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December 2016

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The Worldâ&#x20AC;&#x2122;s Leading Alternative Risk Transfer Journal Since 1984

Practicing Whatâ&#x20AC;&#x2122;s Always Been

Preached One SIIA member finally plunged into self-insurance for its own employees

strength in

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balance Experts in coverage solutions for single entities, groups and public entities, our integrated approach gives self-insureds greater stability and control over their self-funded plan. Unparalleled underwriting expertise, innovative risk management and in-house claims management, work in sync and in perfect balance for best possible outcomes.

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Self-Insurer’s Publishing Corp.

December

The Self-Insurer (ISSN 10913815) is published monthly by Self-Insurers’ Publishing Corp. (SIPC) Postmaster: Send address changes to The Self-Insurer P.O. Box 1237 Simpsonville, SC 29681

Editorial Staff PUBLISHING DIRECTOR Erica Massey

4 Practicing What’s Always Been

Preached

SENIOR EDITOR Gretchen Grote CONTRIBUTING EDITOR Mike Ferguson DIRECTOR OF OPERATIONS Justin Miller DIRECTOR OF ADVERTISING Shane Byars

One SIIA member finally plunged into self-insurance for its own employees Written by Bruce Shuntan

EDITORIAL ADVISORS Bruce Shutan Karrie Hyatt

2016

Volume 98

Outside the Beltway

SIIA Launches “2nd Half” Campaign To Support NY Groups of 51-100

18 ACA, HIPAA and Federal Health Benefit Mandates The Affordable Care Act (ACA), the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and other federal health benefit mandates 31

Section 1557: Removing the Gender Divide in Employer Medical Plans

Editorial and Advertising Office P.O. 1237, Simpsonville, SC 29681 (888) 394-5688

2016 Self-Insurers’ Publishing Corp. Officers

James A. Kinder, CEO/Chairman Erica M. Massey, President Lynne Bolduc, Esq. Secretary

ICCIE

Takes the Lead in

Captive Education

SIIA Endeavors Association Continues to Improve its Political Positioning During Times of Change

News from SIIA Members

Written by Karrie Hyatt

December 2016 | The Self-Insurer

Practicing Whatâ&#x20AC;&#x2122;s Always Been

Preached One SIIA member finally plunged into self-insurance for its own employees

Written by Bruce Shuntan

or 15 years, Premier Healthcare Exchange provided advanced network and cost management solutions to leading insurance companies, Taft-Hartley funds, HMOs and TPAs. And as a SIIA member, PHX clearly understood and appreciated the purpose and power of self-insurance. But it didnâ&#x20AC;&#x2122;t actual self-fund the health benefits coverage of its own workforce until Jan. 1, 2016.

PRACTICING WHAT’S PREACHED | FEATURE

The carrier’s evolution serves as a compelling argument in favor of the self-insured approach not only from a cost standpoint, but also larger strategic considerations involving the workforce. “Once we reached about 300 employees, there was enough scale to consider” switching from a fully insured to self-funded plan from a business perspective, explains Matt Hintz, CHRO of Zelis Healthcare, which earlier in the year acquired PHX and renamed it Claims Integrity. More than half of roughly 600 employees across the parent company’s three divisions are eligible for health insurance benefits. Sister companies include Network Solutions (formerly Stratose/GlobalCare) and Payments (formerly Pay-Plus Solutions) – both of which also this year transitioned from fully insured to self-funded health plans for their employees. The company has a smaller presence in Chicago, New Orleans and other parts of the U.S. Zelis’ technology platform serves the cost-containment and payments needs of more than 500 health care payers for medical, dental and workers’ compensation claims. It also delivers electronic payments and explanation of payments to more than 200,000 health care providers and offers patients provider lookups and medical referrals. Each Zelis unit has a long tradition of investing in their employees in terms of benefits, pay practices, training and a caring corporate culture, as well as career and leadership development. “And so, this is part of an overall compensation and employee-engagement strategy,” Hintz says. The company’s primary goal is to fuel the rapid expansion of its various divisions, while at the same time recognizing that employees are the most important asset in that growth. Recruitment and retention are critical to high-growth companies and Hintz considers selffunded benefits an integral part of that talent equation. While getting a better handle on employee health care costs is a huge motivation to selfinsure, Zelis was driven to reinvest any savings in its human capital. And while the Affordable Care Act has lured many smaller and midsize employers to self-insurance as a means of avoiding various fees and wresting control from insurers, it has had virtually had no impact on Zelis. The company would not release information about its fully insured health plan costs, describing the information as confidential. Hintz says the thinking behind the move to self-insure was “provide

