HRFocus HR CORNER HUMAN CAPITAL PRACTICE

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1 HR CORNER HUMAN CAPITAL PRACTICE HRFocus September FORMULA RETAIL EMPLOYEE RIGHTS ORDINANCE GOT EMPLOYEES IN SAN FRANCISCO? By Marina A. Galatro, PHR-CA, SHRM-CP Sr. HR Consultant, Willis HR Partner Willis North America Human Capital Practice The San Francisco Board of Supervisors, the legislative branch of the City and County of San Francisco, passed two ordinances on November 25, 2014 that became effective on July 3, The ordinances, also known as the Retail Workers Bill of Rights, regulate hours, retention, scheduling and treatment of part-time employees at formula retail establishments. The ordinances are classified as: Hours and Retention Protections for Formula Retail Employees Ordinance (San Francisco Police Code Article 33F) Predictable Scheduling and Treatment of Formula Retail Employees Ordinance (San Francisco Police Code Article 33G) COVERED EMPLOYERS The laws apply to formula retail establishments (or chain stores) with at least 40 formula retail establishments worldwide and 20 or more employees in San Francisco as well as their janitorial and security contractors. Note: the original ordinance stated establishments with at least 20 formula retail establishments worldwide, but an amendment was passed on July 7, 2015 to change that number to 40 (effective August 14th). ARE YOU A COVERED EMPLOYER? The ordinance defines formula retail establishment as a retail or service business with any two of the following: A standardized array of merchandise A standardized façade A standardized décor and color scheme Uniform apparel Standardized signage A trademark or service mark HR CORNER Formula Retail Employee Rights Ordinance... Got Employees in San Francisco?... 1 HEALTH OUTCOMES Doing The Math On Medical Costs: The Pareto Principle...5 LEGAL AND COMPLIANCE New Trade Law Increases ACA Reporting Penalties...7 MLR Rebate Reminder...9 Health Coverage Tax Credit Returns WEBCASTS CONTACTS Continued on page 2 1

2 HR Corner continued from page 1 Following are some of the establishments that may fall under the formula retail use definition: Amusement and game arcade Bar Eating and drinking use Financial service Liquor store Massage establishment Movie theatre Restaurant (large fast food, small self-service, fullservice, specialty food) Sales and service (including retail) For more information about what qualifies as a formula retail use, click here. WHAT DO THESE ORDINANCES MEAN TO YOU? The Hours and Retention Protections for Formula Retail Employees ordinance requires formula retail establishments to offer additional hours of work, when available, to current part-time employees. Therefore, before hiring new employees, contractors or temporary employees, employers must offer additional work to current part-time employees if qualified and if work is the same or similar. one hour of pay for each shift change, at the employee s regular hourly rate. If the employer changes the employee s schedule with fewer than 24 hours notice, the employer must provide two hours of pay if the changed shift is four hours or less or four hours of pay if the changed shift is longer than four hours, at the employee s regular hourly rate. PAY FOR ON-CALL SHIFTS If an employee is required to be on-call, but is not called in to work, the employer must provide the employee with two hours of pay if the on-call shift lasted four hours or less, or four hours of pay if the on-call shift exceeded four hours. If the employer provides at least 24 hours notice that the on-call shift has been cancelled or moved to another date, then the employer will not be required to provide this compensation to the employee. The ordinance also requires successor employers to retain employees for 90 days upon a change in control of the business. The Predictable Scheduling and Treatment of Formula Retail Employees ordinance requires formula retail establishments to provide employees with two weeks notice of work schedules, notice of changes to work schedules, and compensation (predictability pay) for schedule changes made on fewer than seven days notice and for unused on-call shifts. This ordinance also provides part-time employees with the same starting rate of hourly pay, access to paid and unpaid time off, and eligibility for promotions, as is provided to full-time employees in similar positions. WHAT IS PREDICTABILITY PAY? If changes are made to an employee s schedule with fewer than seven days notice but more than 24 hours notice, the employer must provide the employee with 2 Continued on page 3

