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Ex. 4 Ex. 4 Ex. 4

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UA L13:000001

Pages 2 through 40 redacted for the following reasons: ---------------------------Exemption 4

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UA L13:000002

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ANNUAL LIMIT WAIVER APPLICATION 2010

Annual Limit Waiver Request Applicant Name

Policy Name (use a new row for each Applicant policy (Plan/ Policy application) Situs) City

Applicant (Plan/ Policy Plan/ Policy Situs) Effective Date Contact State (mm/dd/yyyy) Name

Street Address

City

State

Phone Number (including Zip Code area code)

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Email Address sostrander @ualocal 13.org Other Yes

Total Number of Individuals Type of Covered by Current Coverage Policy Plan Overall (e.g., Limited Self(include all Annual Benefit, HRA, Insured Individual or dependents Limit (in Rx only, Other) (Yes/No) Group Policy covered) dollars)
Ex. 4

Rochester

NY

12/01/1975

Rochester

NY

14615

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Section VII of U.A. Local 13 Applicant & Employers Plan entitled Group "Reimbursem Insurance ent of Medical Plan Expenses"

Steve Ostrander

1850 Mt. Read Blvd

1-800-2248544 x104

Group

PRA Disclosure Statement

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According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless it displays a valid OMB control number. The valid OMB control number for this information collection is 0938-1105. The time required to complete this information collection is estimated to average ( 8 hours) or ( 240 minutes) per response, including the time to review instructions, search existing data resources, gather the data needed, and complete and review the information collection. If you have comments concerning the accuracy of the time estimate(s) or suggestions for improving this form, please write to: CMS, 7500 Security Boulevard, Attn: PRA Reports Clearance Officer, Mail Stop C4-26-05, Baltimore, Maryland 21244-1850.

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UA L13:000003

ANNUAL LIMIT WAIVER APPLICATION 2010

Ambulatory

Emergency

Hospitalization

Laboratory

Pediatric

Maternity/ Newborn

Mental Health/ Substance Abuse

Rehabilitative/ Devices

*None

*None

*None

*None

*None

*None

*None

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*None

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Preventive/ Wellness Prescription
Ex. 4

Current Essential Benefits Annual Limits (Annual Limit for Each Essential Benefit)

Office Visit Hospital Inpatient Emergency Room Rx Copays/Coinsurance Copay/Coinsurance Copay/Coinsurance Copay/Coninsurance

Coinsura Coinsura nce (if Copay (if Coinsuran nce (if Copay (if Copay (if Coinsuranc Copay (if ce (if Plan applicabl e (if applicabl applicabl applicabl applicabl applicabl e) e) applicable) e) e) Deductible e) applicable) e)

*None

*None

*None

*None

*None

*None

*None

*None

*None

*None

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UA L13:000004

ANNUAL LIMIT WAIVER APPLICATION 2010

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Ex. 4

Current Monthly Premium Rates or Premium Equivalent Rates (in dollars)*:

Projected Rate Increase that would result from compliance with $750,000 Annual Limit Renewal Monthly Premium Rates or Premium Equivalent Rates if Waiver Granted Restriction (in dollars) (Average Premium by Individual)* (in dollars)*

Employee Employer Individual/ Employee contribution contribution Tier* (if applicable) (if applicable)
Ex. 4

Total

Employee Employer contribution contribution (if applicable) (if applicable)


Ex. 4

Total

Employee Employer contribution contribution (if applicable) (if applicable)

Decrease in Access to Benefits that Projected Rate Increase would result that would result from from compliance with $750,000 compliance Annual Limit Restriction with $750,000 (in dollars)(Average Annual Limit Premium by Individual) Restriction (Difference of Column AT (describe and AQ divided by briefly in cell or in a

Plan Administr ator/ CEO of Health Insuranc e Issuer Name

Title of Individual Providing Attestation

Employee

*None

*None

*None

*None

*None

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*None

None

Steve Ostrander

Fund Manager

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

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From: Sheer, Jennifer (HHS/OCIIO) Sent: Wednesday, December 15, 2010 9:19 AM To: 'sostrander@ualocal13.org' Cc: Sheer, Jennifer (HHS/OCIIO) Subject: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application Attachments: Waiver Application Form.xls Follow Up Flag: Follow up Flag Status: Completed

Jennifer L. O. Sheer

Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services jennifer.sheer@hhs.gov 301-492-4487

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Dear Mr. Ostrander: Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act) Section 2711. In order to expedite your application, please provide the following information: I. Please complete the entire annual limits spreadsheet, attached to this email. Please return the completed spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an explanation regarding why you are unable to complete that particular cell in a separate document. II. In addition, please provide the following information: Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with grandfathering provisions, pursuant to 45 CFR 147.140? Confirm whether the plan was created pursuant to the Taft-Hartley Act. In order to complete your application, please provide this information by 5:00 pm, December 16, 2010. Once this information is received and the application is complete, it will be processed by the Department of Health and Human Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30 days of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decision. Thank you.

