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1 Update: How To Prepare For 2014 Tripp W. Vander Wal The materials and information have been prepared for informational purposes only. This is not legal advice, nor intended to create or constitute a lawyer-client relationship. Before acting on the basis of any information or material, readers who have specific questions or problems should consult their lawyer 2 Where Do We Go From Here? The U.S. Supreme Court appears to have settled the question of the constitutionality of in its June 2012 opinion There are some cases currently before lower federal courts challenging Health Care Reform Most of the cases focus on the mandate to cover contraceptives 3 1

2 Where Do We Go From Here? Officials from the Obama administration have indicated that they do not intend to push back the 2014 effective date of the state exchanges and the individual and employer mandates despite some calls to do so 4 Where Do We Go From Here? The U.S. Department of Health and Human Services (HHS) and other federal agencies were reportedly working on several sets of regulations to implement over the summer and early fall of 2012 and have been busy releasing the guidance since the November 2012 election 5 Agenda Fees imposed by Other requirements under Health Care Reform Exchanges and coverage from exchanges What will you do? 6 2

3 7 Only large employers are subject to the pay or play penalty under Health Care Reform A large employer is any employer with 50 or more: Full-time employees; and Full-time equivalent employees ( FTEs ) 8 9 Who are my full-time employees? Only common law employees who work: On average, at least 30 hours per week; or 130 hours per month Several individuals are excluded: Independent contractors Leased employees Employees working outside the U.S. (regardless of citizenship) Sole proprietors, partners and more than 2% S-corp shareholders 3

4 Which hours must be counted? All hours that employees are paid or entitled to be paid for the performance of duties All hours that employees are paid or entitled to be paid on account of a period of time during which no duties are performed (e.g., due to vacation, illness, layoff, etc.) 10 For hourly employees, credit hours based on actual hours of service For salaried employees: Actual hours Days-worked equivalency method credit 8 hours of service for each day an employee is credited with at least one hour of service Weeks-worked equivalency method credit 40 hours of service for each week an employee is credited with at least one hour of service 11 There are special rules to credit hours while on an unpaid leave due to FMLA, USERRA or unpaid jury duty 12 4

5 Large Employer Example: In 2014, Employer A employs 44 full-time employees and part-time employees that cumulatively work the following hours: Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec P.T Step 1: Calculate FTEs by dividing parttime hours by 120 (keep fractions) Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec P.T FTE Step 2: Add FTEs and full-time employees Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec F.T FTE Tot Step 3: Add full-time and FTEs for 2014 and divide by 12: Average full-time and FTEs in 2014 = 49.7 Step 4: Round all fractions down e.g., 49.9 = 49, not 50): 49.7 = 49 Employer A is not a large employer 15 5

6 16 Seasonal Worker Exception - If an employer has 50 or more full-time and FTEs on 120 days (or 4 months) or less, the employer is not a large employer if the reason the number of full-time and FTEs exceeds 50 is a result of employing seasonal workers The 120 days (or 4 months) does not need to be consecutive What is a seasonal worker? An employee that performs labor or services on a seasonal basis For example, an agricultural worker or retail worker employed only during holiday seasons An employer may use a reasonable good faith interpretation of the term seasonal worker Pay If a large employer decides to pay, it will be subject to a $2,000 per full-time employee (disregarding the first 30 full-time employees), if at least one full-time employee receives a premium tax credit on the exchange Low income individuals (with household income between 100% and 400% of the federal poverty level) are eligible for a premium tax credit If no employees receive a premium tax credit, the employer is not subject to the pay or play penalty, even if the employer decides to pay 6

7 Play (and pay?) If an employer decides to play, it must offer health coverage to substantially all of its fulltime employees Substantially all means 95% of an employer s full-time employees (if an employer has less than 100 full-time employees, substantially all means all but 5 of the employer s full-time employees) Play (and pay?) A large employer that offers coverage to substantially all of its full-time employees may still be subject to the pay or play penalty if any full-time employees receive a premium tax credit When may a full-time employee in this situation receive a premium tax credit? The employee is in the 5% or (5 employees) that are not offered coverage The coverage offered either fails to provide minimum value or is not affordable How is this penalty calculated? $3,000 x each full-time employee that receives a premium tax credit on the exchange Example: Employer has 7 employees that are not offered coverage and 3 employees that are offered coverage that is not affordable. Employer s penalty is $30,000, if each employee receives a premium tax credit 21 7

