MY PLAN IS GETTING A REBATE FROM THE INSURER WHAT DO I DO WITH IT?
|
|
- Samson Benson
- 5 years ago
- Views:
Transcription
1 HUMAN CAPITAL PRACTICE ALERT: HEALTH CARE REFORM BILL August MY PLAN IS GETTING A REBATE FROM THE INSURER WHAT DO I DO WITH IT? EXECUTIVE SUMMARY All insured employer group medical plans (but not self-funded plans) will be receiving rebates from their insurers if the insurers spent less than 85% (80% in the small group market as determined by the states but in all cases fewer than 100 covered lives) of the premium dollars collected for their group of policies on medical expenses. Those insurers have sent or will soon be sending those rebates to individuals and employers. Employers will need to determine how much, if any, of the rebate they can retain, use for plan operations or return to plan participants. Employers are plan fiduciaries and therefore must make prudent determinations in the best interests of the plan participants and beneficiaries. Many employers will take a conservative view and distribute the rebates to the plan participants in proportion to the amount that they paid for their coverage, and some may even choose to distribute the entire rebate to plan participants, even if that is not mandated. There are methods for employers who would prefer to use those funds for plan operations or other purposes. While that may be an option for some employers in some situations, the conservative option is to reallocate those funds to the plan participants. In the event that they prefer to use the funds in another way, employers should consult legal counsel to make certain that they are comfortable with that option. DISCUSSION Under the Patient Protection and Affordable Care Act (PPACA), health insurance issuers are required to provide rebates to enrollees when their spending for the benefit of policyholders (on reimbursement for clinical services and activities for improving health care quality) in relation to the premiums charged (as adjusted for taxes) is less than the MLR standards established pursuant to the statute. Rebates are based upon aggregated market data in each state and not upon a particular group health plan's experience. While that is a requirement at the insurance company level (note that this requirement is NOT applicable to self-funded plans, even those with stop-loss coverage), the rebates will be sent to the employers sponsoring the plans, and the Department of Labor (DOL) has provided rules that will apply to the manner in which employers can or must allocate those rebates. When rebates are issued to employer plans, issues concerning the status of such funds under ERISA, and how such funds must be handled, necessarily arise. Traditionally, ERISA fiduciary standards apply to any return of premiums to employer plans. In addition, under PPACA the rebates may now be distributed to non-erisa plans (such as governmental plans and church plans), so while those assets will not be governed by ERISA, in some ways they have to be treated as though they were. The general rule that applies for any rebate is that, to the extent that the rebates are plan assets (and that characterization will apply relatively broadly), they become subject to ERISA s
2 fiduciary requirements and, with some exceptions, must be held in trust (although there is an exception for insurance contracts), may not inure to the benefit of any employer, and must be held for the exclusive purpose of 1) providing benefits to plan participants and their beneficiaries and 2) defraying reasonable expenses of administering the plan. If the employer is the policyholder and the insurance policy or contract, together with other instruments governing the plan, can fairly be read to provide that some part or all of a distribution belongs to the employer, then that language will generally govern, and the employer may retain distributions. However, the DOL states in its guidance that the fact that the employer is the owner of the policy would not, by itself, indicate that the employer may retain the distributions. In determining who is entitled to the distribution, one would need to carefully analyze the terms of the governing plan documents and the parties understandings and representations. Assuming the plan documents and other extrinsic evidence do not resolve the allocation issue, the portion of a rebate that is attributable to participant contributions would be considered plan assets. The guidance discusses five scenarios: 1. If the employer paid the entire cost of the insurance coverage, then no part of the rebate would be attributable to participant contributions and there would be no plan assets. 2. On the other hand, if participants paid the entire cost of the insurance coverage, then the entire amount of the rebate would be attributable to participant contributions and would be deemed entirely plan assets and would have to be distributed entirely to the participants. 3. If the participants and the employer each paid a fixed percentage of the cost, a percentage of the rebate equal to the percentage of the cost paid by participants would be attributable to participant contributions. 4. If the employer was required to pay a fixed amount and participants were responsible for paying any additional costs, then the portion of the rebate under the policy up to the participants total amount of contributions during the relevant period would be attributable to participant contributions and be plan assets. 5. Finally, if participants paid a fixed amount and the employer was responsible for paying any additional costs, then the portion of the rebate under the policy up to the employer s total amount of contributions during the relevant period would not be attributable to participant contributions and would not be plan assets. To the extent that an employer s portion of the rebate exceeds the employer s total premiums and other plan expenses paid (an unlikely occurrence), the excess must be held in trust for the exclusive benefit of participants and beneficiaries. Unfortunately, those scenarios do not answer the next question: We have plan assets now what? Decisions on how to apply or expend the plan's portion of a rebate are subject to ERISA's general standards of fiduciary conduct. The DOL also reiterated that the fiduciary has a duty of impartiality to the plan's participants, so no allocation method should be considered that would affect the fiduciary (in his or her role as a participant) differently than other plan participants. In deciding on an allocation method, the plan fiduciary may properly weigh the costs to the plan and the ultimate plan benefit as well as the competing interests of participants or classes of 2 Willis North America 08/12