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UA L13:000008

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2015%202010.htm[08/02/2011 10:53:28 AM]

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Jennifer L. O. Sheer

Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov 301-492-4487 From: Tricia Marciano [triciam@ualocal13.org] Sent: Thursday, December 16, 2010 11:04 AM To: Sheer, Jennifer (HHS/OCIIO) Cc: Steve Ostrander Subject: FW: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)
UA L13:000009

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2016%202010.htm[08/02/2011 10:53:17 AM]

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Good morning I am unfortunately on sick leave today, and will not be able to return your call until I return to the office. If this is something we can address via e-mail, please let me know. If it does require a phone call, please know that you can have extra time to complete the spreadsheet and that I will return your call when I return to the office. I thank you for your understanding.

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From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov] Sent: Thursday, December 16, 2010 11:13 AM To: Tricia Marciano Cc: Steve Ostrander Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

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give me a call to discuss the information. I will not be in the office tomorrow, but will return on Monday, December 20 th . Thank you. Tricia Marciano Insurance & Pension Specialist UA Local 13 1850 Mt. Read Blvd. Rochester, NY 14615 Phone (585) 338-2310 x106 Fax (585) 544-3993

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From: Tricia Marciano [triciam@ualocal13.org] Sent: Thursday, December 16, 2010 3:26 PM To: Sheer, Jennifer (HHS/OCIIO) Cc: Steve Ostrander; TobinLaw Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call) Attachments: Waiver Application Form.xlsx; WaiverResponse.docx Follow Up Flag: Follow up Flag Status: Completed Jennifer, Thank you for getting back to me in a timely fashion. Attached is the spreadsheet along with our response to the sections of the spreadsheet where we indicated none. This document outlines how our plan works. Steve Ostrander (Fund Manager), our Legal Counsel and myself met this morning to go over this information. When you return to the office, please

Jennifer, I left you a Voice Mail message regarding the waiver application. Please call me when you get a moment today. Thank you. Tricia Marciano Insurance & Pension Specialist UA Local 13 1850 Mt. Read Blvd. Rochester, NY 14615 Phone (585) 338-2310 x106 Fax (585) 544-3993

From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov] Sent: Wednesday, December 15, 2010 9:19 AM To: Steve Ostrander Cc: Sheer, Jennifer (HHS/OCIIO) Subject: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application

Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act) Section 2711. In order to expedite your application, please provide the following information: I. Please complete the entire annual limits spreadsheet, attached to this email. Please return the completed spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an explanation regarding why you are unable to complete that particular cell in a separate document. II. In addition, please provide the following information: Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with grandfathering provisions, pursuant to 45 CFR 147.140?

Confirm whether the plan was created pursuant to the Taft-Hartley Act. In order to complete your application, please provide this information by 5:00 pm, December 16, 2010. Once this information is received and the application is complete, it will be processed by the Department of Health and Human Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30 days of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decision.

Thank you.
---------------------------------UA L13:000010

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2016%202010.htm[08/02/2011 10:53:17 AM]

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Dear Mr. Ostrander:

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From: Steve Ostrander Sent: Thursday, December 16, 2010 10:16 AM To: Tricia Marciano Subject: FW: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application

Jennifer L. O. Sheer
Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov 301-492-4487

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UA L13:000011

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2016%202010.htm[08/02/2011 10:53:17 AM]

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UA LOCAL 13 & EMPLOYERS GROUP INSURANCE PLAN Response to Fields Indicated as *None

The amount in each participants hour bank will vary for each participant based upon their hours worked and their Medical/Dental coverage selection. Work in the construction industry is cyclical. The average amount available for reimbursement in a participants hour bank is $Ex. 4 . Therefore, it is not feasible that we can comply with the $750,000 Annual Limit Res n based upon our plan design.

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Hourly contributions from Contractors per Collective Bargaining Agreement are deposited into each participants Hour Bank. Any contributions in excess of the required amount for their individual selected insurance coverage (the cost of one years worth of Health Care coverage) under the plan provisions can be used for reimbursement of the participants out of pocket medical expenses.

UA L13:000012

From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov] Sent: Wednesday, December 15, 2010 9:19 AM To: Steve Ostrander Cc: Sheer, Jennifer (HHS/OCIIO) Subject: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application

Dear Mr. Ostrander: Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act) Section 2711. In order to expedite your application, please provide the following information: I. Please complete the entire annual limits spreadsheet, attached to this email. Please return the completed spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an explanation regarding why you are unable to complete that particular cell in a separate document. II. In addition, please provide the following information: Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with grandfathering provisions, pursuant to 45 CFR 147.140? Confirm whether the plan was created pursuant to the Taft-Hartley Act.

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From: Steve Ostrander Sent: Thursday, December 16, 2010 10:16 AM To: Tricia Marciano Subject: FW: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application

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From: Tricia Marciano [triciam@ualocal13.org] Sent: Thursday, December 16, 2010 11:04 AM To: Sheer, Jennifer (HHS/OCIIO) Cc: Steve Ostrander Subject: FW: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call) Attachments: Waiver Application Form.xls Follow Up Flag: Follow Up Flag Status: Completed Jennifer, I left you a Voice Mail message regarding the waiver application. Please call me when you get a moment today. Thank you. Tricia Marciano Insurance & Pension Specialist UA Local 13 1850 Mt. Read Blvd. Rochester, NY 14615 Phone (585) 338-2310 x106 Fax (585) 544-3993

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UA L13:000013

file:///C|/...bers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20(Please%20Call)%20Dec%2016%202010.htm[08/02/2011 10:53:07 AM]