8 22 Minimum Value In general, an employer s plan must cover at least 60% of the total allowed benefits under the plan HHS issued proposed regulations in November 2012 offering three different methods to determine an employer group health plan s minimum value: Calculator method Safe harbor checklists method Actuarial certification method Minimum Value Employer HSA and HRA contributions for the current year are included in determining minimum value (not affordability) An employer s plan isn t affordable if the employee s required contribution for single employee coverage in the employer s lowest cost medical option exceeds 9.5% of the employee s household income The IRS has provided 3 safe-harbors where an employer s plan will be considered affordable for purposes of avoiding the $3,000 penalty for a year 8

9 W-2 Safe-Harbor -- The premium for single employee coverage under the employer s lowest cost health option does not exceed 9.5% of the employee s wages for that year (as defined for purposes of Box 1 on Form W-2) If an individual is not a full-time employee for the entire year, the employee s W-2 wages should be adjusted to reflect the portion of the year when the employee was offered health coverage and then there should be a comparison of the adjusted wages to the employee s premium share during that period W-2 Box-1 is affected by an employee s pre-tax contributions (i.e., qualified retirement plan salary deferrals, contributions to a Medical FSA or a DCAP and pre-tax contributions towards the cost of health coverage) 25 Rate of Pay Safe-Harbor -- Instead of comparing the employee s premium to his or her W-2 Box-1 pay, the premium is compared to an employee s hourly pay rate as in effect as of the beginning of the year, multiplied by 130 (the benchmark for determining whether an hourly employee is fulltime under the pay or play penalty) A similar safe-harbor is available for salaried employees based on the employee s monthly salary at the beginning of the year Federal Poverty Line Safe-Harbor -- Under the federal poverty line safeharbor, coverage provided to an employee is affordable if the employee s cost for single employee coverage under the plan does not exceed 9.5% of the federal poverty line for a single individual as in effect at the beginning of the year In 2013 this is $11,490 so the safe-harbor is $90.96/month ($11,490/12 x 9.5%) 9

10 Affordability, minimum value and wellness plans: If a wellness plan includes a tobacco cessation component, affordability and minimum value are calculated based on the assumption that all participants receive the wellness incentive for completing the tobacco cessation requirement or are non-smokers On the other hand, with respect to wellness incentives for meeting certain health goals, affordability and minimum value are calculated based on the assumption that all participants failed to receive the wellness incentive (except in 2014 for wellness programs that were in effect on May 3, 2013) 28 Determining full-time employees Relatively easy, if all of an employer s employees either clearly work: (1) on average at least 30 hours per week or (2) less than an average of 30 hours per week Offer the first group coverage and exclude the second group Note: An employer should still track the second group s hours in case of an IRS audit 29 Variable hour and Seasonal employees are more difficult: A variable hour employee may be full-time in some months but not others; A seasonal employee may only be a full-time employee during the seasons the employee is working 30 10

11 31 It s not administratively practical (or possibly feasible) to provide variable hour or seasonal employees coverage only in the months that the employee was full-time As a result, an employer can either provide coverage to these employees all year or exclude them from coverage all year If these employees are excluded, in the months the variable hour and seasonal employees are full-time, the employer is subject to 1/12 of the applicable pay or play penalty, unless... An employer elects to use the look-back measurement/stability period safe harbor Using this safe-harbor, an employer may determine if an employee is a full-time employee over a measurement period and apply that determination for a following stability period The measurement period must be between 3 and 12 months and a stability period must be at least 6 months or as long as the measurement period 32 Example of a 12-month measurement and stability period: Any employee that works at least 1,560 hours is a full-time employee (1,560/52 weeks = 30 hours) An employee s status in the measurement period is applied during a 12-month stability period, regardless of the number of hours actually worked in the stability period 33 11

