)(4) , divided by (b)(4) enrollees = $(b)(4) per enrollee cost). (b)(4) Literally, 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 (b)(4) different collective bargaining agreements, some of the COBRA rates are subsidized by employers. This means there een different COBRA rates. Because there are no universal COBRA rates, our email reply of November 17th and November 23rdcan be said to represent thearithmetic mean of COBRA rates (i.e., total costs divided by all enrollees) to produce a COBRA equivalency rate, with and without a waiver.
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file:///T|/...O%2012600%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Additional%20info%20(2)%2011.30.10.htm[07/13/2011 1:40:29 PM]
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Insummary: COBRA arithmetic mean with a waiver: $(b)(4) COBRA arithmetic mean without a waiver $(b)(4) We rely upon the original waiver,in addition to the email replies o projections.
to $(b)(4) ber 1
and23rd in support of these
Mr. Moultrie,
Inreceipt of your email, an explanation for the delay in response is appropriate. Last Thursday, I was hospitalized until yesterday with a severe Deep Vein Thrombosis. Now discharged but working remotely, I attend to your office's inquiry.
Your office seeks a per enrollee cost if theUCBF is granted a waiver. Once again, because there are
(b)(4)
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Dan, Thank you for your responses. Can you provide the COBRA equivalency rates? Cam Lynne Moultrie Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov
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From: Moultrie, Cam (HHS/OCIIO) [Cam.Moultrie@hhs.gov] Sent: Tuesday, November 30, 2010 3:26 PM To: Roslokken, Dan Cc: Habit, Sandra (HHS/OCIIO) Subject: RE: Waiver Application for United Crafts Benefits Fund (11/23)
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In an attempt to bring this matter to satisfactory conclusion for both of our offices, I suggest a telelphone conversation to discuss any remaining issues. I will reach out to your office this afternoon to seek an appropriate time for same. I look forward to speaking with you. Respectfully, and on behalf of the UCBF, Dan Daniel W.Roslokken General Counsel and Managing Director IDA 169 Ramapo Valley Road Oakland, New Jersey 07436 201.337.0007,x260 droslokken@uhy-us.com
groups within the UCBF, there are (b)(4) different answers (contribution rates having been set by collective bargaining agreements). Thus, the answer requested is not simple to obtain.
However, acknowledging the utility of a per enrollee cost with a waiver, we believe the question can be approached and addressed in the following manner: Take the current annualized plan cost for 2010: $(b)(4) . Multiply the plan cost by Divided among (b)(4) % to account for expected medical trend, equals an expected 2011 medical spend of : $(b)(4) per enrollee (annually). be between $(b)(4) and enrollees, this nge drive per enrollee costs up enrollees equals$(b)(4)
I $(b)(4) o (b)(4) by the projected2011calendar yearUCBF plan costs per enrollee without a wai (i. t plan costs PLUS excess loss coverage premium). Divided among (b)(4) (b)(4) o$ per enrollee. This means in practical terms that denial of the waiv %.
While we provide the above calculations for your office's consideration, we again caution that because each of the nineteen participating employer groupshave different contribution arrangements set by collective bargaining agreements, that the above calculations may not necessarily typify actual experience. Also qualifying these calculations is thatthey do not account for differentials in EE,EE + child,EE + spouse, or familycoverage (the reason for both caveats having been set forth at length in the initial submission and subsequent email correspondence). We trust this information is responsive toyour inquiry.