In order to complete your application, please provide this information by 5:00 pm, December 16, 2010. Once this information is received and the application is complete, it will be processed by the Department of Health and Human Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30 days of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decision. Thank you.
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Jennifer L. O. Sheer

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file:///C|/...bers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20(Please%20Call)%20Dec%2016%202010.htm[08/02/2011 10:53:07 AM]

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Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services jennifer.sheer@hhs.gov 301-492-4487

From: Sheer, Jennifer (HHS/OCIIO) Sent: Thursday, December 16, 2010 11:13 AM To: Tricia Marciano Cc: Steve Ostrander Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call) Follow Up Flag: Follow up Flag Status: Completed
Good morning I am unfortunately on sick leave today, and will not be able to return your call until I return to the office. If this is something we can address via e-mail, please let me know. If it does require a phone call, please know that you can have extra time to complete the spreadsheet and that I will return your call when I return to the office. I thank you for your understanding.

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Jennifer L. O. Sheer
Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov 301-492-4487

From: Steve Ostrander Sent: Thursday, December 16, 2010 10:16 AM To: Tricia Marciano Subject: FW: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application


From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov] Sent: Wednesday, December 15, 2010 9:19 AM To: Steve Ostrander Cc: Sheer, Jennifer (HHS/OCIIO)
UA L13:000015

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2016%202010.htm[08/02/2011 10:52:56 AM]

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Jennifer, I left you a Voice Mail message regarding the waiver application. Please call me when you get a moment today. Thank you. Tricia Marciano Insurance & Pension Specialist UA Local 13 1850 Mt. Read Blvd. Rochester, NY 14615 Phone (585) 338-2310 x106 Fax (585) 544-3993

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From: Tricia Marciano [triciam@ualocal13.org] Sent: Thursday, December 16, 2010 11:04 AM To: Sheer, Jennifer (HHS/OCIIO) Cc: Steve Ostrander Subject: FW: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

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Subject: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application

Dear Mr. Ostrander:

Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act) Section 2711. In order to expedite your application, please provide the following information:

I. Please complete the entire annual limits spreadsheet, attached to this email. Please return the completed spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an explanation regarding why you are unable to complete that particular cell in a separate document.

II. In addition, please provide the following information:

Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with grandfathering provisions, pursuant to 45 CFR 147.140?

In order to complete your application, please provide this information by 5:00 pm, December 16, 2010. Once this information is received and the application is complete, it will be processed by the Department of Health and Human Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30 days of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decision. Thank you.
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Jennifer L. O. Sheer

Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services

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jennifer.sheer@hhs.gov 301-492-4487

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Confirm whether the plan was created pursuant to the Taft-Hartley Act.

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UA L13:000016

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2016%202010.htm[08/02/2011 10:52:56 AM]

Steve Ostrander
Fund Manager UA Local 13 Benefits Office 1850 Mt. Read Blvd. Rochester, NY 14615 sostrander@ualocal13.org phone: 585-338-2310 ext.104 fax: 585-544-3993 toll free: 1-800-224-8544

From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov] Sent: Tuesday, December 21, 2010 4:21 PM To: Tricia Marciano Cc: Steve Ostrander Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

Hello I have two quick questions regarding your spreadsheet. In column Q (Current Plan Overall Annual Limit), you entered $Ex. 4 Is this the maximum amount that an individual could accumulate in his/her hour bank for reimbursable medical expenses? Second, in column AB, you list the plan deductible as $Ex. 4 what plan are you referring to (Im not clear on what this number means in relationship to the hour bank). Thank you in advance for the clarification.
UA L13:000017

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From: Steve Ostrander [SOstrander@ualocal13.org] Sent: Tuesday, December 21, 2010 5:00 PM To: Sheer, Jennifer (HHS/OCIIO) Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call) Follow Up Flag: Follow up Flag Status: Completed Jennifer, Tricia has the day off today, and she is in possession of all the paperwork. I am unable to answer the first question regarding Ex. 4 the $ , but I can answer the second question. The $Ex. 4 is the annual cost of our policy per participant at the family level. The cost in premium is close to $Ex. 4 per month. Each participant is required to maintain a one year premium balance in their hour bank before any reimbursements can be requested. We had an instance in the past where a participant drained his hour bank to $0.00 and was subsequently laid off. He did not have any contributions coming in for his health care and ran out of coverage within 3 months. He then was still unemployed and unable to self pay his premium, and was termed from the health plan. He was offered COBRA, but could not pay for that either on $Ex. 4 per week unemployment. We have since instituted this one year policy to prevent this situation from ever arising again. Hope that helps, and I will have Tricia contact you tomorrow morning. Regards, Steve

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file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2021%202010.htm[08/02/2011 10:51:13 AM]

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Jennifer L. O. Sheer
Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services jennifer.sheer@hhs.gov 301-492-4487

From: Tricia Marciano [mailto:triciam@ualocal13.org] Sent: Thursday, December 16, 2010 3:26 PM To: Sheer, Jennifer (HHS/OCIIO) Cc: Steve Ostrander; TobinLaw Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

----------------------------------

Jennifer L. O. Sheer
Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov 301-492-4487 From: Tricia Marciano [triciam@ualocal13.org]


UA L13:000018

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2021%202010.htm[08/02/2011 10:51:13 AM]

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Good morning I am unfortunately on sick leave today, and will not be able to return your call until I return to the office. If this is something we can address via e-mail, please let me know. If it does require a phone call, please know that you can have extra time to complete the spreadsheet and that I will return your call when I return to the office. I thank you for your understanding.