12 An employer may use an administrative period of up to 90 days between the measurement period and stability period to determine which employees are full-time and offer them an opportunity to enroll in coverage Another example for calendar year based plan: M.P PY/S.P. A.P plan year: Measurement Period: May 1, 2013 Oct. 31, 2013 Administrative Period: Nov Dec. 31, 2013 Stability Period: January 1, 2014 December 21, plan year: Measurement Period: Nov. 1, 2013 Oct. 31, 2014 Administrative Period: Nov Dec. 31, 2014 Stability Period: January 1, 2015 December 21, Transitional Measurement period safe harbor: In 2013 only, an employer may use a measurement period that is less than 12 months and still use a 12-month stability period in 2014, if The measurement period is at least 6 months It begins by July 1, 2013; and It ends no later than 90 days before the first day of the 2014 plan year 12

13 New Employees A new employee is any employee that hasn t worked for the employer for at least one full standard measurement period New employees that are reasonably expected to work full-time on his or her start date must be offered coverage at or before the conclusion of the employee s initial three full calendar months of employment New Employees What if an employer cannot reasonably determine if a new employee will work full-time (e.g., the employee is a variable hours employee or a seasonal employee)? Employer may use an initial measurement period to determine if the employee works fulltime. The employee s status in the initial measurement period is applied during an initial stability period, that is generally as long as the initial measurement period Example: Employer adopts a 12-month initial measurement period for newlyhired variable hour employees Variable hour employee A is hired on May 9 of year 1 and works, on average, at least 30 hours per week during his initial measurement period 39 13

14 Variable hour employee A must be treated as a full-time employee for the subsequent initial stability period (which must be for a period of at least 12 months) regardless of whether he works less than full-time during the initial stability period Variable hour employee B is hired on May 9 of year 1 and does not work, on average, at least 30 hours per week during her initial measurement period 40 Variable hour employee B is not required to be treated as full-time for the subsequent initial stability period (which may not be longer than 13 months) even if she works on a full-time basis during the initial stability period The pay or play penalty applies to calendar year based plans on January 1, 2014 The pay or play penalty applies to noncalendar year based plans on January 1, 2014, unless the plan qualifies for transitional relief. If the plan qualifies for transitional relief, the pay or play penalty will not apply until the first day of the plan s 2014 plan year 14

15 A non-calendar year based plan will qualify for transitional relief, if: As of December 27, 2012, 25% of all employees were covered under the plan, or As of the most recent open enrollment period before December 27, 2012, 33% of all employees were offered coverage under the plan 43 Other Fees Under 44 Other Fees Under Medicare Hospital Insurance Payroll Tax - Currently, the Medicare hospital insurance payroll tax for employees is 2.9% (1.45% paid by the employee and 1.45% paid by the employer, with self-employed individuals paying 2.9%) Beginning in 2013, higher income taxpayers with wages in excess of $200,000 (if single) or $250,000 (if married and filing jointly) will be subject to an additional.9% Medicare hospital insurance payroll tax on wages in excess of those thresholds 45 15

16 Other Fees Under The IRS has recently issued regulations on this tax The regulations clarify that employers should withhold for the new tax on wages paid to an employee in excess of $200,000 for the year (regardless of the employee s other income or tax filing status) In addition, these individuals will be subject to a 3.8% tax on their net investment income which includes interest, dividends and royalties. However, net investment income for this purpose does not include distributions from a 401(k) plan or other qualified retirement plans 46 Other Fees Under PCORI Fee - For plan years ending on and after October 1, 2012, a new fee will be assessed to finance comparative clinical effectiveness research through the Patient-Centered Outcomes Research Institute (PCORI) For the first plan year the fee is based on the average number of covered lives (employees and dependents) under a health plan multiplied by $1 The multiplier increases to $2 for the next plan year ending on or after October 1, Other Fees Under For plan years ending on or after October 1, 2014 the fee will be increased based on national health spending The fee no longer applies for plan years ending after October 1,

17 Other Fees Under The following health benefits are not subject to the fee: Excepted benefits such as stand-alone dental and vision plans and most medical FSAs HSAs (but the HDHP is subject to the fee) Most EAPs, disease management programs and wellness programs if they do not provide significant benefits in the nature of medical care or treatment 49 Other Fees Under Hospital indemnity coverage Stop-loss insurance If an HRA is integrated with the employer s self-funded group health plan, no separate tax applies However, if the HRA is integrated with the fullyinsured group health plan, a separate fee does apply (but is only based on employees; dependents are disregarded) 50 Other Fees Under Retiree only plans are subject to the fee Fee is based upon number of covered lives, so both employees and dependents are counted The regulations provide several alternative methods for counting the average number of covered lives during a year Actual count Snapshot count Form 5500 method 51 17