Mr. Moultrie,
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From: Moultrie, Cam (HHS/OCIIO) [Cam.Moultrie@hhs.gov] Sent: Thursday, November 18, 2010 4:19 PM To: Roslokken, Dan Subject: RE: Waiver Application for United Crafts Benefits Fund
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However, because theUCBF is comprised of nineteen different contributing employers, there are nineteen different COBRA rates (range of $(b)(4) to $(b)(4) /month). Thus, this approach may be so cumbersome as to be impractical.
In an attempt to provide some measurement of a premium equivalence, weprovide the following exercise as an illustrative aid to the OCIIO: The current annualized plan cost for 2010 is $(b)(4) Divided among (b)(4) enrollees equals $(b)(4) per enrollee (annually). This figure is illustrative only inasmuch that it does NOT account for differentials in EE,EE + child,EE + spouse, or familycoverage. Nor does this figureaccount or represent the actualcontribution rates of the underlying employer groups or of enrollees. In comparison, the projected2011calendar yearUCBF plan costs will be between $(b)(4) and $(b)(4) (i.e., current plan costs PLUS excess loss coverage premium). Divided among (b)(4) enrollees, this produces a range of $(b)(4) to $(b)(4) per enrollee. (b)(4) (b)(4) (b)(4) Utilizing the2010 per-enrollee measurement of $ , the projected 2011 costs per enrollee($ to $ ), represent (b)(4) (b)(4) 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 bargaining agreements), and the fact that theUCBF 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 theseconsequences thatUCBF seeks a waiver of the annual limit restrictions under section 2711.
Mr. Roslokken, Thank you for your response. Can you provide COBRA equivalencies to estimate the cost of premiums for employees, employee + spouse, and employee+family? Thanks again. Cam Moultrie Cam Lynne Moultrie Program Analyst
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Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov
Dear Mr. Moultrie,
Because there is no insured premiumfor 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 is no blended 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 thecalendar year 2009, the total medical claims cost of theUCBF (excluding life insurance, dental benefits, optical and prescription) was $(b)(4) For the first 10 months ofcalendar year 2010, total medical claims cost of theUCBF (excluding life insurance, dental benefits, optical and prescription benefits) are $(b)(4) Annualized, this will be $ (b)(4) for calendar year 2010. If theUCBF was to comply with therestricted annual limit of $750,000, excess loss coverage would have to be purchased. As previously represented (with the quote being submitted in the initial waiver application), the cost for
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The annualized premium for excess loss coverage is between $(b)(4)
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Within the 2711 Waiver application,to approximate the cost of excess loss coverage that would cover the differential between theUCBF's current fiscal exposure and therestricted 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. and $
(b)(4)
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A common aspect of self funded health plans is that, in order to hedge against catastrophic claim costs, excess loss coverage can be purchased. Typically, the health plan retains the financial risk ofclaimsupto a particular amount per individual (otherwise called the "specific retention"), over which amount the excess loss coverage is responsible for payment. Due to the limited benefit provided by the UCBF, there had been no role or prior use of excess loss coverage.
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Please be advised that the health benefits plan sponsored through theUCBF is on a 100% self funded basis. That is, to the extent a medical claim is adjudicated as eligible and payable, the cost thereof is 100% directly funded through the UCBF. Nineteenseparate employer groups contribute monies to fund the health benefits plan. There is no insurance carrier. Therefore there is no "premium", per se. Role of excess loss coverage.
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(USD).
the excess loss coverage would range between$(b)(4) to $ (USD). The additional expense of the excess loss coverage,means the projected2011calendar yearUCBF plan (b)(4) costs would be between $ and $(b)(4) (i.e., current plan costs PLUS excess loss coverage premium). This additional cost of compliance means an increase between (b)(4) % to (b)(4) %.
(b)(4)
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 ways: 100% passed on to participating enrollees, which is: Unprecedented, and; Potentially barred by the terms of the underlying collective bargaining agreements, thereby implicating 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 theUCBF is NOT the originator or guarantor of funding (and the ability to collect additional fundingfrom employer groups or the enrollees themselves is likelybarred by collective bargaining agreement terms), theUCBF would no choice butto consider closing the health benefit fund,dis-enrolling allenrollees.