3 participants, provided such method is reasonable, fair and objective. For example, if a fiduciary finds that the cost of distributing shares of a rebate to former participants approximates the amount of the proceeds, the fiduciary may properly decide to allocate the proceeds to current participants based upon a reasonable, fair and objective allocation method. Similarly, if distributing payments to any participants is not cost-effective (e.g., payments to participants are of de minimis amounts, or would give rise to tax consequences to participants or the plan), the fiduciary may use the rebate for other permissible plan purposes, including applying the rebate toward future participant premium payments or toward benefit enhancements. In some cases, the plan involved may have terminated before the rebate is paid to the policyholder. The DOL states that the policyholder, in handling rebates, must comply with ERISA's fiduciary provisions, including looking to the plan document to determine how assets of the plan are to be allocated upon termination. Finally, if the determination is made that the rebate does constitute plan assets, the DOL guidance provides that any distribution or premium holiday should be completed no later than the third month after receipt of the rebate from the insurer or be put in trust for the plan. GOVERNMENTAL PLANS The Department of Health and Human Services (HHS) promulgated special rules for non-erisa plans, since the DOL s rules do not apply to them. With respect to rebates paid to non-federal governmental plans, HHS indicates that the rebate may be used, at the option of the policyholder, to: 1. Reduce subscribers' portion of the annual premium for the subsequent policy year for all subscribers covered under any group health policy offered by the plan 2. Reduce subscribers' portion of the annual premium for the subsequent policy year for only those subscribers covered by the group health policy on which the rebate was based 3. Provide a cash refund only to subscribers that were covered by the group health policy on which the rebate is based In all three options, the rebate would reduce premiums or be paid to subscribers enrolled during the year in which the rebate is actually paid, rather than the MLR reporting year on which the rebate was calculated. CHURCH PLANS These HHS rules, as outlined above, apply to church plans that have not elected to be subject to ERISA. The plan sponsor could only provide the rebate to the employer if the insurer receives written assurance from the policyholder that the rebates will be used in the same way that a rebate to a non-federal governmental plan could be used. Therefore, the church plan would follow the rules set out above, or if the plan does not provide the written assurance, the insurer would pay the rebate directly to the plan participants covered by the policy, including any portion attributable to premiums paid by the employer, so the employer should consider whether the avoidance of the administrative burden outweighs the value of the rebate. WHAT PARTICIPANTS ARE INCLUDED IN THE REBATE DETERMINATION? The rules generally provide that former employees do not have to be included in the distribution of the rebate. That general rule applies for ERISA plans if the administrative costs outweigh the value of the distribution; there is no requirement to distribute the funds to the former participants. Employers should not rely on a gut determination that the costs exceed the value of the distribution, but should look at the costs and make a decision based on all the facts and circumstances and document that determination. 3 Willis North America 08/12
4 For non-federal government plans, the guidance explicitly provides that former participants do not have to be included in the distribution; that applies generally for church plans as well. (The exception is if the insurer makes the distribution to participants because the church plan sponsor has declined to provide the assurance of compliance. In that case, the insurer must provide the rebate to all participants who were in the plan during the year to which the rebate relates.) USES OTHER THAN REALLOCATION DIRECTLY TO PLAN PARTICIPANTS The guidance under the MLR provisions is not as general as prior guidance from the DOL. However, it may be that reallocating the funds directly to plan participants is administratively difficult for employers. In that circumstance, employers can use the funds to reduce plan premiums in the future or enhance benefits under the plan. That is the general rule under the prior guidance. In addition, prior guidance would permit the use of plan assets to pay the administrative expenses for the plan. That would be the most efficient use of the rebates for most employers and would likely be sanctioned by the DOL under prior guidance. However, there is no specific guidance with respect to the MLR rebates. So, that leaves a question for employers since there is no direct guidance; but under the general rules for ERISA plans, it would be a proper use of plan assets. Since the PPACA rules also require the insurer to notify participants about the rebate, the determination to use the assets in a way that would not permit participants to see a direct benefit would potentially lead them to ask questions and maybe seek other avenues to recover a portion of the rebate they feel should be allocated directly to them. Some employers may determine that, despite the general guidance on plan assets and proper uses, there are other risks to avoid and therefore will seek to take a more conservative view than they would otherwise think necessary. TAX TREATMENT If any portion of the rebate is paid to the participants, the rebate will generally be reported on the W-2 in the year it is received. That is because the participants likely paid for their share of the premium on a pre-tax basis. To the extent a portion of the rebate was paid on an after-tax basis, the rebate would not be considered taxable income and would not be reported. That would be an atypical result, but it would be possible. For instance, coverage of a domestic partner in an employer plan would likely have resulted in the use of after-tax funds to pay for a share of the employee s premium. That proportion of the rebate would be on an after-tax basis and would not be reported as taxable income. CONCLUSION Employers have to act as plan fiduciaries and make a prudent determination of the optimal method of allocation of the rebates based on the facts and circumstances. Employers should remember that the amounts that are being returned are quite small and therefore the stakes are quite small as well. It may be that the most efficient option for many employers, even if not absolute mandated by the analysis, would be to distribute the entire rebate, in cash or if easier in the form of a premium holiday, to the plan s current participants. That option may not be as appealing to employers as using the funds in another manner but sometimes those additional documentation and administrative hoops outweigh the benefit. 4 Willis North America 08/12
5 KEY CONTACTS U.S. HUMAN CAPITAL PRACTICE OFFICE LOCATIONS NEW ENGLAND Auburn, ME Bangor, ME Boston, MA Burlington, VT Hartford, CT Manchester, NH Portland, ME Shelton, CT NORTHEAST Buffalo, NY Morristown, NJ Mt. Laurel, NJ New York, NY Norwalk, CT Radnor, PA Wilmington, DE ATLANTIC Baltimore, MD Knoxville, TN Memphis, TN Metro DC Nashville, TN Norfolk, VA Reston, VA Richmond, VA Rockville, MD SOUTHEAST Atlanta, GA Birmingham, AL Charlotte, NC Gainesville, FL Greenville, SC Jacksonville, FL Marietta, GA Miami, FL Mobile, AL Orlando, FL Raleigh, NC Savannah, GA Tallahassee, FL Tampa, FL Vero Beach, FL MIDWEST Appleton, WI Chicago, IL Cleveland, OH Columbus, OH Detroit, MI Grand Rapids, MI Milwaukee, WI Minneapolis, MN Moline, IL Pittsburgh, PA Schaumburg, IL SOUTH CENTRAL Amarillo, TX Austin, TX Dallas, TX Denver, CO Houston, TX McAllen, TX Mills, WY New Orleans, LA Oklahoma City, OK Overland Park, KS San Antonio, TX Wichita, KS WESTERN Fresno, CA Irvine, CA Las Vegas, NV Los Angeles, CA Novato, CA Phoenix, AZ Portland, OR Rancho/Irvine, CA San Diego, CA San Francisco, CA San Jose, CA Seattle, WA The information contained in this publication is not intended to represent legal or tax advice and has been prepared solely for educational purposes. You may wish to consult your attorney or tax adviser regarding issues raised in this publication. 5 Willis North America 08/12
ALERT: HEALTH CARE REFORM BILL
HUMAN CAPITAL PRACTICE ALERT: HEALTH CARE REFORM BILL July 2010 Vol. 3, No. 12 REGULATIONS ON GRANDFATHERED PLANS www.willis.com As the dust settled following enactment of the health care reform law last
More informationHRFocus HR CORNER HUMAN CAPITAL PRACTICE VS. EXEMPT STATUS ANSWERED TABLE OF CONTENTS. August 2012 Issue 62.