the richest benefits we can and be in the right space to attract, develop and retain people.” Zelis employees now have a myriad of choices – from a high deductible health plan and comprehensive coverage to ancillary benefits that include dental and vision. Once a full year of expenses under each unit’s self-insured health plan can be evaluated, Zelis plans to recalibrate plan design based on usage. However, the immediate expectation is that there will be an overall reduction in plan administrative and utilization costs associated with the new approach.

Matt Hintz

Understanding benefits value While Zelis employees understand their health benefits far better than the average consumer of employer-provided insurance plans essentially because it’s the company’s core business, they’re still exploring unchartered territory. “We want our employees to understand the value of their benefits, and also to maximize their participation in the benefits, particularly things that keep them healthy,” Hintz explains. He credits a robust, hands-on and frequent communication process over the course of the company integration throughout open enrollment with helping achieve those objectives. The effort includes multiple sessions for employees, an onboarding program and town-hall format. “I do think that the interchange between the employee and certainly management and HR is pretty robust,” he adds. “The key to the employee communications have been the transparency by which we’ve operated.” December 2016 | The Self-Insurer

PRACTICING WHAT’S PREACHED | FEATURE

As this issue went to press, Zelis was about to hold another town hall meeting where employees would be brought up to speed on the growth of the enterprise’s disparate businesses and how they can share in the spoils.

about it,” according to Hintz. “We have a culture of caring about our clients. And then we take the time to make sure that they’re well versed and can explain the products that we sell, and that they can service those.” A recent Forrester Research, Inc. report suggests employee engagement at work and with their benefit plans is “a measurable workforce characteristic” that not only reduces turnover, but also drives customer satisfaction. Researchers analyzed the practices of 20 vendors whose software solutions promote higher employee engagement. Among the key levers: coaching and performance, communication, learning and careers, measurement, rewards and recognition, and health and well-being.

Hintz, who has been administering benefits for more than 25 years, believes the secret to success is when employees are more focused on their benefits than the type of coverage to which they’re transitioning. Then again, he lauds the deep knowledge of health care and sophistication of the company’s workforce, which certainly makes for an easier time at open enrollment. But it also spills into other aspects of the business. “We have almost no attrition of accounts, and that’s because they’re providing great service at the customer level, and they care

“Our overall people strategy is one of engagement so that we can engage our

clients, and you can’t do that without a robust benefits package and investing in your employees,” he explains. “We believe that the self-insured model keeps us sharp in terms of how we think about our investment in the benefits and how we care for employees.” The lesson for other employers is that they gain a competitive advantage when employees understand the cost of benefits and make better choices that will keep them healthier and more productive in the workplace. Hintz predicts that self-insurance will continue to trickle down market to smaller businesses because the health care consumerism trend is here to stay. Bruce Shutan is a Los Angeles freelance writer who has closely covered the employee benefits industry for nearly 30 years.

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The Self-Insurer | www.sipconline.net

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ICCIE

Takes the Lead in

Captive Education

he International Center for Captive Insurance Education (ICCIE) has been offering classes for only a dozen years, yet the organization has become a leader in the captive industry. ICCIE is working to help build the captive industry by providing quality education to captive professionals.