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From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov] Sent: Thursday, December 16, 2010 11:13 AM To: Tricia Marciano Cc: Steve Ostrander Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

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give me a call to discuss the information. I will not be in the office tomorrow, but will return on Monday, December 20 th . Thank you. Tricia Marciano Insurance & Pension Specialist UA Local 13 1850 Mt. Read Blvd. Rochester, NY 14615 Phone (585) 338-2310 x106 Fax (585) 544-3993

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Jennifer, Thank you for getting back to me in a timely fashion. Attached is the spreadsheet along with our response to the sections of the spreadsheet where we indicated none. This document outlines how our plan works. Steve Ostrander (Fund Manager), our Legal Counsel and myself met this morning to go over this information. When you return to the office, please

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Sent: Thursday, December 16, 2010 11:04 AM To: Sheer, Jennifer (HHS/OCIIO) Cc: Steve Ostrander Subject: FW: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act) Section 2711. In order to expedite your application, please provide the following information:

II. In addition, please provide the following information: Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with grandfathering provisions, pursuant to 45 CFR 147.140?

Confirm whether the plan was created pursuant to the Taft-Hartley Act.

In order to complete your application, please provide this information by 5:00 pm, December 16, 2010. Once this information is received and the application is complete, it will be processed by the Department of Health and Human Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30 days of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decision.

Thank you.

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I. Please complete the entire annual limits spreadsheet, attached to this email. Please return the completed spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an explanation regarding why you are unable to complete that particular cell in a separate document.

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Dear Mr. Ostrander:

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From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov] Sent: Wednesday, December 15, 2010 9:19 AM To: Steve Ostrander Cc: Sheer, Jennifer (HHS/OCIIO) Subject: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application

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UA L13:000019

From: Steve Ostrander Sent: Thursday, December 16, 2010 10:16 AM To: Tricia Marciano Subject: FW: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2021%202010.htm[08/02/2011 10:51:13 AM]

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Jennifer, I left you a Voice Mail message regarding the waiver application. Please call me when you get a moment today. Thank you. Tricia Marciano Insurance & Pension Specialist UA Local 13 1850 Mt. Read Blvd. Rochester, NY 14615 Phone (585) 338-2310 x106 Fax (585) 544-3993

----------------------------------

Jennifer L. O. Sheer
Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov 301-492-4487

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UA L13:000020

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2021%202010.htm[08/02/2011 10:51:13 AM]

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Jennifer L. O. Sheer
Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services jennifer.sheer@hhs.gov 301-492-4487

give me a call to discuss the information. I will not be in the office tomorrow, but will return on Monday, December 20 th . Thank you. Tricia Marciano Insurance & Pension Specialist UA Local 13 1850 Mt. Read Blvd. Rochester, NY 14615 Phone (585) 338-2310 x106 Fax (585) 544-3993
From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov] Sent: Thursday, December 16, 2010 11:13 AM To: Tricia Marciano Cc: Steve Ostrander Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

Good morning I am unfortunately on sick leave today, and will not be able to return your call until I return to the office. If this is something we can
UA L13:000021

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2017%202010.htm[08/02/2011 10:52:32 AM]

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Jennifer, Thank you for getting back to me in a timely fashion. Attached is the spreadsheet along with our response to the sections of the spreadsheet where we indicated none. This document outlines how our plan works. Steve Ostrander (Fund Manager), our Legal Counsel and myself met this morning to go over this information. When you return to the office, please

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From: Tricia Marciano [mailto:triciam@ualocal13.org] Sent: Thursday, December 16, 2010 3:26 PM To: Sheer, Jennifer (HHS/OCIIO) Cc: Steve Ostrander; TobinLaw Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

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From: Sheer, Jennifer (HHS/OCIIO) Sent: Friday, December 17, 2010 9:12 AM To: 'Tricia Marciano' Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call) Follow Up Flag: Follow up Flag Status: Completed Hello Tricia Thank you for your understanding. I will call you Monday morning to discuss your application. Have a good weekend. ----------------------------------

address via e-mail, please let me know. If it does require a phone call, please know that you can have extra time to complete the spreadsheet and that I will return your call when I return to the office. I thank you for your understanding.

----------------------------------

Jennifer L. O. Sheer
Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov 301-492-4487

From: Steve Ostrander Sent: Thursday, December 16, 2010 10:16 AM To: Tricia Marciano Subject: FW: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application

Dear Mr. Ostrander:

Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act) Section 2711. In order to expedite your application, please provide the following information:

I. Please complete the entire annual limits spreadsheet, attached to this email. Please return the completed spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an explanation regarding why you are unable to complete that particular cell in a separate document.

UA L13:000022

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2017%202010.htm[08/02/2011 10:52:32 AM]

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From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov] Sent: Wednesday, December 15, 2010 9:19 AM To: Steve Ostrander Cc: Sheer, Jennifer (HHS/OCIIO) Subject: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application

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Jennifer, I left you a Voice Mail message regarding the waiver application. Please call me when you get a moment today. Thank you. Tricia Marciano Insurance & Pension Specialist UA Local 13 1850 Mt. Read Blvd. Rochester, NY 14615 Phone (585) 338-2310 x106 Fax (585) 544-3993

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ra do .

co m

From: Tricia Marciano [triciam@ualocal13.org] Sent: Thursday, December 16, 2010 11:04 AM To: Sheer, Jennifer (HHS/OCIIO) Cc: Steve Ostrander Subject: FW: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

II. In addition, please provide the following information:

Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with grandfathering provisions, pursuant to 45 CFR 147.140?