HR CORNER HUMAN CAPITAL PRACTICE HRFocus August 2012 Issue 62 EMPLOYER Q&As ON NONEXEMPT VS. EXEMPT STATUS ANSWERED In a recent BLR webinar, Allen M. Kato outlined the importance of proper classification
More informationEmployee Benefits Alert
Employee Benefits Alert Issue 110 June 2007 The Massachusetts Health Care Reform Act: What s an Employer to Do? The Massachusetts Health Care Reform Act became law in April 2006; the July 1, 2007 effective
More informationEmployee Benefits Alert
Employee Benefits Alert September 2005 Issue No. 48 Health Saving Accounts: Comparability Rules The IRS and Treasury recently published proposed regulations concerning the comparability rules for employer
More informationEmployee Benefits Alert
Employee Benefits Alert Issue No. 21 Legal & Research Group September 2004 Benefits Brokerage & Consulting Services Rx Purchasing Coalition HR Consulting Data Analysis Benefits Administration Retirement
More informationHR Focus. HR Corner. Proposed EEO-1 Amendment to Include Pay Data Have you Heard? March 2016
HR Focus March 2016 HR Corner Proposed EEO-1 Amendment to Include Pay Data Have you Heard? By: Marina A. Galatro, PHR-CA, SHRM-CP Sr. HR Consultant, HR Partner On January 29, 2016, the Equal Employment
More informationHIGH AND WIDE: INCOME INEQUALITY GAP IN THE DISTRICT ONE OF BIGGEST IN THE U.S. By Wes Rivers
An Affiliate of the Center on Budget and Policy Priorities 820 First Street NE, Suite 510 Washington, DC 20002 (202) 408-1080 Fax (202) 325-8839 www.dcfpi.org March 13, 2014 HIGH AND WIDE: INCOME INEQUALITY
More information50-State Property Tax Comparison Study: For Taxes Paid in Executive Summary
50-State Property Tax Comparison Study: For Taxes Paid in 2017 Executive Summary By Lincoln Institute of Land Policy and Minnesota Center for Fiscal Excellence April 2018 As the largest source of revenue
More informationEmployee Benefits Alert
Legal & Research Group Employee Benefits Alert Issue No. 40 June 2005 Legislative & Compliance Benefits Brokerage & HR Consulting Services Rx Purchasing Coalition Data Analysis Benefits Administration
More informationMedicare Secondary Payer Rules Tighter Enforcement?
Executive Signal Issue 5 October 2007 Medicare Secondary Payer Rules Tighter Enforcement? Earlier this year the White House web site featured an article outlining President Bush s proposed budget for 2008.