Dear Mr. Roslokken: Thank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section 2711. 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, you 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 lifetime limit on your plan or policy. Plans that previously had a lifetime limit may add an annual limit not less than the lifetime limit without affecting the grandfather status of 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 basis.
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Please provide the current monthly premium rates and the projected monthly premium rates applicable 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 January Premium (current level) 2011 January Premium (renewal) 2011 January Premium (if $750,000 annual limit was applied)
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EE EE + Child (if applicable or other appropriate tier) EE + Spouse (if applicable or other appropriate tier) Family (if applicable or other appropriate tier)
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From: Moultrie, Cam (HHS/OCIIO) Sent: Tuesday, November 30, 2010 3:08 PM To: Habit, Sandra (HHS/OCIIO) Subject: FW: Waiver Application for United Crafts Benefits Fund (11/23)
Cam Lynne Moultrie Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov
Divided among (b)(4)
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Multiply the plan cost by
% to account for expected medical trend, equals an expected 2011 medical spend of : $(b)(4) per enrollee (annually).
enrollees equals$(b)(4)
In comparison, the projected2011calendar yearUCBF plan costs per enrollee without a waiver will be between $(b)(4) and (b)(4) $ (i. t plan costs PLUS excess loss coverage premium). Divided among (b)(4) enrollees, this nge o (b)(4) o $(b)(4) per enrollee. This means in practical terms that denial of the waiver will drive per enrollee costs up by %. While we provide the above calculations for your office's consideration, we again caution that because each of the nineteen participating employer groupshave different contribution arrangements set by collective bargaining agreements, that the above calculations may not necessarily typify actual experience. Also qualifying these calculations is thatthey do not account for differentials in EE,EE + child,EE + spouse, or familycoverage (the reason for both caveats having been set forth at length in the initial submission and subsequent email correspondence).
UCrafts:000044
file:///T|/...00%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Request%20for%20info%20response%2011.30.10.htm[07/13/2011 1:40:30 PM]
pl
Mr. Moultrie, Inreceipt of your email, an explanation for the delay in response is appropriate. Last Thursday, I was hospitalized until yesterday with a severe Deep Vein Thrombosis. Now discharged but working remotely, I attend to your office's inquiry. Your office seeks a per enrollee cost if theUCBF is granted a waiver. Once again, because there are nineteen different employer groups within the UCBF, there are nineteen different answers (contribution rates having been set by collective bargaining agreements). Thus, the answer requested is not simple to obtain. However, acknowledging the utility of a per enrollee cost with a waiver, we believe the question can be approached and addressed in the following manner: Take the current annualized plan cost for 2010: $(b)(4)
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Respectfully, and on behalf of the UCBF, Dan Daniel W.Roslokken General Counsel and Managing Director IDA 169 Ramapo Valley Road Oakland, New Jersey 07436 201.337.0007,x260 droslokken@uhy-us.com From: Moultrie, Cam (HHS/OCIIO) [Cam.Moultrie@hhs.gov] Sent: Thursday, November 18, 2010 4:19 PM To: Roslokken, Dan Subject: RE: Waiver Application for United Crafts Benefits Fund
Mr. Moultrie,
In an attempt to provide some measurement of a premium equivalence, weprovide the following exercise as an illustrative aid to the OCIIO: The current annualized plan cost for 2010 is $(b)(4) . Divided among (b)(4) enrollees equals $(b)(4) per enrollee (annually). This figure is illustrative only inasmuch that it does NOT account for differentials in EE,EE + child,EE + spouse, or familycoverage. Nor does this figureaccount or represent the actualcontribution rates of the underlying employer groups or of enrollees. In comparison, the projected2011calendar yearUCBF plan costs will be between $(b)(4) and $(b)(4) (i.e., current plan (b)(4) (b)(4) (b)(4) costs PLUS excess loss coverage premium). Divided among enrollees, this produces a range of $ to $ per enrollee. (b)(4) Utilizing the2010 per-enrollee measurement of $(b)(4) the projected 2011 costs per enrollee($(b)(4) to $ ), represent a(b)(4) % to a(b)(4) % 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 bargaining agreements), and the fact that theUCBF is neither the originator nor guarantor of funding, the totality of funding would fall entirely upon enrollees, likely causing massive disenrollment.
UCrafts:000045
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However, because theUCBF is comprised of nineteen different contributing employers, there are nineteen different COBRA rates (range of $(b)(4) to $ (b)(4) month). Thus, this approach may be so cumbersome as to be impractical.
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It is due to theseconsequences thatUCBF seeks a waiver of the annual limit restrictions under section 2711.