3 HR Corner continued from page 2 EXCEPTIONS TO PREDICTABILITY PAY AND PAY FOR ON-CALL SHIFTS Employers do not have to provide predictability pay or payment for on-call shifts if any of the following conditions apply: Operations cannot begin or continue due to threats to employees or property Operations cannot begin or continue because public utilities fail Operations cannot begin or continue due to an act of God or other cause not within the employer s control (such as an earthquake) Another employee previously scheduled to work that shift is unable to work and did not provide at least seven days notice Another employee failed to report to work or was sent home The employer requires the employee to work overtime The employee trades shifts with another employee or requests a change in shifts WORKPLACE POSTING Formula retail establishments are required to post a notice at the workplace informing covered employees of their rights under the new laws. This notice must be posted in a conspicuous place at any workplace or job site where any of its covered employees works. Please note that the pending amendment could require a change to the notice. NEED MORE INFORMATION? There is a great deal of information on the Formula Retail Employee Rights Ordinances on the City & County of San Francisco Office of Labor Standards Enforcement (OLSE) website, including the amendment text, downloadable notice, FAQs, fact sheet, a presentation overview, and contact information should you need further assistance. You can also sign up for the Formula Retail Employee Rights Ordinances list to receive updates about the Ordinances, amendments, new guidance, and additional resources. 3

4 HEALTH OUTCOMES DOING THE MATH ON MEDICAL COSTS: THE PARETO PRINCIPLE By Ronald Leopold, MD, MBA, MPH Practice Leader, Health Outcomes, Willis Human Capital Practice Twenty percent of a population accounts for 80% of its medical costs. This ratio is known as the Pareto Principle, named after the Italian economist Vilfredo Pareto, who, in 1906, found that 80% of the land in Italy was owned by 20% of the population. What is most important about Pareto s finding was that this 80/20 distribution occurs extremely frequently in what we do. 20% of your customers represent 80% of your sales. And 20% of your time produces 80% of your results. And so on.1 Since Pareto published these findings, the magical ratio of 80/20 (or the 80/20 rule ) has been scattered throughout society and nature: 80% of any company s profits come from 20% of their best products. 80% of traffic comes from 20% of roads. 80% of food production comes from 20% of the best crops. The ratio is everywhere frequently even tipped to a 90/10 or 95/5 division.2 It is also a widely recognized and powerful driver of health care costs. A basic understanding of health care spending for a large group is that not all people are alike. Recognizing that a relatively small minority of individuals drives the overwhelming majority of costs is fundamental to understanding how medical services are consumed. Taking this principle further, we often divide a population into three groups, based on cost stratification. What is remarkable is that the cost stratification of 1,000 members of a health plan for an automobile parts manufacturer in Kenosha, WI shows remarkable similarity to a similar analysis for the same size population of a department store in Abilene, Texas. In fact, we can depend on the fact that any population of health plan members falls into three predictable cohorts. The first cohort comprises 70% of a population that typically drives only 7% of the overall health care costs of a population. Most members of a health plan spend relatively few dollars. In fact, typically 15-18% of the members of a medical plan will spend zero dollars in a given calendar year. The 70% tend to be relatively younger, lower risk individuals. In that group, however, are also individuals who have delayed health care or not adequately addressed significant health risks. Lapses in critical preventive screening may reside in this cohort. The importance of focusing on wellness, prevention and primary care is vital to keeping this generally healthy population low cost in the future. Continued on page 5 4