Confirm whether the plan was created pursuant to the Taft-Hartley Act.

In order to complete your application, please provide this information by 5:00 pm, December 16, 2010. Once this information is received and the application is complete, it will be processed by the Department of Health and Human Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30 days of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decision.
----------------------------------

Jennifer L. O. Sheer
Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov 301-492-4487

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UA L13:000023

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2017%202010.htm[08/02/2011 10:52:32 AM]

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Thank you.

Jennifer L. O. Sheer
Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services jennifer.sheer@hhs.gov 301-492-4487

From: Tricia Marciano [mailto:triciam@ualocal13.org] Sent: Thursday, December 16, 2010 3:26 PM To: Sheer, Jennifer (HHS/OCIIO) Cc: Steve Ostrander; TobinLaw Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

give me a call to discuss the information. I will not be in the office tomorrow, but will return on Monday, December 20 th . Thank you. Tricia Marciano Insurance & Pension Specialist UA Local 13 1850 Mt. Read Blvd. Rochester, NY 14615 Phone (585) 338-2310 x106 Fax (585) 544-3993
From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov]
UA L13:000024

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2021%202010.htm[08/02/2011 10:52:00 AM]

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Jennifer, Thank you for getting back to me in a timely fashion. Attached is the spreadsheet along with our response to the sections of the spreadsheet where we indicated none. This document outlines how our plan works. Steve Ostrander (Fund Manager), our Legal Counsel and myself met this morning to go over this information. When you return to the office, please

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From: Sheer, Jennifer (HHS/OCIIO) Sent: Tuesday, December 21, 2010 4:21 PM To: 'Tricia Marciano' Cc: Steve Ostrander Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call) Follow Up Flag: Follow up Flag Status: Completed Hello I have two quick questions regarding your spreadsheet. In column Q (Current Plan Overall Annual Limit), you entered $ Ex. 4 Is this the maximum amount that an individual could accumulate in his/her hour bank for reimbursable medical expenses? Second, in column AB, you list the plan deductible as $Ex. 4 what plan are you referring to (Im not clear on what this number means in relationship to the hour bank). Thank you in advance for the clarification. ----------------------------------

co m

Sent: Thursday, December 16, 2010 11:13 AM To: Tricia Marciano Cc: Steve Ostrander Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

Good morning I am unfortunately on sick leave today, and will not be able to return your call until I return to the office. If this is something we can address via e-mail, please let me know. If it does require a phone call, please know that you can have extra time to complete the spreadsheet and that I will return your call when I return to the office. I thank you for your understanding.

----------------------------------

Jennifer L. O. Sheer

jennifer.sheer@hhs.gov 301-492-4487

From: Tricia Marciano [triciam@ualocal13.org] Sent: Thursday, December 16, 2010 11:04 AM To: Sheer, Jennifer (HHS/OCIIO) Cc: Steve Ostrander Subject: FW: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov] Sent: Wednesday, December 15, 2010 9:19 AM To: Steve Ostrander Cc: Sheer, Jennifer (HHS/OCIIO) Subject: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application

Dear Mr. Ostrander:

Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act) Section 2711. In order to expedite your application, please provide the following information:
UA L13:000025

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2021%202010.htm[08/02/2011 10:52:00 AM]

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From: Steve Ostrander Sent: Thursday, December 16, 2010 10:16 AM To: Tricia Marciano Subject: FW: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application

pl

Jennifer, I left you a Voice Mail message regarding the waiver application. Please call me when you get a moment today. Thank you. Tricia Marciano Insurance & Pension Specialist UA Local 13 1850 Mt. Read Blvd. Rochester, NY 14615 Phone (585) 338-2310 x106 Fax (585) 544-3993

et eC

ol o

ra do .

co m

Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services

I. Please complete the entire annual limits spreadsheet, attached to this email. Please return the completed spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an explanation regarding why you are unable to complete that particular cell in a separate document.

II. In addition, please provide the following information:

Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with grandfathering provisions, pursuant to 45 CFR 147.140?

Thank you.
----------------------------------

Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov 301-492-4487

Co m

pl

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ol o

Jennifer L. O. Sheer

ra do .

In order to complete your application, please provide this information by 5:00 pm, December 16, 2010. Once this information is received and the application is complete, it will be processed by the Department of Health and Human Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30 days of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decision.

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Confirm whether the plan was created pursuant to the Taft-Hartley Act.

