Employee Benefits Compliance Update

Transcription

1 Compliance MARCH 2016 Employee Benefits Compliance Update USI Insurance Services Employee Benefits Compliance Practice In this issue DOL releases proposed changes to SBC template and related documents Administration s proposed modifications to the Cadillac tax ACA: Summary of Form 1095-C, Part II coding for COBRA situations Final regulations establish new dollar thresholds for 2017 non-grandfathered plans out-of-pocket maximum Paid sick leave for federal contractors ACA impact on expatriates, inpatriates, and expatriate medical plans New compliance questions in the 2015 Form 5500 should not be answered California imposes new restrictions on out-of-pocket limits and deductibles Page

2 DOL releases proposed changes to SBC template and related documents The DOL recently released proposed revised template for the Summary of Benefits and Coverage and related documents. The draft template includes additional definitions and examples on how plans will pay for procedures. On February 26, 2016, the Department of Labor ( DOL ) released proposed revisions to the Summary of Benefits and Coverage ( SBC ) and related documents, pursuant to final guidance issued in June SBCs are required by the Affordable Care Act and must be distributed to participants at the time of enrollment and prior to a plan s annual open enrollment period. Insurance carriers and plan administrators for insured health plans and plan administrators for self-insured medical plans (usually the plan sponsor unless otherwise designed in the plan documents) are responsible for preparing and issuing SBCs. Although the effective date of the new templates has not been announced, the DOL has informally indicated that the new SBC template, glossary, and instructions are applicable to plan years commencing on or after April 1, The DOL is requesting public comments on the proposed amendments prior to the release of the final documents. The primary changes include: Shortened length of the SBC: The new SBC template is two and one-half pages double-sided (five total pages) rather than four pages doublesided (eight total pages). Revised heading on the first page of the SBC: The new template lists the terms commonly used throughout the SBC and encourages participants to visit the glossary for additional information. The heading also includes a new statement regarding premium costs, which are in addition to a participant s out-of-pocket expenses when accessing plan benefits. Important Questions section: The proposed SBC template revises this section to include new questions, such as what services are covered before deductibles are met (for example, preventive services), clarify what kind of expenses are not included in out-of-pocket maximums, and update the wording of some questions to clarify some of the expenses individual can face when accessing care. Revised Limitations, Exceptions, and Other Important Information section: The description of the type of limitations or exclusions applicable to care, including a reference to services that require preauthorization, is expanded. New disclosures: The proposed SBC template requires that the plan specifically state with a yes or no answer if the plan provides minimum essential coverage (MEC) and if the plan meets minimum value (MV) requirements. It also explains to participants the tax consequences of not enrolling in MEC coverage and an individual s eligibility for premium tax credits if their plan is not MV. It also amends the section pertaining to the rights to continue coverage, includes a more comprehensive discussion of an individual s grievance and appeals rights, and provides for language access services for individuals who do not speak English. New coverage examples: The proposed SBC adds a third coverage example involving a simple fracture, and provides more succinct descriptions of the participant s plan expenses when accessing care. New instructions: The instructions for completing the SBC include new information on addressing coverage or exclusion of abortion services, and incorporate previously-issued guidance on combining information for different cost-sharing options and explaining the effect of a health FSA, HRA, HSA, or wellness program. Uniform glossary: Proposed revisions include the requirement that SBCs underline terms defined in the glossary and, in electronic SBCs, hyperlink directly to the definition. Page 1