More informationERRATA. To: Recipients of MG-388-RC, Estimating Terrorism Risk, RAND Corporation Publications Department. Date: December 2005
ERRATA To: Recipients of MG-388-RC, Estimating Terrorism Risk, 25 From: RAND Corporation Publications Department Date: December 25 Re: Corrected pages (pp. 23 24, Table 4.1,, Density, Density- Weighted,
More informationEmployee Benefits Alert
Employee Benefits Alert December 2005 Issue No. 54 UnumProvident Settlement to Affect All California Disability Insurers Executive Summary A recent settlement of a case filed by the California Department
More informationAEI Center on Housing Markets and Finance Announces Ten Best and Worst Metro Areas to Be a First Time Homebuyer
AEI Center on Housing Markets and Finance Announces Ten Best and Worst Metro Areas to Be a First Time Homebuyer Edward Pinto and Tobias Peter November 28th, 2018 New AEI study ranks 50 metros by home price
More informationEmployee Benefits Alert
Legal & Research Group Benefits Alert Issue No. 24 October 2004 Benefits Brokerage & Consulting Services Rx Purchasing Coalition HR Consulting Data Analysis Benefits Administration Retirement Services
More informationData Brief. Trends in Employer-Sponsored Health Insurance Premiums and Employee Contributions in Major Metropolitan Areas,
December 2012 Data Brief Trends in Employer-Sponsored Health Insurance Premiums and Employee Contributions in Major Metropolitan Areas, 2003 2011 The mission of The Commonwealth Fund is to promote a high
More informationFOR IMMEDIATE RELEASE Contact: Ann Marie Gorden/Robert Nihen
cutting through complexity News FOR IMMEDIATE RELEASE Contact: Ann Marie Gorden/Robert Nihen June 24, 2014 KPMG LLP 201-505-6288/201-307-8296 agorden@kpmg.com / rnihen@kpmg.com CINCINNATI, CLEVELAND, ATLANTA
More informationOffice. Office. IRR Viewpoint 2015
IRR Viewpoint 05 Above: Designed in 95 in the Art Deco style by architect Timothy Pflueger as the Pacific Telephone and Telegraph Building, 40 New Montgomery Street, San Francisco, CA has been the subject
More informationehealth Inventory Report of Major Medical Health Plans Available Off of Government Exchanges
ehealth Inventory Report of Major Medical Health Available Off of Government Exchanges February 2014 Introduction Beginning January 1, 2014, all new major medical health insurance plans were required to
More informationMattress Firm s Pending Acquisition of Sleepy s November 30, 2015
Mattress Firm s Pending Acquisition of Sleepy s November 0, 2015 Forward Looking Statements and Non-GAAP Information This presentation contains forward-looking statements within the meaning of federal
More informationHRFocus HR CORNER HUMAN CAPITAL PRACTICE. EMPLOYERS HAVE A DIRECT IMPACT ON EMPLOYEE JOB SATISFACTION SAYS NEW SURVEY This article provided by BLR
HR CORNER HUMAN CAPITAL PRACTICE HRFocus December 2013 www.willis.com EMPLOYERS HAVE A DIRECT IMPACT ON EMPLOYEE JOB SATISFACTION SAYS NEW SURVEY This article provided by BLR A survey of employees in Canada
More informationMetroMonitor Tracking Economic Recession and Recovery in America s 100 Largest Metropolitan Areas
MetroMonitor Tracking Economic Recession and Recovery in America s 100 Largest Metropolitan Areas Howard Wial and Richard Shearer June 2011 (Updated on June 24, 2011) With job growth slowing and housing
More informationTRUCKERS APPLICATION
DEEP SOUTH TRUCKERS APPLICATION PROPOSAL FORM - PRIMARY COVERAGE/COMMERCIAL TRUCKMEN REQUIRED FOR 10 OR MORE POWER UNITS THAT ARE ICC REGULATED **IMPORTANT - PLEASE NOTE** ALL ITEMS MUST BE COMPLETED IN
More informationFILED: NEW YORK COUNTY CLERK 12/22/ :58 AM INDEX NO /2013 NYSCEF DOC. NO. 95 RECEIVED NYSCEF: 12/22/2017
Buckingham Badler Assoc., Inc. 286 Richmond Valley Road Staten Island, NY 10309 09/20/2011 Attention: Celeste Regarding: Allerand LLC 500 Greenwich Street #401 New York, NY 10013 Quote Number: XX582725
More informationD E E P S O U T H O F T E N N E S S E E
5 410 MARYLAND WAY, SUITE 41 0, B RENTWOOD, TN 3 7027 P H O N E : 6 1 5. 8 3 2. 8 9 0 0 o r 8 8 8. 8 3 2. 8 9 0 0 F A X : 6 1 5. 8 3 2. 5 4 3 4 o r 8 8 8. 8 3 2. 8 9 0 1 TRUCKERS APPLICATION PROPOSAL FORM
More informationUS Hotel Industry Overview. Chris Crenshaw
US Hotel Industry Overview Chris Crenshaw ccrenshaw@str.com July 2014 (12 MMA): All Signs Point To A Sellers Market % Change Room Supply* 1.8 bn 0.8% Room Demand* 1.1 bn 3.4% Occupancy 63 % 2.6% A.D.R.*
More informationTax Rates and Tax Burdens in the District of Columbia - A Nationwide Comparison
Government of the District of Columbia Natwar M. Gandhi Chief Financial Officer Tax Rates and Tax Burdens in the District of Columbia - A Nationwide Comparison 2010 Issued September 2011 Tax Rates and
More informationHRFocus LEGAL & COMPLIANCE EMPLOYEE BENEFITS DOL PUBLISHES MODEL COBRA SUBSIDY NOTICES BACKGROUND
EMPLOYEE BENEFITS HRFocus April 2009 Issue 22 LEGAL & COMPLIANCE DOL PUBLISHES MODEL COBRA SUBSIDY NOTICES www.willis.com New COBRA subsidies for employees and new notification mandates for employers are
More informationFOCUS On Benefits January, 2007
In This Issue San Francisco Workers Granted Paid Sick Time Family Deductibles That Permit HDHP Coverage Clear SPDs Required Elder Care Benefits California Modifies Sexual Harassment Training Eligibility
More informationReverse Market Insight, Inc Acero, Suite 140, Mission Viejo, CA (682) HECM Lenders (FHA Approved Only) Competition Growth -6.