UA L13:000026

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2021%202010.htm[08/02/2011 10:52:00 AM]

Jennifer L. O. Sheer
Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services jennifer.sheer@hhs.gov 301-492-4487

From: Steve Ostrander [mailto:SOstrander@ualocal13.org] Sent: Tuesday, December 21, 2010 5:00 PM To: Sheer, Jennifer (HHS/OCIIO) Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

Jennifer, Tricia has the day off today, and she is in possession of all the paperwork. I am unable to answer the first question regarding the $Ex. 4 but I can answer the second question. The $ Ex. 4 is the annual cost of our policy per participant at the family Ex. 4 level. The cost in premium is close to $ per month. Each participant is required to maintain a one year premium balance in their hour bank before any reimbursements can be requested. We had an instance in the past where a participant drained his hour bank to $0.00 and was subsequently laid off. He did not have any contributions coming in for his health care and ran out of coverage within 3 months. He then was still unemployed and unable to self pay his premium, and was termed from the health plan. He was offered COBRA, but could not pay for that either on $Ex. 4 per week unemployment. We have since instituted this one year policy to prevent this situation from ever arising again. Hope that helps, and I will have Tricia contact you tomorrow morning. Regards, Steve

Steve Ostrander
Fund Manager UA Local 13 Benefits Office 1850 Mt. Read Blvd. Rochester, NY 14615 sostrander@ualocal13.org phone: 585-338-2310 ext.104 fax: 585-544-3993
UA L13:000027

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2021%202010.htm[08/02/2011 10:52:43 AM]

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From: Sheer, Jennifer (HHS/OCIIO) Sent: Wednesday, December 22, 2010 9:59 AM To: 'Steve Ostrander' Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call) Follow Up Flag: Follow up Flag Status: Completed Hi Steve Thank you for this information, this does help to clarify things. I will keep an eye out for Tricias response. Thank you. ----------------------------------

toll free: 1-800-224-8544


From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov] Sent: Tuesday, December 21, 2010 4:21 PM To: Tricia Marciano Cc: Steve Ostrander Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

Jennifer L. O. Sheer
Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services jennifer.sheer@hhs.gov 301-492-4487

From: Tricia Marciano [mailto:triciam@ualocal13.org] Sent: Thursday, December 16, 2010 3:26 PM To: Sheer, Jennifer (HHS/OCIIO) Cc: Steve Ostrander; TobinLaw Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

give me a call to discuss the information. I will not be in the office tomorrow, but will return on Monday, December 20 th . Thank you. Tricia Marciano Insurance & Pension Specialist UA Local 13 1850 Mt. Read Blvd. Rochester, NY 14615 Phone (585) 338-2310 x106 Fax (585) 544-3993
From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov] Sent: Thursday, December 16, 2010 11:13 AM
UA L13:000028

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2021%202010.htm[08/02/2011 10:52:43 AM]

Co m

Jennifer, Thank you for getting back to me in a timely fashion. Attached is the spreadsheet along with our response to the sections of the spreadsheet where we indicated none. This document outlines how our plan works. Steve Ostrander (Fund Manager), our Legal Counsel and myself met this morning to go over this information. When you return to the office, please

pl

et eC

ol o

ra do .

Hello I have two quick questions regarding your spreadsheet. In column Q (Current Plan Overall Annual Limit), you entered $ Ex. 4 Is this the maximum amount that an individual could accumulate in his/her hour bank for reimbursable medical expenses? Second, in column AB, you list the plan deductible as $ Ex. 4 what plan are you referring to (Im not clear on what this number means in relationship to the hour bank). Thank you in advance for the clarification. ----------------------------------

co m

To: Tricia Marciano Cc: Steve Ostrander Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

Good morning I am unfortunately on sick leave today, and will not be able to return your call until I return to the office. If this is something we can address via e-mail, please let me know. If it does require a phone call, please know that you can have extra time to complete the spreadsheet and that I will return your call when I return to the office. I thank you for your understanding.

----------------------------------

Jennifer L. O. Sheer
Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov 301-492-4487

From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov] Sent: Wednesday, December 15, 2010 9:19 AM To: Steve Ostrander Cc: Sheer, Jennifer (HHS/OCIIO) Subject: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application

Dear Mr. Ostrander:

Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act) Section 2711. In order to expedite your application, please provide the following information:

UA L13:000029

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2021%202010.htm[08/02/2011 10:52:43 AM]

Co m

From: Steve Ostrander Sent: Thursday, December 16, 2010 10:16 AM To: Tricia Marciano Subject: FW: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application

pl

Jennifer, I left you a Voice Mail message regarding the waiver application. Please call me when you get a moment today. Thank you. Tricia Marciano Insurance & Pension Specialist UA Local 13 1850 Mt. Read Blvd. Rochester, NY 14615 Phone (585) 338-2310 x106 Fax (585) 544-3993

et eC

ol o

ra do .

From: Tricia Marciano [triciam@ualocal13.org] Sent: Thursday, December 16, 2010 11:04 AM To: Sheer, Jennifer (HHS/OCIIO) Cc: Steve Ostrander Subject: FW: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

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I. Please complete the entire annual limits spreadsheet, attached to this email. Please return the completed spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an explanation regarding why you are unable to complete that particular cell in a separate document.

II. In addition, please provide the following information:

Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with grandfathering provisions, pursuant to 45 CFR 147.140?

Confirm whether the plan was created pursuant to the Taft-Hartley Act. In order to complete your application, please provide this information by 5:00 pm, December 16, 2010. Once this information is received and the application is complete, it will be processed by the Department of Health and Human Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30 days of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decision.