Dear Mr. Moultrie,

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Please be advised that the health benefits plan sponsored through theUCBF is on a 100% self funded basis. That is, to the extent a medical claim is adjudicated as eligible and payable, the cost thereof is 100% directly funded through the UCBF. Nineteenseparate employer groups contribute monies to fund the health benefits plan. There is no insurance 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, excess loss coverage can be purchased. Typically, the health plan retains the financial risk ofclaimsupto a particular amount per individual (otherwise called the "specific retention"), over which amount the excess loss coverage is responsible for payment. Due to the limited benefit provided by the UCBF, there had been no role or prior use of excess loss coverage. Within the 2711 Waiver application,to approximate the cost of excess loss coverage that would cover the differential between theUCBF's current fiscal exposure and therestricted 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 $(b)(4)
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and $(b)(4)
(USD).
Because there is no insured premiumfor 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 is no blended 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 thecalendar year 2009, the total medical claims cost of theUCBF (excluding life insurance, dental benefits, optical and prescription) was $(b)(4) For the first 10 months ofcalendar year 2010, total medical claims cost of theUCBF (excluding life insurance, dental benefits, optical and prescription benefits) are $(b)(4) Annualized, this will be $(b)(4) for calendar year 2010. If theUCBF was to comply with therestricted annual limit of $750,000, excess loss coverage would have to be purchased. As previously represented (with the quote being submitted in the initial waiver application), the cost for the excess loss coverage would range between$(b)(4) (USD). to $ (b)(4) The additional expense of the excess loss coverage,means the projected2011calendar yearUCBF plan costs would be between $(b)(4) and $(b)(4) (i.e., current plan costs PLUS excess loss coverage premium). This additional cost of compliance means an increase between (b)(4) % to (b)(4) %. 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 ways:
UCrafts:000047
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100% passed on to participating enrollees, which is: Unprecedented, and; Potentially barred by the terms of the underlying collective bargaining agreements, thereby implicating 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 theUCBF is NOT the originator or guarantor of funding (and the ability to collect additional fundingfrom employer groups or the enrollees themselves is likelybarred by collective bargaining agreement terms), theUCBF would no choice butto consider closing the health benefit fund,dis-enrolling allenrollees.
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Daniel W.Roslokken Managing Director and General Counsel IDA 169 Ramapo Valley Road Oakland, New Jersey 07436 201.337.0007 droslokken@uhy-us.com
Dear Mr. Roslokken: Thank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section 2711. 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, you 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 lifetime limit on your plan or policy. Plans that previously had a lifetime limit may add an annual limit not less than the lifetime limit without affecting the grandfather status of 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 basis. Please provide the current monthly premium rates and the projected monthly premium rates applicable 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 January Premium 2011 January Premium 2011 January Premium (renewal) (if $750,000 annual (current level) 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) In order to complete your application, please provide this information by 5:00 pm, November 16, 2010. We look forward to receiving your completed application. Thank you.
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Cam L. Moultrie Program Analyst Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov IMPORTANT: If this communication contains statements concerning taxation, those statements are provided for information purposes only, are not intended to constitute tax advice which may be relied upon to avoid penalties under any federal, state, local or other tax statutes or regulations, and do not resolve any tax issues in your favor. Upon request, we can provide you with express written tax advice after necessary factual development and subject to such conditions and qualifications as we may deem appropriate in the circumstances. This electronic mail message and any attached files contain information intended for the exclusive use of the party or parties to whom it is addressed and may contain information that is proprietary, privileged, confidential and/or exempt from disclosure under applicable law. If you are not an intended recipient, you are hereby notified that any viewing, copying, disclosure or distribution of this information may be subject to legal restriction or sanction. Please notify the sender, by electronic mail or telephone, of any unintended recipients and delete the original message without making any copies .
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From: Botwinick, Alexandra (HHS/OCIIO) Sent: Thursday, December 09, 2010 8:06 AM To: 'droslokken@uhy-us.com' Subject: Waiver of the Annual Limits Requirements of PHS Act Section 2711 Importance: High Attachments: Updated Jan 1 Approval Letter .pdf Good Morning, Thank you for submitting an application for a Waiver of the Annual Limits Requirements of the PHS Act Section 2711 for United Crafts Benefits Fund. HHS has reviewed your application and made its determination. Please see the attached letter. Please confirm receipt of this letter by replying to this e-mail address with a copy to OCIIOOversight@hhs.gov. Please let me know if I can be of further assistance. Sincerely,

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Alexandra Botwinick Office of Oversight HHS/OCIIO
alexandra.botwinick@hhs.gov
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file:///T|/...%2012600%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Approval%20letter%20sent%2012-9-2010.htm[07/13/2011 1:40:31 PM]

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(b)(4) (b)(4) (b)(4)

(b)(4) (b)(4) (b)(4)