Reverse Market Insight, Inc. 25910 Acero, Suite 140, Mission Viejo, CA (682) 651-5632 HECM (FHA Approved Only) Industry Overview HECMs Endorsed through June Next Release Date: Week 1 of August Endorsement
More informationHRFocus HR CORNER HUMAN CAPITAL PRACTICE
HR CORNER HUMAN CAPITAL PRACTICE HRFocus September 2015 www.willis.com FORMULA RETAIL EMPLOYEE RIGHTS ORDINANCE GOT EMPLOYEES IN SAN FRANCISCO? By Marina A. Galatro, PHR-CA, SHRM-CP Sr. HR Consultant,
More informationHRFocus LEGAL & COMPLIANCE EMPLOYEE BENEFITS STIMULUS PACKAGE BRINGS CHANGES TO COBRA COBRA SUBSIDY
EMPLOYEE BENEFITS HRFocus March 2009 Issue 21 www.willis.com LEGAL & COMPLIANCE STIMULUS PACKAGE BRINGS CHANGES TO COBRA While the impact of the massive economic stimulus legislation on the current recession
More informationPORTFOLIO REVENUE EXPENSES PERFORMANCE WATCHLIST
July 2018 ASSET MANAGEMENT Low-Income Housing Tax Credit Portfolio Trends Analysis Enterprise s Low-Income Housing Tax Credit (LIHTC) Portfolio Trends Analysis provides important information to our management
More informationFOCUS On Benefits June, 2006
In This Issue CMS Disclosure Notices Revised IRS Issues Proposed Regulations Governing DCAP Redefining Dependent Child Laws Health Savings Accounts Gaining Popularity States Examining Medicaid Programs
More informationALERT: HEALTH CARE REFORM BILL
HUMAN CAPITAL PRACTICE ALERT: HEALTH CARE REFORM BILL April 2010 Vol. 3, No. 3 FIRST THINGS FIRST: HEALTH CARE REFORM IN 2010 AND 2011 www.willis.com The parts of health care reform getting the most fanfare
More information2018 National Electric Rate Study
2018 National Electric Rate Study Ranking of Typical Residential, Commercial and Industrial Electric Bills LES Administrative Board June 15, 2018 Emily N. Koenig Director of Finance & Rates 1 Why is the
More informationReverse Market Insight, Inc Acero, Suite 140, Mission Viejo, CA (682) HECM Lenders (FHA Approved Only) Competition Growth -4.
Reverse Market Insight, Inc. 25910 Acero, Suite 140, Mission Viejo, CA (682) 651-5632 HECM (FHA Approved Only) Industry Overview HECMs Endorsed through December Next Release Date: Week 1 of February Endorsement
More informationReverse Market Insight, Inc Acero, Suite 140, Mission Viejo, CA (682) HECM Lenders (FHA Approved Only) Competition Growth -6.
Reverse Market Insight, Inc. 25910 Acero, Suite 140, Mission Viejo, CA (682) 651-5632 HECM (FHA Approved Only) Industry Overview HECMs Endorsed through January Next Release Date: Week 1 of March Endorsement
More informationReverse Market Insight, Inc Acero, Suite 140, Mission Viejo, CA (682) HECM Lenders (FHA Approved Only) Competition Growth -6.
Reverse Market Insight, Inc. 25910 Acero, Suite 140, Mission Viejo, CA (682) 651-5632 HECM s (FHA Approved Only) Industry Overview HECMs Endorsed through March Next Release Date: Week 1 of May Endorsement
More informationFINANCIAL STATE OF THE CITIES
FINANCIAL STATE OF THE CITIES An Annual Report by Truth in Accounting www.statedatalab.org January 2019 1 Table of Contents Executive Summary 4 Introduction and Background 5 Summary of Findings 6 Sunshine
More informationHRFocus HR CORNER HUMAN CAPITAL PRACTICE
HR CORNER HRFocus June 2015 THE NEW CALIFORNIA FAMILY RIGHTS ACT BY MARINA A. GALATRO, PHR-CA, SHRM-CP SENIOR HUMAN RESOURCES CONSULTANT WILLIS HUMAN CAPITAL PRACTICE HUMAN CAPITAL PRACTICE www.willis.com
More informationINDUSTRIAL REPORT VIEWPOINT 2017 / COMMERCIAL REAL ESTATE TRENDS. By: Hugh F. Kelly, PhD, CRE. irr.com. An Integra Realty Resources Publication
INDUSTRIAL REPORT VIEWPOINT 2017 / COMMERCIAL REAL ESTATE TRENDS By: Hugh F. Kelly, PhD, CRE Growing Consumption Fuels the Industrial Sector IRR research indicates that more than half of U.S. industrial
More informationReverse Market Insight, Inc Acero, Suite 140, Mission Viejo, CA (682) HECM Lenders (FHA Approved Only) Competition Growth -10.