Thank you.
----------------------------------

Jennifer L. O. Sheer
Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov 301-492-4487

Co m

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ol o

ra do .
UA L13:000030

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2021%202010.htm[08/02/2011 10:52:43 AM]

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From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov] Sent: Tuesday, December 21, 2010 4:21 PM To: Tricia Marciano Cc: Steve Ostrander Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

Hello I have two quick questions regarding your spreadsheet. In column Q (Current Plan Overall Annual Limit), you entered $Ex. 4 Is this the maximum amount that an individual could accumulate in his/her hour bank for reimbursable medical expenses? Second, in column AB, you list the plan deductible as $Ex. 4 what plan are you referring to (Im not clear on what this number means in relationship to the hour bank). Thank you in advance for the clarification. ----------------------------------

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From: Tricia Marciano [triciam@ualocal13.org] Sent: Wednesday, December 22, 2010 11:59 AM To: Sheer, Jennifer (HHS/OCIIO) Cc: Steve Ostrander Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call) Follow Up Flag: Follow up Flag Status: Completed Jennifer, Heres the clarification on your two questions below: Column Q, $Ex. 4 . That is the most that one particular participant currently has in their hour bank available for medical reimbursement after their one years worth of insurance has been held in reserve. Column AB, $Ex. 4 That is the current cost of one years health insurance. I hope this information is helpful and please do not hesitate to call me if you need additional clarification. Have a wonderful holiday. Tricia Marciano Insurance & Pension Specialist UA Local 13 1850 Mt. Read Blvd. Rochester, NY 14615 Phone (585) 338-2310 x106 Fax (585) 544-3993

ra do .

co m

Jennifer L. O. Sheer
Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services jennifer.sheer@hhs.gov 301-492-4487
UA L13:000031

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2022%202010.htm[08/02/2011 10:51:38 AM]

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From: Tricia Marciano [mailto:triciam@ualocal13.org] Sent: Thursday, December 16, 2010 3:26 PM To: Sheer, Jennifer (HHS/OCIIO) Cc: Steve Ostrander; TobinLaw Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

Jennifer, Thank you for getting back to me in a timely fashion. Attached is the spreadsheet along with our response to the sections of the spreadsheet where we indicated none. This document outlines how our plan works. Steve Ostrander (Fund Manager), our Legal Counsel and myself met this morning to go over this information. When you return to the office, please give me a call to discuss the information. I will not be in the office tomorrow, but will return on Monday, December 20 th . Thank you. Tricia Marciano Insurance & Pension Specialist UA Local 13 1850 Mt. Read Blvd. Rochester, NY 14615 Phone (585) 338-2310 x106 Fax (585) 544-3993

----------------------------------

Jennifer L. O. Sheer

jennifer.sheer@hhs.gov 301-492-4487

From: Tricia Marciano [triciam@ualocal13.org] Sent: Thursday, December 16, 2010 11:04 AM To: Sheer, Jennifer (HHS/OCIIO) Cc: Steve Ostrander Subject: FW: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

Jennifer, I left you a Voice Mail message regarding the waiver application. Please call me when you get a moment today. Thank you. Tricia Marciano
UA L13:000032

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2022%202010.htm[08/02/2011 10:51:38 AM]

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Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services

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Good morning I am unfortunately on sick leave today, and will not be able to return your call until I return to the office. If this is something we can address via e-mail, please let me know. If it does require a phone call, please know that you can have extra time to complete the spreadsheet and that I will return your call when I return to the office. I thank you for your understanding.

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From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov] Sent: Thursday, December 16, 2010 11:13 AM To: Tricia Marciano Cc: Steve Ostrander Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

ra do .

co m

Insurance & Pension Specialist UA Local 13 1850 Mt. Read Blvd. Rochester, NY 14615 Phone (585) 338-2310 x106 Fax (585) 544-3993
From: Steve Ostrander Sent: Thursday, December 16, 2010 10:16 AM To: Tricia Marciano Subject: FW: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application

Dear Mr. Ostrander:

Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act) Section 2711. In order to expedite your application, please provide the following information:

II. In addition, please provide the following information: Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with grandfathering provisions, pursuant to 45 CFR 147.140?

In order to complete your application, please provide this information by 5:00 pm, December 16, 2010. Once this information is received and the application is complete, it will be processed by the Department of Health and Human Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30 days of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decision.

Thank you.
----------------------------------

Jennifer L. O. Sheer
Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services

UA L13:000033

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2022%202010.htm[08/02/2011 10:51:38 AM]

Co m

Confirm whether the plan was created pursuant to the Taft-Hartley Act.

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et eC

I. Please complete the entire annual limits spreadsheet, attached to this email. Please return the completed spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an explanation regarding why you are unable to complete that particular cell in a separate document.

ol o

ra do .

From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov] Sent: Wednesday, December 15, 2010 9:19 AM To: Steve Ostrander Cc: Sheer, Jennifer (HHS/OCIIO) Subject: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application

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jennifer.sheer@hhs.gov 301-492-4487

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ra do .
UA L13:000034

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2022%202010.htm[08/02/2011 10:51:38 AM]

co m

Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services jennifer.sheer@hhs.gov 301-492-4487

Jennifer, Heres the clarification on your two questions below: Column Q, $Ex. 4 . That is the most that one particular participant currently has in their hour bank available for medical reimbursement after their one years worth of insurance has been held in reserve. Column AB, $Ex. 4 . That is the current cost of one years health insurance. I hope this information is helpful and please do not hesitate to call me if you need additional clarification. Have a wonderful holiday. Tricia Marciano Insurance & Pension Specialist UA Local 13 1850 Mt. Read Blvd. Rochester, NY 14615 Phone (585) 338-2310 x106 Fax (585) 544-3993
From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov] Sent: Tuesday, December 21, 2010 4:21 PM To: Tricia Marciano
UA L13:000035

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2022%202010.htm[08/02/2011 10:52:10 AM]

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From: Tricia Marciano [mailto:triciam@ualocal13.org] Sent: Wednesday, December 22, 2010 11:59 AM To: Sheer, Jennifer (HHS/OCIIO) Cc: Steve Ostrander Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

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ra do .