3 Administration s proposed modifications to the Cadillac tax While opponents to the Cadillac tax on high cost employer-sponsored health plans hope to repeal the provision completely after the next general election, proponents may seek to just modify the provision in order to preserve some of the projected revenue from the tax that would otherwise be lost. In its proposed 2017 federal budget, the current Administration has suggested several changes to the Cadillac tax, including an adjustment to the applicable tax thresholds in states where the cost of healthcare is particularly high and smoothing out how the cost of health flexible spending accounts are taken into account in calculating the tax. After a considerable bipartisan lobby effort last fall, a two-year delay in the effective date of the so-called Cadillac tax from 2018 to 2020 was included in the omnibus spending law signed on December 18, 2015 (see our December 22, 2015 Employee Benefits Compliance Alert). While it is widely expected that opponents to the Cadillac tax will attempt to use the delay to push for a repeal of this Affordable Care Act provision after the next general election, it is possible that a new Congress and new Administration may compromise and agree to only modify this excise tax on high cost employer-sponsored health plans. Increasing the applicable tax threshold for singleonly coverage to the greater of the current law threshold or a gold plan average premium that would be calculated and published for each State. The State average gold plan premium would be a weighted average of the premiums for the lowestcost silver self-only Marketplace plan offered for each age and county in the State, multiplied by 8/7 to simulate the cost of an actuariallyequivalent gold plan. A multiplier would be applied to this amount to create the other-thansingle-only coverage threshold. Rather than using the amounts actually contributed on an employee-by-employee basis, calculating the cost of coverage under a health flexible spending account (health FSA) for similarly situated participating employees as being equal to the sum of (a) the average salary reduction amount elected by such employees for the year, and (b) the average employer contribution for such employees for the year. Requiring a study of the potential effects of the Cadillac tax on firms with unusually sick employees, to be conducted by the Government Accountability Office in consultation with the Department of Treasury and other experts. Another example of a proposed modification is in the Health Savings Act of 2016 (S. 2499) introduced by Senator Orrin Hatch (R-UT) which, among other things, would exclude health savings accounts (HSAs) and health FSA contributions from the Cadillac tax. On February 9, 2016, the current Administration included one such proposal in its proposed budget for the 2017 fiscal year. The General Explanations of the Administration s Fiscal Year 2017 Revenue Proposals (known as the Greenbook) describes the proposed changes to the Cadillac tax as: Page 2

4 ACA: Summary of Form 1095-C, Part II coding for COBRA situations Final 2015 Form 1095-C Instructions provide a simplified method for reporting for terminated employees eligible for COBRA. Only notable adjustment may occur when employment terminates mid-month and active coverage terminates as of date of termination. Different treatment applies for ongoing employee whose coverage is terminated due to a reduction in hours. Special rule applies for self-insured plans using Form 1095-C to report actual coverage for individuals, including non-employee COBRA qualified beneficiaries, who are non-employees for the entire calendar year. Many employers subject to reporting rules under section 6056 of the Internal Revenue Code are having difficulty determining the correct coding for Forms 1095-C in COBRA situations. Final C instructions substantially simplified coding for terminating employees, particularly when active coverage continues through the end of the month of termination. However, coding for employees who have a reduction in hours (typically moving to parttime ) resulting in a loss of active coverage, can be complex. This is particularly true for employers who apply the look-back measurement method for determining full-time employee status and have employees who move to part-time and become ineligible but must continue to be viewed as fulltime for the balance of a stability period. Following is a summary of various COBRA situations, with resulting code entries based on interpretation of the final 2015 Form 1095-C Instructions. COBRA due to termination of employment (regardless of whether former employee elects coverage, and employee is not rehired) Line 14 Line 15 Line 16 For the balance of the calendar year of the qualifying event (QE): Coverage ends immediately mid-month Coverage ends at end of the month ONLY IF COBRA coverage is elected, plan is self-insured, and employer elects to use Form 1095-C rather than Form 1095-B 1H for month of QE and months Applicable Series 1 code for month of QE, then 1H for months Complete if Line 14 is 1B, 1C, 1D, or 1E for month of QE, otherwise and months leave In calendar year(s) subsequent to QE: 1G in the All 12 months column 2B for month of QE, then 2A 2C for the month of QE, then 2A for months Page 3