Reverse Market Insight, Inc. 25910 Acero, Suite 140, Mission Viejo, CA (682) 651-5632 HECM (FHA Approved Only) Industry Overview HECMs Endorsed through August Next Release Date: Week 1 of October Endorsement
More informationTrends in Total and Out-of- Pocket Spending in Metro Areas:
Trends in Total and Out-of- Pocket Spending in Metro Areas: 2012-2015 It is well-documented that health care prices vary widely by geography. 1 These variations can also lead to differences in health care
More informationEconomic Risks and Their Meaning for the Southwest STEVE COCHRANE, MANAGING DIRECTOR
Economic Risks and Their Meaning for the Southwest STEVE COCHRANE, MANAGING DIRECTOR The Europeans Are All-in Composition of the European Central Bank s balance sheet, bil 5,000 Other assets Emergency
More informationNAREIT Investor Conference Summary of Public Storage/Shurgard Merger
THE MOST RECOGNIZED BRANDS IN SELF-STORAGE NAREIT Investor Conference Summary of Public Storage/Shurgard Merger June 6-8, 2006 page 1 Disclosures Forward-Looking Statements This presentation contains forward-looking
More informationAmerican Jobs Act - Preventing Teacher Layoffs Estimated Jobs Impact by State
American Jobs Act - Preventing Teacher Layoffs Estimated Jobs Impact by Funds Allocated Estimate of Jobs Supported for 1 School Year Alabama $ 451,477,775 7,000 Alaska $ 70,483,533 900 Arizona $ 625,502,087
More informationExecutive Summary. Introduction
Date: Regarding: 2014-2017 United States Animal Loss Claims (External Dissemination) Prepared by: David Fennig, Strategic Analyst Executive Summary The purpose of this ForeCAST SM is to analyze claims
More informationEquity LifeStyle Properties
Equity LifeStyle Properties Colony Cove Ellenton, FL OUR STORY One of the nation s largest real estate networks with 383 properties containing over 142,000 sites in 32 states and British Columbia Unique
More informationRegional Snapshot: The Cost of Living in Metro Atlanta
Regional Snapshot: The Cost of Living in Metro Atlanta Photo by rawpixel.com on Unsplash Atlanta Regional Commission, February 2018 For more information, contact: cdegiulio@atlantaregional.org In Summary
More informationComparative Revenues and Revenue Forecasts Prepared By: Bureau of Legislative Research Fiscal Services Division State of Arkansas
Comparative Revenues and Revenue Forecasts 2010-2014 Prepared By: Bureau of Legislative Research Fiscal Services Division State of Arkansas Comparative Revenues and Revenue Forecasts This data shows tax
More informationequity advisory services
CAPABILITIES equity advisory services YOUR SINGLE POINT OF CONTACT FOR THE ENTIRE CAPITAL STACK Better relationships. Better results. EQUITY VOLUME BY PROPERTY TYPE Our close relationships with debt providers
More informationCarroll Co-Invest Fund II, LP Investor Update, Q4 2013
Carroll Co-Invest Fund II, LP Investor Update, Q4 2013 January 31, 2014 We are pleased to report that Carroll Co-Invest Fund II experienced a successful 4th quarter 2013. Our work at ARIUM Resort, Carroll
More informationPRODUCER ANNUITY SUITABILITY TRAINING REQUIREMENTS BY STATE As of September 11, 2017
PRODUCER ANNUITY SUITABILITY TRAINING REQUIREMENTS BY STATE As of September 11, 2017 This document provides a summary of the annuity training requirements that agents are required to complete for each
More informationRelationships. Results. COMPANY OVERVIEW COMMERCIAL REAL ESTATE DEBT, EQUITY & SERVICING
Relationships. COMPANY OVERVIEW Results. COMMERCIAL REAL ESTATE DEBT, EQUITY & SERVICING COMMERCIAL REAL ESTATE DEBT, EQUITY & SERVICING Relationships. Results. For more than 50 years, NorthMarq Capital
More informationReverse Market Insight, Inc PCH, Suite D4, Dana Point, CA (682) HECM Lenders (FHA Approved Only) Competition Growth 43.
Reverse Market Insight, Inc. 34232 PCH, Suite D4, Dana Point, CA (682) 651-5632 HECM (FHA Approved Only) Industry Overview HECMs Endorsed through February Next Release Date: Week 1 of April Endorsement
More informationReverse Market Insight, Inc Acero, Suite 140, Mission Viejo, CA (682) HECM Lenders (FHA Approved Only) Competition Growth 1.
Reverse Market Insight, Inc. 25910 Acero, Suite 140, Mission Viejo, CA (682) 651-5632 HECM s (FHA Approved Only) Industry Overview HECMs Endorsed through February Next Release Date: Week 1 of April Endorsement
More informationReverse Market Insight, Inc Acero, Suite 140, Mission Viejo, CA (682) HECM Lenders (FHA Approved Only) Competition Growth 10.
Reverse Market Insight, Inc. 25910 Acero, Suite 140, Mission Viejo, CA (682) 651-5632 HECM (FHA Approved Only) Industry Overview HECMs Endorsed through January Next Release Date: Week 1 of March Endorsement
More informationequity advisory services
CAPABILITIES equity advisory services YOUR SINGLE POINT OF CONTACT FOR THE ENTIRE CAPITAL STACK Better relationships. Better results. EQUITY VOLUME BY PROPERTY TYPE Our close relationships with debt providers
More informationU.S. Investment Outlook
U.S. Investment Outlook Quarterly Investor Research update Q2 2015 U.S. Investment overview 37% 21% 15% 15% U.S. cities dominating global investment activity Top 20 Cities for Transactional Volumes H1
More informationState of the U.S. Multifamily Market. Q Review and Forecast
State of the U.S. Multifamily Market Q1 2015 Review and Forecast Agenda Economy Leasing Fundamentals Rent and NOI Trends Single-Family Market Capital Markets Economy page 3 GDP Growth Contributions To
More informationCAPITALIZATION RATES BY PROPERTY TYPE
RATES BY PROPERTY TYPE MID-YEAR 2014 0 RATES BY ASSET TYPE MID-YEAR 2014 O V E R V I E W Capital continues to flow steadily into the U.S. real estate market, as both domestic and foreign investors increase
More information2014 U.S. Census (2015) Median African-American Household Income Rank, Memphis Included. Household Median Income Ranking, African American Population
2015 2015 Rankings Report Prepared by Elena Delavega, PhD, MSW Department of Social Work Benjamin L. Hooks Institute for Social Change University of Memphis 2014 U.S. Census (2015) - Rank, Memphis Included
More informationRelationships. Results. COMPANY OVERVIEW COMMERCIAL REAL ESTATE DEBT, EQUITY & SERVICING
Relationships. COMPANY OVERVIEW Results. COMMERCIAL REAL ESTATE DEBT, EQUITY & SERVICING C O M M E R C I A L R E A L E S TAT E D E B T, E Q U I T Y & S E R V I C I N G Relationships. Results. For more
More informationCounty of Sonoma Agenda Item Summary Report
Revision No. 20151201-1 County of Sonoma Agenda Item Summary Report Agenda Item Number: 31h (This Section for use by Clerk of the Board Only.) Clerk of the Board 575 Administration Drive Santa Rosa, CA
More informationReverse Market Insight, Inc PCH, Suite D4, Dana Point, CA (682) HECM Lenders (FHA Approved Only) Competition Growth -8.