5 Health Outcomes continued from page 5 On the other hand, 25% of a population drives a disproportionate share (35%) of the costs. The 25% are often individuals who have higher risks and are actively engaged in treatment. Acute conditions resulting in relatively time-limited medical spending often make up some of this group. Individuals with chronic conditions who are seeking medical care are also in this group. Understanding this group and following cost trends, utilization trends, risk stratification and gaps in care for a population form a key population health strategy. Perhaps most importantly, 5% of a population drives, on average, 58% of the medical coasts of a population. 5 So, who are these individuals, and what conditions account for these expenditures? A recent analysis of Willis health care data reveals that the majority of these expenditures are accountable by the following conditions: Osteoarthritis Pregnancy Complications Intervertebral Disc Disorders Breast Cancer Coronary Artery Disease Joint Derangement Complicated Gastrointestinal Disorders Cancer Therapies Procedure Complications Gynecological Disorders Demyelinating Diseases Myocardial Infarction Back Pain Musculoskeletal Disorders Lower GI Disorders Rheumatoid Arthritis Diabetes Mellitus Gall Bladder Diseases Renal Failure Newborn Care It is also important to note that pharmacy costs, in particular specialty pharmacy costs, are emerging as powerful drivers of higher medical costs in a population. Look for the specialty pharmacy category to play an even greater role in the highest cost cohort in the coming years. SO WHAT DOES THIS MEAN? A medical plan sponsor can depend upon a small number of people driving the lion s share of its costs. Understanding who those individuals are and what drives those costs may be the most powerful way to reduce medical trends in the short term. It is important to appreciate, however, that individuals migrate from one cohort to another from year to year. A recent analysis of high utilizers of hospital services published in Health Affairs found that only 28% of these high-cost utilizers were still high utilizers one year later. In other words, the individuals who make up this cohort turn over significantly from year to year. Whereas health care costs were on average $113,522 for someone in this cohort, costs for individuals in this group dropped by 60% within two years. 6 In other words, the ability to predict (or narrow down) who might be in that most expensive 5% cohort has powerful implications: 1) it can help you lower costs and 2) it can help you improve health outcomes and powerfully improve peoples lives. SO WHAT SHOULD YOU DO? The solution is in the data. Big Data health care analytics can help employer plan sponsors understand what has happened, but also understand where the next wave of expenditure might come from. Employers are starting to focus on understanding their high cost patterns, finding covered members with higher levels of risk, identifying members with high medical complexity and pinpointing situations where high levels of medical uncertainty may drive higher costs. Continued on page 6 5

6 Health Outcomes continued from page 5 Understanding the conditions that drive the highest costs (orthopedic, cancer, cardiac, labor, delivery complications) and learning when and how to identify next year s high cost claims this year that s doing the math. That s where employers craft high yield strategies that make a meaningful difference in their medical cost trend. SOURCES 1 Pareto Principle: How to Use It to Dramatically Grow Your Business, Forbes, Jan 20, Pareto s Principle in Hospital Medicine, Suneel Dhand, MD; Society of Hospital Medicine > The Hospital Leader; December 3, Ibid. 5 Verisk Health Analytics normative determinations. 6 August 2015 issue of Health Affairs by Tracy L. Johnson et al entitled, For Many Patients Who Use Large Amounts of Health Care Service, The Need Is Intense Yet Temporary. 6

7 LEGAL AND COMPLIANCE NEW TRADE LAW INCREASES ACA REPORTING PENALTIES On June 29, 2015, the President signed the Trade Preferences Extension Act of 2015, which among other things increased the penalties associated with pay or play reporting under the Patient Protection and Affordable Care Act (PPACA or ACA). BACKGROUND Under the PPACA employer mandate, applicable large employers (ALEs) must offer minimum essential coverage (MEC) to their full-time employees (average 30 hours or more per week), and the coverage must be affordable and provide minimum value, or the employer must pay a corresponding penalty tax. In order for the federal government to monitor ALE compliance with this coverage obligation, the law requires that ALEs meet certain reporting obligations to the IRS and to employees. Under Internal Revenue Code (IRC) Section 6056 regulations, ALEs are directed to use Form 1094-C (transmittal form that also summarizes employer shared responsibility compliance) and Form 1095-C (addressing each employee s coverage) (collectively, the C Forms ) to report how they are meeting their pay or play obligations. The PPACA also requires individuals to secure minimum essential coverage or pay a corresponding penalty under the individual mandate. Under IRC Section 6055 regulations, employers, insurance companies and other entities that provide health coverage to individuals are required to meet certain reporting obligations to covered individuals and the IRS that substantiates that individual mandate requirement. These reporting obligations are met by using the C Forms (if the reporting entity is an ALE sponsor of a self-insured plan) or by using Form 1094-B (transmittal form) and Form 1095-B (listing the covered individuals) (collectively, the B Forms ) if the reporting entity is an insurance company or a non-ale that is the source of health coverage for the individual. All ACA mandatory reporting begins during the first quarter Failure to file a timely, correct or complete B or C Form with the IRS or to send a timely, correct or complete statement to an employee (or other applicable individual) can result in a penalty that is in addition to the penalty tax levied on an employer for failing to meet the employer s pay or play obligations. PENALTY CHANGES The increases in the ACA reporting penalties were adopted through amendments to IRC Sections 6721 (addressing IRS information returns) and 6722 (addressing employee statements). The following summarizes those increases: The penalty for failure to file a timely, correct or complete information return (any of the B or C Forms) with the IRS is increased from $100 per return to $250 per return. The penalty for failure to furnish a timely, correct or complete statement (a Form 1095-B, 1095-C or one of the permitted substitute statements) to an employee or other individual entitled to such a statement is increased from $100 per return to $250 per return. For IRS information return and employee statement failures, the maximum penalty per calendar year is increased from $1.5 million to $3 million. Continued on page 8 7