5 COBRA offer to continuing employee due to reduction in hours Line 14 Line 15 Line 16 For the calendar year of QE (and for any subsequent calendar years after the QE but ONLY IF employee is considered a fulltime employee for one or more months in those years, such as through the application of a stability period under the look-back measurement method): Applicable Series 1 code for all months of calendar year(s) Higher COBRA premium rate might take away ability to use 1A Complete if Line 14 is 1B, 1C, 1D, or 1E Adjust if necessary for higher COBRA premium rate after QE 2C for months before QE, and for month of QE and months If enrolled, regardless of fulltime status or not 2B for month of QE and months If employee doesn t enroll and loses full-time status 2F, 2G, 2H or for month of QE and months If employee retains full-time status but doesn t enroll Applicable coding depends on whether the higher COBRA premium rate meets one of the affordability safe harbors or not In subsequent calendar years (but ONLY IF employee is not considered a full-time employee for all 12 months, the employee elected COBRA coverage, and the plan is self-insured): 1G in the All 12 months column Independent COBRA election (by spouse, ex-spouse, dependents due to death of employee, divorce, legal separation, aging out as a dependent) under SELF-INSURED PLANS ONLY Line 14 Line 15 Line 16 COBRA coverage independently elected by spouse, ex-spouse, or dependents (self-insured employers required to distribute separate Form 1095-C (or, alternatively, Form 1095-B) in the name of the COBRA qualified beneficiary): 1G in the All 12 months column Final regulations establish new dollar thresholds for 2017 non-grandfathered plans out-of-pocket maximum 2017 out-of-pocket maximum for nongrandfathered plans will be $7,150 for self-only coverage, and $14,300 for all tiers other than self-only. New regulations in 2016 will apply to out-ofpocket maximum applied to an individual under family coverage. On March 1, 2016, the Department of Health and Human Services announced the finalized 2017 health plan out-of-pocket maximums (OOPM) maximums. Under the ACA, the annual out-of-pocket maximum applicable to non-grandfathered group health plans became effective for plan years beginning in The final regulations provide that the limits for 2017 are $7,150 for self-only coverage and $14,300 for tiers other than self-only. Year ACA OOPM self only ACA OOPM other than self only HSA OOPM self only HSA OOPM other than self only 2015 $6,600 $13,200 $6,450 $12, $6,850 $13,700 $6,550 $13, $7,150 $14,300 TBD TBD Page 4

6 Employers need to be mindful of the new regulations beginning in 2016 requiring that all non-grandfathered health plans apply the self-only out-of-pocket maximum to any individual, regardless of whether the individual participates in a self-only tier of coverage or any other tier of coverage, such as family coverage. Thus, for example, in 2017, if several individuals are enrolled in family coverage with a family out-of-pocket maximum of $10,000, if any one of those individuals incurs out-of-pocket expenses exceeding $7,150, all remaining eligible claims incurred by that individual for the balance of the plan year must be paid at 100% by the plan. Please review our June 2015 Benefits Compliance Update for further detail on this issue. Remember that HSA-eligible high-deductible health plans (HDHPs) must comply with minimum deductible and maximum out-of-pocket requirements, and that the maximum out-of-pocket requirement for an HSA-eligible HDHP is now different than the maximum out-of pocket limit permissible under the ACA applicable to all types of non-grandfathered plans. In turn, employers maintaining an HSA-eligible HDHP will need to comply with both sets of rules. Thus, for example, a family HDHP should be able to comply with both outof-pocket limits if it applies a self-only out-of-pocket maximum that is no higher than the self-only ACA limit and, in all events, pays all expenses for all family members once the group s expenses reach the family out-of-pocket maximum under the HSA-eligible rules (or the family limit established for the plan, if lower). Paid sick leave for federal contractors Proposed rule would require certain federal contractors to provide their employees with up to seven days of paid sick leave annually beginning with new federal contracts and replacements for expiring contracts issued in Employees would earn a minimum of one hour of paid sick leave for every 30 hours worked or the contractor could provide 56 hours of paid sick leave at the beginning of each accrual year. The Department of Labor (DOL) recently issued a proposed rule implementing President Obama s 2015 executive order to establish paid sick leave requirements for federal contractors. The proposed rule would require certain federal contractors to provide their employees with up to seven days of paid sick leave annually beginning with new federal contracts and replacements for expiring contracts issued in The rule would apply to the following four major categories of contractual agreements: Procurement contracts for construction covered by the Davis-Bacon Act (DBA); Service contracts covered by the McNamara- O Hara Service Contract Act (SCA); Concession contracts; and Contracts in connection with federal property or lands, and related to offering services for federal employees, their dependents, or the general public. The proposed rule requires that employees earn a minimum of one hour of paid sick leave for every 30 hours worked. In the alternative, the contractor could provide 56 hours of paid sick leave at the beginning of each accrual year. Contractors must allow an employee to use paid sick leave in increments of one Page 5