18 Other Fees Under COBRA qualified beneficiaries are covered lives for this purpose 52 Other Fees Under In the case of fully-insured plans, the fee is payable by the insurer. In the case of selffunded plans, the fee is payable by the employer The fee will be reported on IRS Form 720 and paid once per year by July 31 (July 31, 2013 for the initial year) 53 Other Fees Under The PCORI fee must be paid by July 31 of the calendar year immediately following the last day of the plan year Thus, an employer with a calendar year plan will pay its first PCORI fee by July 31, 2013 On the other hand, if the employer s first plan year ending on or after October 1, 2012 ends on May 31, 2013, the first PCORI fee must be paid by July 31,

19 Other Fees Under Temporary Reinsurance Program A new fee is imposed on group health plans to fund reinsurance for insurers in the individual market Fee is imposed during 2014, 2015 and 2016 Goal is to raise $25 billion $20 billion for reinsurance $5 billion to U.S. Treasury 55 Other Fees Under Fee is front-end loaded it will raise $12 billion in 2014, $8 billion in 2015 and $5 billion in 2016 A state may also impose a supplemental reinsurance fee on fully insured plans, but not self-insured plans IRS proposed regulations issued in December 2012 estimate the fee for 2014 to be $63 per covered person 56 Other Fees Under If the plan is fully-insured, the fee is paid by the insurer if the plan is self-insured, the fee is imposed on the plan (but likely will be sent in by the TPA) Applies to plans that provide major medical coverage the following types of plans are excluded: Stand-alone vision and dental plans Stand-alone prescription drug plans HSAs (but the HDHP is subject to the fee) 57 19

20 Other Fees Under HRAs that are integrated with a fully-insured or self-funded group health plan Medical FSAs (even if not an excepted benefit) Most EAPs, disease management programs and wellness programs (if they do not provide major medical coverage) Hospital indemnity coverage Stop-loss insurance 58 Other Fees Under Fee is based upon number of covered lives, so both employees and dependents are counted The regulations provide several alternative methods for counting the average number of covered lives during a year Actual count Snapshot count Form 5500 method Similar to methods for calculating PCORI fee 59 Other Fees Under There is no exception for retiree only major medical plans Special rules apply if a person is also covered by Medicare: If the group health plan provides primary coverage, a fee must be paid for the person If Medicare provides primary coverage, no fee is paid for the person As a result, retiree plans provided as a supplement to Medicare are exempt 60 20

21 Other Fees Under Fee applies on a calendar year basis, even if the plan has a different plan year Mechanics No later than November 15 of each year, the insurance company or TPA (the contributing entity ) submits a count of covered lives for that year to HHS HHS informs the contributing entity of the fee for the year the same fee per covered life applies to every group health plan 61 Other Fees Under The total charged is the sum of the following: the amount to be raised for the reinsurance pool and the U.S. Treasury that year, plus the administrative costs of collecting the fee and administering the reinsurance pool. This total is divided by the estimated number of covered lives subject to the fee. The contributing entity must pay the fee within 30 days after receiving the invoice 62 Other Fees Under The only good news: the fee is tax deductible and is a permissible plan expense under ERISA 63 21

22 Other Requirements Under 64 Other Requirements Under Waiting Period Beginning in 2014, health plans may not impose a waiting period of longer than 90 days for newly eligible employees A first of the month after 90 days rule will not comply 65 Other Requirements Under 66 Cap on Deductibles for small employer plans For plan years beginning in 2014 the deductible under a small group fully-insured plan cannot exceed $2,000 for single coverage/$4,000 for two-person or family coverage A small employer for this purpose is: Prior to January 1, 2016, an employer that employs 50 or less employees during the preceding year January 1, 2016 and after, an employer that employs 100 or less employees during the preceding year The dollar thresholds will be increased in future years for increases in health care costs 22