8 Legal and Compliance continued from page 7 The penalty for an IRS information return failure or an employee statement failure that is due to intentional disregard is increased from $250 to $500 and the annual penalty limit is increased to $3 million. If a penalty applies to an IRS return or an employee statement failure and the employer corrects the failure in a timely manner, a lower penalty applies. Those lower penalties also have been increased in the following manner: Correction made within 30 days after the deadline for the IRS information return or employee statement the lower applicable penalty is increased from $30 to $50 (in lieu of the new $250 penalty), and the lower calendar year penalty maximum is increased from $250,000 to $500,000 (in lieu of the new $3 million maximum). Correction made by August 1 of the calendar year in which the deadline occurred the lower applicable penalty is increased from $60 to $100 (in lieu of the new $250 penalty), and the lower calendar year penalty maximum is increased from $500,000 to $1,500,000 (in lieu of the new $3 million maximum). There are also increases in the lower penalty limits for entities with gross receipts of not more than $5 million. IRC Sections 6721 and 6722 also provide for a de minimis rule, under which no penalty is levied if: The number of IRS information returns or employee statements involved does not exceed the greater of 10 or 1% of the required number of returns or statements; and The IRS information return or employee statement failure is corrected by August 1 of the calendar year of the deadline. In addition, IRC Section 6724 provides for a waiver of the penalty if it can be demonstrated that the failure was due to reasonable cause and not willful neglect. The changes to IRC Sections 6721 and 6722 affect not only IRS information returns and employee statements required in connection with ACA reporting, they also become effective for numerous other types of IRS information returns and payee statements required by various provisions of the Internal Revenue Code. These include, for example, Forms W-2 and EFFECTIVE DATE The penalty increases apply to returns and statements required to be filed after December 31, 2015, including, for purposes of ACA reporting, the initial required IRS information returns and employee statements that are due during the first quarter of 2016, as summarized below: Employee statements Due February 1, 2016 for both electronic and paper delivery (note that the official due date is January 31 each year, but January 31, 2016 falls on a Sunday) IRS information returns: Mail filing (permitted if fewer than 250 Forms 1095-B or 1095-C) due February 29, 2016 (note that the official due date is February 28 each year, but February 28, 2016 falls on a Sunday) And Electronic filing (required if 250 or more Forms 1095-B or 1095-C) due March 31, 2016 (note that the official due date is March 31 each year) CONCLUSION The increases in the ACA reporting penalties were adopted as part of a trade bill in order to help offset the cost of that legislation. As a result, it is clear that Congress is expecting that ACA reporting failures (as well as other IRS information return and payee statement failures) will generate a significant amount of revenue. In connection with ACA reporting for 2015, the IRS has indicated that it will not impose penalties under either IRC Sections 6721 or 6722 if the reporting entity can show it made a good faith effort to comply with the reporting requirements. That good faith exemption only applies if the information reported on the IRS return or employee statement is incorrect or incomplete. Failure to timely file (or not file at all) an IRS information return or employee statement will not be considered a good faith effort and will not be protected under this special exemption. For this reason, employers should be especially diligent in making sure they have not missed any IRS information return they are required to file or employee statement they are required to send. As indicated above, there are two separate sets of penalties in connection with ACA reporting, one for the IRS information return and the other for the employee statement, and therefore, the penalties double when an employee is overlooked in the reporting process. 8

9 MLR REBATE REMINDER Insured employer group medical plans (but not selffunded plans) may have recently received (or will soon receive) medical loss ratio (MLR) 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 must send rebates to individuals and employers by September 30 (in previous years the deadline was August 1). Carriers first began distributing MLR rebates in 2011 and unfortunately they raised a number of issues for the employers who received them. For employers receiving a rebate this year, a brief discussion of the ERISA concerns is provided below. EMPLOYER-SPONSORED PLANS AND ERISA 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 established rules that 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. 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. For more information on the MLR rebate and issues for employer-sponsored plans, please see Willis Human Capital Practice Alert, August 2014, My Plan is Getting a Rebate from the Insurer - What Do I Do With It? 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 9