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

file:///T|/...0%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Request%20for%20additional%20info%2011.15.10.htm[07/13/2011 1:40:23 PM]

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Confidentiality and Circular 230 Notices

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file:///T|/...se%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Request%20for%20additional%20info%20response%2011.17.10.htm[07/13/2011 1:40:25 PM]

Dear Mr. Moultrie,

Clarifying the issue of "premium rates":

file:///T|/...se%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Request%20for%20additional%20info%20response%2011.17.10.htm[07/13/2011 1:40:25 PM]

Dear Mr. Roslokken:

file:///T|/...se%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Request%20for%20additional%20info%20response%2011.17.10.htm[07/13/2011 1:40:25 PM]

Respectfully, and on behalf of the UCBF,

Confidentiality and Circular 230 Notices

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file:///T|/...se%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Request%20for%20additional%20info%20response%2011.17.10.htm[07/13/2011 1:40:25 PM]

file:///T|/...YELLOW]/United%20Crafts%20Benefits%20Fund/2nd%20request%20for%20additional%20info%20response%2011.18.10.htm[07/13/2011 1:40:26 PM]

Dear Mr. Moultrie,

file:///T|/...YELLOW]/United%20Crafts%20Benefits%20Fund/2nd%20request%20for%20additional%20info%20response%2011.18.10.htm[07/13/2011 1:40:26 PM]

and shall not be employed.

Requested chart materials:

file:///T|/...YELLOW]/United%20Crafts%20Benefits%20Fund/2nd%20request%20for%20additional%20info%20response%2011.18.10.htm[07/13/2011 1:40:26 PM]

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

file:///T|/...YELLOW]/United%20Crafts%20Benefits%20Fund/2nd%20request%20for%20additional%20info%20response%2011.18.10.htm[07/13/2011 1:40:26 PM]

Family (if applicable or other appropriate tier)

Confidentiality and Circular 230 Notices

file:///T|/...YELLOW]/United%20Crafts%20Benefits%20Fund/2nd%20request%20for%20additional%20info%20response%2011.18.10.htm[07/13/2011 1:40:26 PM]

Multiply the plan cost by Divided among (b)(4)

file:///T|/...012600%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/2nd%20Request%20for%20info%2011.30.10.htm[07/13/2011 1:40:27 PM]

We trust this information is responsive toyour inquiry.

file:///T|/...012600%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/2nd%20Request%20for%20info%2011.30.10.htm[07/13/2011 1:40:27 PM]

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are being maintained and are in full compliance therewith.

The annualized premium for excess loss coverage is between $(b)(4)

Requested chart materials:

file:///T|/...012600%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/2nd%20Request%20for%20info%2011.30.10.htm[07/13/2011 1:40:27 PM]

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

file:///T|/...012600%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/2nd%20Request%20for%20info%2011.30.10.htm[07/13/2011 1:40:27 PM]

Confidentiality and Circular 230 Notices

file:///T|/...012600%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/2nd%20Request%20for%20info%2011.30.10.htm[07/13/2011 1:40:27 PM]

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U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov

We trust this information is responsive toyour inquiry.

file:///T|/...th%20NO%2012600%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Additional%20info%2011.30.10.htm[07/13/2011 1:40:28 PM]

Multiply the plan cost by

file:///T|/...th%20NO%2012600%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Additional%20info%2011.30.10.htm[07/13/2011 1:40:28 PM]

Dear Mr. Moultrie,

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file:///T|/...th%20NO%2012600%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Additional%20info%2011.30.10.htm[07/13/2011 1:40:28 PM]

file:///T|/...th%20NO%2012600%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Additional%20info%2011.30.10.htm[07/13/2011 1:40:28 PM]

U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov

Confidentiality and Circular 230 Notices

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file:///T|/...O%2012600%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Additional%20info%20(2)%2011.30.10.htm[07/13/2011 1:40:29 PM]

and23rd in support of these

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file:///T|/...O%2012600%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Additional%20info%20(2)%2011.30.10.htm[07/13/2011 1:40:29 PM]

file:///T|/...O%2012600%20Response%20[YELLOW]/United%20Crafts%20Benefits%20Fund/Additional%20info%20(2)%2011.30.10.htm[07/13/2011 1:40:29 PM]

Dear Mr. Moultrie,