23 Other Requirements Under 67 Maximum out-of-pocket limits for single and two-person/family coverage: For plan years beginning on or after January 1, 2014, out-of-pocket maximums cannot exceed limits for qualified High Deductible Health Plans For 2013, the limits are $6,250 single / $12,500 two-person or family Those amounts may be increased annually for increases in health care costs These limits don t include out-of-network charges Other Requirements Under Automatic Enrollment Employers with more than 200 full-time employees will be required to automatically enroll newly eligible individuals and reenroll existing employees This requirement will not take effect until after regulations are issued Rulemaking is expected to be completed by Other Requirements Under Nondiscrimination Self-funded group health plans have been subject to nondiscrimination rules for many years Those rules prohibit discrimination in favor of highly compensated individuals with regard to eligibility and benefits Historically, fully-insured group health plans have not been subject to nondiscrimination rules 69 23

24 Other Requirements Under That distinction changed under Health Care Reform. Now fully-insured, non-grandfathered group health plans will be subject to similar nondiscrimination rules to the rules for selffunded plans In December 2010, the IRS announced that it is drafting regulations to implement this new requirement and that it will not require fullyinsured, non-grandfathered group health plans to comply with this provision until plan years beginning after a certain period of time following the issuance of regulations 70 Other Requirements Under Notice of Exchange Availability Beginning in 2013 employers must provide individuals with a notice regarding the availability of the state exchanges which must be in place by 2014, and the premium credits and cost-sharing subsidies available to low income individuals if they enroll in coverage on the exchange 71 Other Requirements Under These notices were originally required to be provided by March 1, In late January, this deadline was extended. The DOL has not issued the new deadline but it is expected to be late summer or early fall DOL will issue a model notice 72 24

25 Other Requirements Under Exchanges - Beginning in 2013, employers will be required to interact with the exchanges to verify an employee s eligibility for employer group health coverage in order to administer the potential financial assistance for low income individuals applying for exchange coverage Guidance is expected to be issued in Other Requirements Under IRS Reporting for - Beginning in 2014, employers with 50 or more fulltime employees must report to the IRS whether they offer minimum essential coverage to employees. This information is required in order to administer the pay or play penalty Regulations are expected to be issued detailing the reporting requirements 74 Other Requirements Under Medical Loss Ratios - Employers sponsoring fully-insured group health plans (as opposed to self-funded plans) may be receiving rebates pursuant to the medical loss ratio (MLR) rules of The purpose of the MLR rules is to require insurers to deliver transparency and value in connection with health insurance policies Under the rules, insurers must spend a minimum percentage of collected premium dollars on claims as opposed to profits and indirect costs such as administration and marketing 75 25

26 Other Requirements Under While the rebate may be welcome dollars for the employer, the portion of the rebate attributable to participant (employee) contributions will generally be considered a plan asset under ERISA The ERISA fiduciary rules require plan assets to be used for the exclusive benefit of participants 76 Other Requirements Under The U.S. Department of Labor (DOL) has issued guidance as to permissible methods of applying the portion of any MLR rebates which constitute plan assets Those methods include cash refunds, using the proceeds to reduce future premiums, and/or using the rebate to enhance benefits (e.g., introduce a wellness benefit) 77 Other Requirements Under Rebates provided to participants in cash or which cause a reduction in the employee s pre-tax premium contributions in the year in which the rebate is paid are subject to federal income taxes and payroll taxes The rebate should be distributed as soon as administratively feasible. If the rebate is not used within 3 months, ERISA requires the rebate to be held in trust 78 26

27 Other Requirements Under Wellness - Currently, under the HIPAA nondiscrimination rules, employees enrolled in an employer s health plan may be provided with incentives/penalties to participate in a wellness program based on one or more health status factors The wellness program must satisfy certain requirements, including a cap on the incentive/penalty; it may not exceed 20% of the cost of coverage under the employer s health plan 79 Other Requirements Under increases the 20% limit to 30% beginning with the 2014 plan year Further, the IRS, DOL and HHS have issued proposed regulations increasing the 30% limit to 50% in the case of programs designed to reduce or prevent tobacco use 80 Exchanges and Coverage From Exchanges 81 27