10 HEALTH COVERAGE TAX CREDIT RETURNS The trade bill signed into law on June 29, 2015 (the Trade Preferences Extension Act of 2015 (Pub. L )) retroactively reinstated and modified the Health Coverage Tax Credit (HCTC). The HCTC, which had been allowed to expire after December 31, 2013, is now extended through December 31, The HCTC pays 72.5% of qualified health insurance premiums for certain eligible individuals and their family members. BACKGROUND The HCTC was first established under a 2002 federal law that provided trade adjustment assistance (TAA) or alternate TAA to dislocated workers, farmers and firms that had been adversely affected by international trade. The Trade Act of 2002 included provisions that expanded COBRA and HIPAA benefit protections for certain COBRA qualified beneficiaries. The Trade Act of 2002 provided the following health benefit protections that affected employer-sponsored group health plans: Premium assistance in the form of an advanceable, refundable tax credit, which, in some cases, could be applied directly to COBRA premiums rather than being applied against taxes at the end of the year. The credit was originally set at 65% of qualified health insurance premiums but was later increased to 72.5% (it was increased to 80% for a brief period of time). A second COBRA election opportunity, up to six months after the date of coverage loss, for those suffering a trade-related job loss if they did not elect COBRA when first eligible to do so. Extension of the HIPAA 63-day break in coverage rule so that those electing COBRA during the second election period would be deemed to have no break in coverage from the date of their trade-related job loss until COBRA coverage became effective. The benefit provisions under the Trade Act of 2002 only applied to those employees and former employees who, among other things, obtained DOL certification that their termination or reduction in hours resulted from foreign trade, so most employers were never affected by the Trade Act of Individuals who were at least 55 years old and receiving retirement benefits from the PBGC could also qualify for this assistance. Individuals eligible for the HCTC include: Trade adjustment assistance (TAA) recipients Receiving a trade readjustment allowance (TRA) or are entitled to such an allowance except for being in a break in training under an approved training program or for not having exhausted all rights to any unemployment insurance Alternative TAA (ATAA) recipients Receiving benefits under an alternative trade adjustment assistance program for older workers Reemployment TAA (RTAA) recipients Receiving benefits under a reemployment trade adjustment assistance program for older workers Pension Benefit Guaranty Corporation (PBGC) pension payees Age 55 or older on the first day of the month and receiving a benefit paid by the PBGC Qualifying family members Spouse or dependent of an individual described above who does not have other specified coverage Continued on page 11 10

11 Legal and Compliance continued from page 10 The following health insurance qualified for the credit. COBRA continuation coverage Coverage under a group health plan available through a spouse s employment Coverage under a non-group (individual) health insurance plan, if the first day of coverage started at least 30 days before the individual left his or her job that qualified him or her for TAA, ATAA, RTAA, or PBGC benefits, or the date of Medicare enrollment, death of or divorce from the original TAA recipient or PBGC payee that provided an individual with extended eligibility as a qualified family member REVISED HCTC The trade bill made several changes to the HCTC. The following are highlights: Extends the HCTC through 2019 and applies it retroactively for coverage months beginning after December 31, Individuals may be able to claim retroactive payments for qualified health insurance from January 1, 2014 through July 6, 2015 on an amended tax return (although the IRS cautions taxpayers to wait for additional guidance before filing an amended return). Amends the definition of qualified health insurance, effective January 1, 2016, to exclude coverage purchased through the health insurance marketplace (i.e., public exchanges). Removes the requirement for individuals to be covered under the individual health insurance during the entire 30-day period before the individual terminated employment that qualified the individual as a TAA, RTAA or PBGC pension recipient. Removes the rule on bridging 63-day or longer breaks in creditable coverage since preexisting condition exclusions are now prohibited due to health care reform. Coordinates with the tax credits available for exchange coverage. Since premium tax credits and the HCTC are not available for the same coverage month, a taxpayer receiving both will need to make adjustments on his or her tax return. CONCLUSION Following the expiration of the HCTC, the Department of Labor (DOL) removed references to it from the model COBRA election notice. While the DOL has not yet revised its notice, it will likely do so at a future date. Employers will want to review their current COBRA materials, including notices and summary plan descriptions, as they may now need to be amended to address the HCTC. The IRS has indicated that it will be providing additional details about the HCTC shortly. Such updates and guidance will be posted on its website (see News-and-Background). THE HCTC PAYS 72.5% OF QUALIFIED HEALTH INSURANCE PREMIUMS FOR CERTAIN ELIGIBLE INDIVIDUALS AND THEIR FAMILY MEMBERS. 11