7 hour, and may choose to allow increments of less than one hour, but are not required to do so. Employees would be able to use the paid sick leave to care for themselves, their child, parent, spouse, domestic partner, or other family member. The leave would be able to be taken for: (1) physical or mental illness, injury, or a medical condition; (2) obtaining a diagnosis, care, or preventative care from a health care provider; and (3) absences related to domestic violence, sexual assault, or stalking. The Notice specifically states that conditions may be covered regardless whether they require the attention of a health care provider. Paid sick leave would be provided upon the oral or written request of an employee. A leave request must be made at least seven calendar days in advance where the need for the leave is foreseeable, and in other cases as soon as practicable. Contractors would be required to communicate any denial of a request to use paid sick leave in writing, with an explanation for the denial. In addition, a contractor may only require certification for absences of three or more consecutive days. Paid sick leave would be able to be carried over from one year to the next, and reinstated for employees rehired by the covered contractor within 12 months after a job separation. A contractor would not be able to set a limit on the total accrual of paid sick leave per year (or at any point in time) at less than 56 hours. However, contractors will not be required to pay employees for accrued, unused paid sick leave at the time of a job separation. Contractors would be required to inform employees of the amount of paid sick leave accrued in writing at least monthly, and at other specified times. The full text of the Notice, along with a fact sheet and further information on the proposal, can be found on the DOL s website. The public may comment on the proposed rule until April 12, The DOL hopes to finalize the rule by September 30, ACA impact on expatriates, inpatriates, and expatriate medical plans Expatriates and inpatriates must have minimum essential medical coverage to avoid penalties under ACA individual shared responsibility (unless they are otherwise exempt). Employers are not subject to penalties under ACA employer shared responsibility with respect to expatriates, so long as they are working outside of the U.S. Employers must furnish Form 1095-C to expatriates and inpatriates who are ACA fulltime employees. ACA individual shared responsibility Under ACA individual shared responsibility, all U.S. citizens and nationals (who are not otherwise exempt) may be assessed a penalty if they do not have minimum essential medical coverage. The fact that a U.S. citizen or national is an expatriate (U.S. citizen working outside of the 50 states and District of Columbia) does not mean he/she is exempt from ACA penalties. However, the ACA treats an expatriate as having minimum essential medical coverage for any month during which his/her foreign residency or presence in a foreign country qualifies him/her for the foreign earned income exclusion. An expatriate can qualify for the foreign earned income exclusion by meeting any one of the following tests: His/her tax home is a foreign country, and he/she has been a bona fide resident of a foreign country or countries for an uninterrupted period that includes an entire taxable year (this applies even if the individual is a U.S. citizen); or He/she is a U.S. citizen or resident whose tax home is a foreign country, and he/she is present in a foreign country for at least 330 full days during a 12-month period; Page 6

8 He/she is a student, missionary or charity worker in a foreign country; or He/she is a bona fide resident of a U.S. possession (Guam, American Samoa, the Northern Mariana Islands, Puerto Rico, or the U.S. Virgin Islands). An expatriate who satisfies one of the above tests is treated as having minimum essential medical coverage, and will not be subject to penalties under ACA individual shared responsibility, for those months in which one of the above tests is met. Inpatriates (foreign citizens who lawfully work in the U.S.) are not exempt from penalties under ACA individual shared responsibility because of their inpatriate status. Inpatriates must have minimum essential medical coverage to avoid penalties if they are in the U.S. long enough to qualify as a resident alien for U.S. income tax purposes. ACA employer shared responsibility Under ACA employer shared responsibility, employers have a choice between offering affordable, minimum value medical coverage to their ACA full-time employees or paying a penalty to IRS. An employee qualifies as an ACA full-time employee if he/she has an average of 30 or more hours of service per week. IRS final regulations state that an hour of service means each hour for which an employee is paid (or entitled to payment) for the performance of duties for the employer, and each hour for which an employee is paid (or entitled to payment) for a period during which no duties are performed (such as vacation time). However, an hour of service does not include employment outside of the 50 states and District of Columbia. Expatriates are not credited with hours of service under the ACA while they are working outside of the U.S. As a result, expatriates would not qualify as ACA full-time employees for purposes of ACA employer shared responsibility while they are working as expatriates outside of the U.S. The employer would not be subject to penalties under ACA employer shared responsibility with respect to expatriates for the period in which they work outside of the U.S., even if the employer fails to offer minimum essential medical coverage to them. However, inpatriates are credited with hours of service while working in the U.S. and may qualify as ACA full-time employees for purposes of ACA employer shared responsibility. If that should happen, the employer could be assessed a penalty by IRS if the employer fails to offer minimum value, affordable medical coverage to the inpatriate and the inpatriate receives a premium tax credit to help pay for a qualified health plan obtained from an insurance marketplace or exchange. An inpatriate can receive a premium tax credit to help pay for a qualified health plan, if he/she meets all of the following criteria: He/she is a U.S. national (i.e., noncitizen lawfully present in the U.S.); and He/she is reasonably expected to remain in the U.S. for the entire period for which enrollment in a qualified health plan is sought; and He/she is not covered under employer-sponsored minimum essential medical coverage; and He/she is not eligible for employer-sponsored minimum essential medical coverage that is both minimum value and affordable. A special problem can arise under ACA employer shared responsibility if an employee transfers between U.S. and foreign positions within an employer s controlled group. For example, an employee may transfer from a U. S parent company to a foreign subsidiary, or from a U.S. subsidiary to a foreign parent company. According to IRS final regulations, whenever such a transfer takes place, the following rules may be followed: If the employee transfers from a position in the U.S. to a position outside the U.S., he/she may be treated as having terminated employment from the U.S. employer as long as the new position is anticipated to continue for at least 12 months, and substantially all compensation after the transfer is Page 7