Reverse Market Insight, Inc. 34232 PCH, Suite D4, Dana Point, CA (682) 651-5632 HECM s (FHA Approved Only) Industry Overview HECMs Endorsed through November Next Release Date: Week 1 of January Endorsement
More informationAffordable Coverage: Short-Term Health Insurance and the ACA
Affordable Coverage: Short-Term Health Insurance and the ACA JULY 2018 2 Short-Term Health Plan s Cost 80 Percent Less than Obamacare Plans, ehealth Analysis Finds Short-term health insurance premiums
More informationFOCUS On Benefits March, 2007
In This Issue Congress Caps Deferred Comp? FMLA: Persistent Employer Pain On-Site Health Clinics: Cost Cutting Tool? Stronger Oversight of 401(k)s Does Medicare Bonus Improve Quality? Update: Massachusetts
More informationReverse Market Insight, Inc PCH, Suite D4, Dana Point, CA (682) HECM Lenders (FHA Approved Only) Competition Growth -6.
Reverse Market Insight, Inc. 34232 PCH, Suite D4, Dana Point, CA (682) 651-5632 HECM s (FHA Approved Only) Industry Overview HECMs Endorsed through March Next Release Date: Week 1 of May Endorsement Growth
More informationCost and Coverage Implications of the ACA Medicaid Expansion: National and State by State Analysis
Cost and Coverage Implications of the ACA Medicaid Expansion: National and State by State Analysis Report Authors: John Holahan, Matthew Buettgens, Caitlin Carroll, and Stan Dorn Urban Institute November
More informationProperty Tax Relief in New England
Property Tax Relief in New England January 23, 2015 Adam H. Langley Senior Research Analyst Lincoln Institute of Land Policy www.lincolninst.edu Property Tax as a % of Personal Income OK AL IN UT SD MS
More informationEmployee Benefits Alert
Employee Benefits Alert Issue No. 10 Legal & Research Group January 2004 Benefits Brokerage & Consulting Services Rx Purchasing Coalition HR Consulting Data Analysis Benefits Administration Retirement
More informationOlder consumers and student loan debt by state
August 2017 Older consumers and student loan debt by state New data on the burden of student loan debt on older consumers In January, the Bureau published a snapshot of older consumers and student loan
More informationReverse Market Insight, Inc PCH, Suite D4, Dana Point, CA (682) HECM Lenders (FHA Approved Only) Competition Growth 10.
Reverse Market Insight, Inc. 34232 PCH, Suite D4, Dana Point, CA (682) 651-5632 HECM s (FHA Approved Only) Industry Overview HECMs Endorsed through July Next Release Date: Week 1 of September Endorsement
More informationFOCUS On Benefits July, 2006
In This Issue Voluntary Correction Program Changes Variations on Mandating Health Coverage EEOC Falters in Effort To Keep Up Capping Cancer Drug Costs Costly Healthcare Prevents Enrollment Are COBRA Premium
More informationReverse Market Insight, Inc PCH, Suite D4, Dana Point, CA (682) HECM Lenders (FHA Approved Only) Competition Growth -20.
Reverse Market Insight, Inc. 34232 PCH, Suite D4, Dana Point, CA (682) 651-5632 HECM s (FHA Approved Only) Industry Overview HECMs Endorsed through April Next Release Date: Week 1 of June Endorsement Growth
More informationLocal Anesthesia Administration by Dental Hygienists State Chart
Education or AK 1981 General Both Specific Yes WREB 16 hrs didactic; 6 hrs ; 8 hrs lab AZ 1976 General Both Accredited Yes WREB 36 hrs; 9 types of AR 1995 Direct Both Accredited/ Board Approved No 16 hrs
More informationStructured Finance. U.S. RMBS Sustainable Home Price Report. First-Quarter 2017 Update Special Report RMBS / U.S.A.
U.S. RMBS Sustainable Home Price Report First-Quarter 2017 Update Special Report RMBS / U.S.A. U.S. Prices Grow at a Sustainable Pace: National inflation-adjusted home prices continue to grow at a rate
More informationMaximizing Network Opportunities. March 22, 2018
Maximizing Network Opportunities March 22, 2018 Our vision Better cost controls CREATE networks tailored to each market s unique needs and competitive cost structure HEALT H TRIPLE AIM Better experience
More informationUS CAPITAL MARKETS REPORT
US CAPITAL MARKETS REPORT Capitalization Rates By Property Type Fall 2016 US Capital Markets Report Capitalization Rates By Asset Type OVERVIEW Year-to-date investment sales volume lagged on a year-over-year
More informationMEETING OF THE WQA ADMINISTRATIVE/FINANCE COMMITTEE
MEETING OF THE WQA ADMINISTRATIVE/FINANCE COMMITTEE TO BE HELD ON TUESDAY, MARCH 12, 2013 AT 12:00 P.M. AT 1720 W. CAMERON AVE., SUITE 100, WEST COVINA, CA 91790 AGENDA WQA Committee Members: Watermaster
More informationEurope June Carol Tomé Executive Vice President, Corporate Services & Chief Financial Officer. Diane Dayhoff Vice President, Investor Relations
Europe June 2017 Carol Tomé Executive Vice President, Corporate Services & Chief Financial Officer Diane Dayhoff Vice President, Investor Relations Forward Looking Statements and Non-GAAP Financial Measurements
More informationAdministrative handbook Aetna Funding Advantage SM
Quality health plans & benefits Healthier living Financial well-being Intelligent solutions Administrative handbook Aetna Funding Advantage SM For self-insured groups with less than 100 eligible employees
More informationTERRORISM RISK INSURANCE PROGRAM 2018 DATA CALL: CAPTIVE INSURERS INSURER GROUP AFFILIATIONS
OMB No. 15050257 Expiration: INSURER GROUP AFFILIATIONS B C G H Group Code (NAIC or as 3 assigned by Aggregator) Insurer Group Name 3 Total 2016 Policyholder Surplus: 4 4 Total 2016 TRIPEligible DEP (all
More information2018 NORTH AMERICAN CONSTRUCTION FORECAST REPORT
2018 NORTH AMERICAN CONSTRUCTION FORECAST REPORT Published October 2017 Oldcastle Business Intelligence TABLE OF CONTENTS Executive Summary... 2 U.S. Economic Overview... 3 U.S. Construction Forecast...