12 WEBCASTS UNDERSTANDING THE IMPACT OF PHARMACY COST AND HOW TO CUSHION THE BLOW TUESDAY, SEPTEMBER 15, 2015, 2 PM EASTERN Presented by: Anthony Root, Senior Consultant, Reporting & Analytics Human Capital Practice As medical science advances toward innovative treatments for various diseases, the cost of developing those treatments, especially in the pharmaceutical industry, are escalating dramatically. New drugs in the biologic and biosimilar categories are the new cutting edge treatments for diseases such as cancer, rheumatoid arthritis, multiple sclerosis, and Crohn s. And while they are improving the lives of those with these diseases, the associated costs are often significant. For some employers (those who pay a significant portion of that cost), the increasing cost is often unexpected. Since the cost of treating diseases is directly linked to the health of a population, data and clinical analysis are critical to identifying potential risk, levels of appropriate care and drivers of cost. Data analytics are used to review components of cost and identify the drivers or outliers that are impacting the overall cost. This session will take a look at the current pharmaceutical climate, specifically as it relates to the impact pharmacy has on an employer s overall health care cost. We will review a wide range of topics, including identifying the pharmacy cost drivers and strategies for managing pharmacy cost. During this session, participants will learn: What s driving the increasing cost of pharmacy About health risk and disease burden How to identify specific cost drivers using analytics An overview of specialty drugs What impact biosimilar drugs have on cost How to measure the success of implemented strategies To RSVP, click here. NOTE: Advance RSVP is required to participate in this call. Registration ends 1 hour prior to the call start time. SUCCESSION PLANNING: HOW TO CREATE A ROADMAP FOR THE FUTURE GROWTH OF YOUR ORGANIZATION TUESDAY, OCTOBER 20, 2015, 2 PM EASTERN Co-Presented By Leann Hoene, SPHR-CA, GPHR, SHRM-SCP Senior Human Resources Consultant HR Partner Consulting Human Capital Practice Megan Gaddy Human Resources Consultant HR Partner Consulting Human Capital Practice Studies have shown that most companies have little or no defined succession plan in place not for their mission critical positions, and not even for their CEO. The results can be traumatic when a key employee exits the organization, leaving skill gaps and a loss of valuable knowledge and expertise. By then, it is too late to start planning for the future. The future is now. Succession planning is more than having successors for the CEO. It s an enterprise-wide perspective on leadership development that builds broader capability and a deeper pipeline of critical skills and talent not just at the top, but in all levels of the organization. This session will describe how to build an eye-opening and compelling business case. We will discuss the 8-Step Action Plan for creating a succession management process, including identifying key competencies and skills, defining high-potential and high performing employees, identifying mission critical positions, measuring and assessing the skill gaps, and engaging in the development and retention of key employees for the future. During this session, participants will learn: The key differences between replacement planning, succession planning, and succession managementh How to identify and prioritize critical positions based on impact and retention outlook What systems track developmental goals Metrics used to gauge the impact and success of the program To RSVP, click here. NOTE: Advance RSVP is required to participate in this call. Registration ends 1 hour prior to the call start time. Each of the above programs has been approved for 1 recertification hour toward PHR, SPHR and GPHR recertification through the Human Resource Certification Institute (HRCI). For more information about certification or recertification, please visit the HRCI homepage at 12

13 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 Stamford, 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

14 Milwaukee, WI Minneapolis, MN Moline, IL Overland Park, KS 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 San Antonio, TX Wichita, KS WESTERN Fresno, CA Irvine, CA Las Vegas, NV Los Angeles, CA Phoenix, AZ Portland, OR 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. Willis North America Inc. Brookfield Place 200 Liberty Street, 7th Floor New York, New York United States Tel: /07/15