9 foreign-source income. If an employee transfers from a non-u.s. position to a U.S. position, the employee may be treated as a new hire in the U.S. position if the employee has no prior U.S. hours of service. Otherwise, the employee may be treated as new hire only if the period of employment outside the U.S. was sufficient to constitute a break under the rehire rules (generally 13 weeks). ACA information reporting For 2015 and subsequent calendar years, all employers that are applicable large employer members must comply with ACA information reporting by providing Form 1095-C to their ACA full-time employees (as well as to IRS). If an expatriate worked outside of the U.S. for the entire calendar year, then he/she would not qualify as an ACA full-time employee (as discussed above), and would not receive Form 1095-C from the employer. However, if the expatriate qualified as an ACA fulltime employee for one or more months of the year for example, by working in the U.S. for one or more months before being transferred overseas, or after returning from overseas then the employer would be responsible for furnishing Form 1095-C to the expatriate (as well as to IRS). As discussed above, when an expatriate completes a foreign assignment and returns to the U.S., he/she would be considered a new hire by the employer if he/she worked overseas for at least 13 weeks. In the case of an inpatriate, if he/she is considered an ACA full-time employee based on his/her hours of service in the U.S., then the employer will need to issue Form 1095-C to the inpatriate (as well as to IRS). ACA Market Reform Standards The Expatriate Health Coverage Clarification Act of 2014 (the Expatriate Act ), enacted in December 2014 as Division M of the Consolidated and Further Continuing Appropriations Act (H.R. 83), exempts qualified expatriate coverage from some ACA market reform standards. For further details on what constitutes a qualified expatriate plan including conditions the plan must meet under ACA, see our February 2015 Employee Benefits Compliance Update. To be treated as qualified expatriate coverage, fullyinsured expatriate plans are required to issue Form 1095-B to expatriates as proof of minimum essential medical coverage. If a foreign insurance carrier does not agree to comply with the Form 1095-B reporting requirement, then the expatriate plan is not considered qualified expatriate coverage, and the expatriate plan will be subject to all of the ACA market reform standards. Employers should take steps to confirm that the expatriate plan complies with the Form 1095-B reporting requirement. Cadillac tax The Expatriate Health Coverage Clarification Act of 2014 states that the Cadillac tax applies to a U.S. bound inpatriate if the person is assigned, rather than transferred, to the U.S. The Cadillac tax does not apply to all other categories of expatriates. Additional guidance is necessary to determine how the Cadillac tax will apply to expatriate plans. For additional information on this topic, see our February 2014 and April 2014 Employee Benefits Compliance Updates. New compliance questions in the 2015 Form 5500 should not be answered Certain compliance questions found in the 2015 Form 5500 and Form 5500-SF do not need to be answered. The IRS announced on February 17, 2016, that certain new Internal Revenue Service (IRS) compliance questions found in the 2015 Form 5500 and Form 5500-SF, and Schedules H (Financial Information), I (Financial Information-Small Plan) and R (Retirement Plan Information) do not need to be answered, as the IRS failed to obtain approval Page 8