More informationZurich Surety. Capabilities you can count on
Zurich Surety Capabilities you can count on 2 Capabilities you can count on That s Zurich. We have the global footprint, surety and construction industry expertise and meaningful surety capacity to help
More informationAustralia/Asia July Diane Dayhoff Vice President, Investor Relations. Lyndsey Burton Senior Manager, Investor Relations
Australia/Asia July 2017 Diane Dayhoff Vice President, Investor Relations Lyndsey Burton Senior Manager, Investor Relations Forward Looking Statements and Non-GAAP Financial Measurements Certain statements
More information2017 Supplemental Tax Information
2017 Supplemental Tax Information We have compiled the following information to help you prepare your 2017 federal and state tax returns: - Percentage of income from U.S. government obligations - Federal
More informationFOCUS On Benefits February, 2006
In This Issue USERRA Compliance Reporting Creditable Coverage Status Mental Health Parity Law Extended IRS Announces 2006 Mileage Rates HSA Contributions and Grace Period Coordination Retiree Prescription
More informationAlternative Paths to Medicaid Expansion
Alternative Paths to Medicaid Expansion Robin Rudowitz Kaiser Commission on Medicaid and the Uninsured Kaiser Family Foundation National Health Policy Forum March 28, 2014 Figure 1 The goal of the ACA
More informationFiduciary Tax Returns
Functions and Procedures Index Books On Line Main Directory Overview... 2 How does it work?... 3 What Information is transmitted to the Tax Service?... 4 How do I initiate this service?... 8 Do I have
More informationFOR IMMEDIATE RELEASE February 8, 2012
Contact Information Below CoreLogic Reports 830,000 Completed s Nationally in 2011, a Decrease of 24 Percent from One Year Ago 1.4 Million Homes in the Inventory at the End of 2011 SANTA ANA, Calif., CoreLogic
More informationPlease print using blue or black ink. Please keep a copy for your records and send completed form to the following address.
20 Disbursement for Beneficiary/QDRO Account IBEW Local Union No. 716 Retirement Plan Instructions About You Please print using blue or black ink. Please keep a copy for your records and send completed
More informationSafe Harbor Caution Concerning Forward-Looking Statements Non-GAAP Financial Measures Important Information For Investors And Shareholders
February 13, 2014 Safe Harbor Caution Concerning Forward-Looking Statements Certain statements in this communication regarding the proposed acquisition of Time Warner Cable Inc. ( Time Warner Cable ) by
More informationThe Acquisition of Regions Insurance Group. April 6, 2018
The Acquisition of Regions Insurance Group April 6, 2018 Forward-Looking Statements This presentation contains "forward-looking statements" within the meaning of the Private Securities Litigation Reform
More informationSmall Business Sale Prices Reach Record Highs to Start 2018
Small Business Sale s Reach Record Highs to Start 2018 BizBuySell.com's First Quarter 2018 Insight Report shows a recordbreaking quarter for the business-for-sale market for sales prices and completed
More informationThe Consequences of Mortgage Credit Expansion. What is the Nature of the Mortgage Default Crisis?
The Consequences of Mortgage Credit Expansion Atif Mian Amir Sufi University Chicago GSB October 2008 What is the Nature of the Mortgage Default Crisis? 1 Mortgage Defaults, 2005 to 2007 Prime versus Subprime
More information2016 Workers compensation premium index rates
2016 Workers compensation premium index rates NH WA OR NV CA AK ID AZ UT MT WY CO NM MI VT ND MN SD WI NY NE IA PA IL IN OH WV VA KS MO KY NC TN OK AR SC MS AL GA TX LA FL ME MA RI CT NJ DE MD DC = Under
More informationSunTrust Banks, Inc. James M. Wells III President and Chief Operating Officer
SunTrust Banks, Inc. James M. Wells III President and Chief Operating Officer The following should be read in conjunction with the financial statements, notes and other information contained in the Company
More informationTHE MOST RECOGNIZED BRAND IN SELF-STORAGE
THE MOST RECOGNIZED BRAND IN SELF-STORAGE Forward-Looking Statements This presentation contains "forward-looking statements" within the meaning of Section 27A of the Securities Act of 1933 and Section
More informationSCHIP: Let the Discussions Begin
Figure 0 SCHIP: Let the Discussions Begin Diane Rowland, Sc.D. Executive Vice President, Henry J. Kaiser Family Foundation and Executive Director, Kaiser Commission on for Alliance for Health Reform February
More information