Jennifer L. O. Sheer

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From: Sheer, Jennifer (HHS/OCIIO) Sent: Wednesday, December 22, 2010 12:03 PM To: 'Tricia Marciano' Cc: Steve Ostrander Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call) Follow Up Flag: Follow up Flag Status: Completed Hi Tricia Thank you very much for this clarification. Happy holidays. ----------------------------------

Cc: Steve Ostrander Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

Jennifer L. O. Sheer
Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services jennifer.sheer@hhs.gov 301-492-4487

give me a call to discuss the information. I will not be in the office tomorrow, but will return on Monday, December 20 th . Thank you. Tricia Marciano Insurance & Pension Specialist UA Local 13 1850 Mt. Read Blvd. Rochester, NY 14615 Phone (585) 338-2310 x106 Fax (585) 544-3993
From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov] Sent: Thursday, December 16, 2010 11:13 AM To: Tricia Marciano Cc: Steve Ostrander Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

Good morning I am unfortunately on sick leave today, and will not be able to return your call until I return to the office. If this is something we can address via e-mail, please let me know. If it does require a phone call, please know that you can have extra time to complete the
UA L13:000036

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2022%202010.htm[08/02/2011 10:52:10 AM]

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Jennifer, Thank you for getting back to me in a timely fashion. Attached is the spreadsheet along with our response to the sections of the spreadsheet where we indicated none. This document outlines how our plan works. Steve Ostrander (Fund Manager), our Legal Counsel and myself met this morning to go over this information. When you return to the office, please

ol o

From: Tricia Marciano [mailto:triciam@ualocal13.org] Sent: Thursday, December 16, 2010 3:26 PM To: Sheer, Jennifer (HHS/OCIIO) Cc: Steve Ostrander; TobinLaw Subject: RE: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

ra do .

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Hello I have two quick questions regarding your spreadsheet. In column Q (Current Plan Overall Annual Limit), you entered $Ex. 4 Is this the maximum amount that an individual could accumulate in his/her hour bank for reimbursable medical expenses? Second, in column AB, you list the plan deductible as $Ex. 4 what plan are you referring to (Im not clear on what this number means in relationship to the hour bank). Thank you in advance for the clarification. ----------------------------------

spreadsheet and that I will return your call when I return to the office. I thank you for your understanding.

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Jennifer L. O. Sheer
Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov 301-492-4487 From: Tricia Marciano [triciam@ualocal13.org] Sent: Thursday, December 16, 2010 11:04 AM To: Sheer, Jennifer (HHS/OCIIO) Cc: Steve Ostrander Subject: FW: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application (Please Call)

Dear Mr. Ostrander:

Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act) Section 2711. In order to expedite your application, please provide the following information:

I. Please complete the entire annual limits spreadsheet, attached to this email. Please return the completed spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an explanation regarding why you are unable to complete that particular cell in a separate document.

II. In addition, please provide the following information:


UA L13:000037

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2022%202010.htm[08/02/2011 10:52:10 AM]

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From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov] Sent: Wednesday, December 15, 2010 9:19 AM To: Steve Ostrander Cc: Sheer, Jennifer (HHS/OCIIO) Subject: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application

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From: Steve Ostrander Sent: Thursday, December 16, 2010 10:16 AM To: Tricia Marciano Subject: FW: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application

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Jennifer, I left you a Voice Mail message regarding the waiver application. Please call me when you get a moment today. Thank you. Tricia Marciano Insurance & Pension Specialist UA Local 13 1850 Mt. Read Blvd. Rochester, NY 14615 Phone (585) 338-2310 x106 Fax (585) 544-3993

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Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with grandfathering provisions, pursuant to 45 CFR 147.140?

Confirm whether the plan was created pursuant to the Taft-Hartley Act.

In order to complete your application, please provide this information by 5:00 pm, December 16, 2010. Once this information is received and the application is complete, it will be processed by the Department of Health and Human Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30 days of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decision.

Thank you.

Jennifer L. O. Sheer
Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov 301-492-4487

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UA L13:000038

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2022%202010.htm[08/02/2011 10:52:10 AM]

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From: Sheer, Jennifer (HHS/OCIIO) Sent: Wednesday, December 22, 2010 12:14 PM To: 'Tricia Marciano'; Steve Ostrander Subject: UA Local 13 Plumbers and Pipefitters Annual Limit Waiver Application Follow Up Flag: Follow up Flag Status: Completed

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Jennifer L. O. Sheer
Office of Consumer Support Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services jennifer.sheer@hhs.gov 301-492-4487

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UA L13:000039

file:///C|/...ocal%2013%20Plumbers%20and%20Pipefitters%20Annual%20Limit%20Waiver%20Application%20Dec%2022%202010.htm[08/02/2011 10:52:21 AM]

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Dear Applicant: Thank you for your information. Your application is now complete and you should receive a determination of your application within 30 days. Thank you.