28 Exchanges and Coverage From Exchanges Individual mandate individuals must obtain health insurance with minimum essential coverage or pay a penalty Minimum essential coverage is available through public programs, the exchange or an employer plan Non-grandfathered employer plans may have to make additional changes in 2014 in order to constitute minimum essential coverage (e.g., coverage for clinical trials) 82 Exchanges and Coverage From Exchanges The penalty is the greater of a flat dollar amount or a percentage of household income The flat dollar amount is $95 for 2014, $325 for 2015 and $695 for For later years, the flat dollar amount will be increased for changes in the cost-of-living The percentage of household income is 1% for 2014, 2% for 2015 and 2.5% for 2016 and later years 83 Exchanges and Coverage From Exchanges Exchanges - the first component of this new structure will be that each state must maintain an exchange to help individuals and groups shop for health coverage in a more efficient and comprehensive manner A state can form its own exchange or partner with the federal government, or if the state does not prefer either option, the federal government will come in and establish and operate an exchange for the state 84 28

29 Exchanges and Coverage From Exchanges It appears that most states will not establish their own exchange and will look to the federal government to establish an exchange for the state 85 Exchanges and Coverage From Exchanges Will the coverage offered on the exchange be attractive to employees and how much will it cost? Each option on the exchange must offer a package of essential health benefits There will be four prescribed coverage levels: Bronze designed to provide benefits actuarially equivalent to 60% of full value Silver designed to provide benefits actuarially equivalent to 70% of full value 86 Exchanges and Coverage From Exchanges Gold designed to provide benefits actuarially equivalent to 80% of full value Platinum designed to provide benefits actuarially equivalent to 90% of full value 87 29

30 Exchanges and Coverage From Exchanges Example of Silver Plan from Kaiser Family Foundation Deductible Single Family Coinsurance Single Limit Family Limit Out of Pocket Maximum Single Family $1,550 $3,100 70/30% $2,650 $5,340 $4,200 $8, Exchanges and Coverage From Exchanges Estimated Single Cost & Government Subsidy for Silver Plan 89 Annual Income $30,000 $50,000 $70,000+ Age 30 Cost Gov t Subsidy Employee Cost: Age 40 Cost Gov t Subsidy Employee Cost: Age 50 Cost Gov t Subsidy Employee Cost: Age 60 Cost Gov t Subsidy Employee Cost: $3,440 $932 $2,508 $4,500 $1,991 $2,509 $6,978 $4,470 $2,508 $10,172 $7,663 $2,509 $3,440 $0 $3,440 $4,500 $0 $4,500 $6,978 $2,228 $4,750 $10,172 $5,422 $4,750 $3,440 $0 $3,440 $4,500 $0 $4,500 $6,978 $0 $6,978 $10,172 $0 $10,172 Exchanges and Coverage From Exchanges 90 Est. Family of 4 Cost & Gov t Subsidy for Silver Plan Annual Family Income Age 30 Cost Gov t Subsidy Employee Cost: Age 40 Cost Gov t Subsidy Employee Cost: Age 50 Cost Gov t Subsidy Employee Cost: Age 60 Cost Gov t Subsidy Employee Cost: $10,108 $8,127 $1,981 $12,130 $10,149 $1,981 $16,858 $14,877 $1,981 $24,042 $20,242 $3,800 $40,000 $70,000 $100,000+ $10,108 $2,513 $6,626 $12,130 $5,504 $6,626 $16,858 $10,232 $6,626 $24,042 $17,416 $6,626 $10,108 $0 $10,108 $12,130 $0 $12,130 $16,858 $0 $16,858 $24,042 $0 $24,042 30

31 What Will You Do? 91 What Will You Do? The actual cost of discontinuing the health plan will be more than the $2,000 per full-time employee penalty. While the cost of maintaining a health plan is a deductible business expense, the employer $2,000 penalty is not deductible 92 What Will You Do? Will employers offer replacement compensation/benefits? If an employer provides additional compensation to employees in lieu of health coverage, it may permanently increase the wage base, increase payroll taxes, increase the cost of compensation-related benefits (such as disability, life insurance and retirement benefits), and may actually disadvantage lower income employees if the additional pay causes them to lose eligibility for premium credit/subsidy 93 31

32 What Will You Do? Other possible responses: Reducing employee hours to fewer than 30 per week Does this trigger an ERISA Section 510 violation? Outsourcing certain business functions Introducing a low cost medical option with a low employee premium for single coverage 94 Tripp W. Vander Wal vanderwalt@millerjohnson.com Calder Plaza Building 250 Monroe Ave. NW, Suite 800 Grand Rapids, MI Radisson Plaza Building 100 W Michigan Ave, Suite 200 Kalamazoo, MI