10 from the Office of Management and Budget (OMB) prior to their release. Sponsors of pension, annuity, stock bonus, profit-sharing or other funded plan of deferred compensation subject to Form 5500 and SF requirements are not required to answer the following questions for the 2015 plan year: Form 5500: Preparer Information at bottom of page 1 Form 5500-SF: Preparer Information at bottom of page 1, Lines 10j, 14a-d, and Part IX (Lines 15a-c, 16a-b, 17a-d, 18, 19, and 20) Schedules H and I: Lines 4o-4p, 6a-6d Schedule R: Part VII; Lines 20a-c, 21a-b, 22a-d, and 23 The DOL issued similar guidance indicating that the questions referenced above should not be completed for the 2015 plan year filing. In addition, the Form 5500 and Form 5509-SF instructions have been updated to reflect the same. California imposes new restrictions on outof-pocket limits and deductibles California AB 1305 imposes new restrictions on out-of-pocket limits and deductibles for nongrandfathered group medical insurance policies and HMO contracts. When family coverage is elected, an individual within the family shall not have an out-ofpocket limit that is greater than the maximum out-of-pocket limit for individual coverage for that product. When family coverage is elected and the policy or contract is not a high-deductible health plan, an individual within the family shall not have a deductible that is greater than the deductible limit for individual coverage for that product. Insurance carriers are grappling with the implementation date for these provisions. California Assembly Bill 1305, which was enacted into law on October 8, 2015, imposes new restrictions on out-of-pocket limits and deductibles for group medical insurance policies and health maintenance organization contracts in California. As discussed in the March 2015 Employee Benefits Compliance Update, the Affordable Care Act requires that the self-only out-of-pocket limit under federal law will apply to any individual, regardless of whether the individual participates in a self-only tier of coverage or any other tier of coverage (such as family coverage). California AB 1305 goes beyond the ACA, and imposes new restrictions on out-of-pocket limits and deductibles as outlined in the following chart: Type of policy or contract Non-grandfathered group policy or HMO contract providing family coverage, that is not a highdeductible health plan Non-grandfathered group policy or HMO contract providing family coverage, that is a high-deductible health plan New restriction on out-of-pocket limits An individual within the family shall not have an out-ofpocket limit that is greater than the maximum out-ofpocket limit for individual coverage for that product An individual within the family shall not have an out-ofpocket limit that is greater than the maximum out-ofpocket limit for individual coverage for that product New restriction on deductibles An individual within the family shall not have a deductible that is greater than the deductible limit for individual coverage for that product An individual within the family shall have a deductible equal to whichever of the following is greater: The minimum deductible under federal law for family coverage under a qualifying high deductible health plan (for example, $2,600 in 2016) The deductible for individual coverage under the policy or contract For example, in 2016, the ACA imposes an out-ofpocket limit of $6,850 for self-only coverage, and $13,700 for family coverage. An insurance carrier in California might have a non-grandfathered group medical insurance product with an out-of-pocket limit of $5,000 for the self-only tier, and $10,000 for the family tier. If an employee elects the family Page 9

11 tier, the ACA would impose an out-of-pocket limit of $6,850 for any individual in the family. AB 1305 further restricts the out-of-pocket limit for that individual to $5,000, which is the maximum-out-ofpocket limit for individual coverage for that product. By its terms, AB 1305 applies to group medical insurance policies and HMO contracts issued, amended or renewed in California on or after January 1, 2015, except for high-deductible health plans, which have a delayed effective date of January 1, Insurance carriers and HMOs have been grappling with the problem of when to amend nonhigh-deductible health plans to conform to AB The following insurance carriers have advised us of their position regarding this issue (based on informal conversations conducted in February 2016): Insurance Carrier Aetna Anthem Blue Cross Cigna United Healthcare AB 1305 proposed implementation date Will not require implementation retroactive to January 1, 2016 Will implement the out-of-pocket limit for insurance policies issued, amended or renewed on or after January 1, 2016 Will implement the deductible limit for insurance policies issued, amended or renewed on or after January 1, 2017 Will implement the out-of-pocket limit and deductible limit for HMO contracts, beginning January 1, 2017 Will require implementation retroactive to January 1, 2016 Will require implementation at the start of the plan year, for plan years beginning April 1, 2016, or later How can we help? To learn more about current benefits compliance issues, please contact your local USI Benefits Consultant, or visit us at This material is for informational purposes and is not intended to be exhaustive nor should any discussions or opinions be construed as legal advice. Contact your broker for insurance advice, tax professional for tax advice, or legal counsel for legal advice regarding your particular situation. USI does not accept any responsibility for the content of the information provided or for consequences of any actions taken on the basis of the information provided USI Insurance Services. All rights reserved.