Written by Karrie Hyatt

“The Associate in Captive Insurance (ACI) professional designation was created by the captive insurance industry at the turn of the century because captive insurance leaders saw the need for an education program to raise the level of expertise in the growing industry and to provide a benchmark level of education for its practitioners,” said Mitch Cantor, ICCIE’s executive director.

What is ICCIE?

ICCIE is the only institution offering a degree in captive insurance. As the captive insurance sector began to grow in the 1980s and 1990s, professionals in the industry became aware of a gap in knowledge for those working in the captive sector. No universities or colleges were offering course work geared towards captive insurance. Risk management programs only mentioned captive insurance, but didn’t offer any detailed instruction.Yet as the captive sector continued to grow this gap in available education began to be problematic, especially in recruiting new talent to the field. Around 2000, the idea of forming a captive insurance education center began to be bandied about with the Vermont Captive Insurance Association (VCIA) taking the lead. In 2002, then new VCIA president, Molly Lambert, and her Board made establishing education for captive professionals a priority. According to Cantor, “VCIA sanctioned some outside market research to be done, and then paid for a feasibility study, and, finally, created ICCIE as an independent organization.” In 2003, ICCIE was organized as a 501(c)(3) nonprofit and the first ICCIE Board was established. The Board began working with the University of Vermont to create collegelevel course curriculum. Cantor was brought on in 2004 before the program was officially launched in August of that same year.

The Self-Insurer | www.sipconline.net

Originally, to earn an ACI, students had to complete five core courses, two electives, and three “hot topic” webinars or approved modules at captive conferences. The original five core courses were all launched at the same time in August 2004—these were An Introduction to Alternative Risk Financing Mechanisms, Understanding Risk and Risk Retention Mechanisms, Protecting the Captive: Actuarial Science, and Reinsurance, Forming and Operating a Captive, Business Ethics in the Captive Insurance Industry. The program generally takes about 18 months to complete for most students, but must be completed within three years. The first student to complete the ACI was in March 2005 and, as of this fall, there were

CAPTIVE EDUCATION | FEATURE

approximately 425 ACI graduates with around 1,400 working towards the degree. In September 2015, ICCIE launched a Certificate in Captive Insurance (CCI) degree, an intermediate level program that offers specializations in different areas of captive insurance knowledge. There were two main reasons for creating a mid-level designation. The first was that feedback from captive professionals indicated that many potential students weren’t interested in a full associates degree, but did want to pursue further education about the industry. When ICCIE reached out to the industry, asking the question “What is keeping you from pursuing an ACI?”, many responses indicated that it was the time needed to complete the course work or the cost of the degree.

The second reason is that with the addition of two core courses the ACI degree became more strenuous. “We had one course that covered two topics. We decided that both topics could use more instruction, so we divided it into two different courses and added more information,” said Cantor. “At the same time, we had an investments course as an elective. The feedback we got from a lot of people was that, ‘this is something everyone should really know and it shouldn’t be an elective.’ We talked about it in our Curriculum Committee meeting and it was unanimous to make it a requirement...People like the investments course and think it’s a necessary part of the required program.”

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The three types of CCI certificates are the CCI for general risk management professionals, the CCI-O for captive owners, and the CCI-M for captive managers. At this time, there are no CCI graduates. Cantor elaborated, “By definition, everyone who is an ACI [candidate] is also a CCI, so there are the same number of CCIs. Since the CCI is brand new there is no one who is only doing the CCI who has finished yet. We should have some standalone graduates soon, though.”

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CAPTIVE EDUCATION | FEATURE

ICCIE Looks to the Captive Community

“From day one we’ve had exceptional people stepping up to participate on the ICCIE Board, and that is in large part responsible for the organization’s success,” explained Cantor. From the very beginning, ICCIE has had huge support from the captive insurance community and takes full advantage of the expertise available. According to Cantor, “We have a Curriculum Committee of very experienced people in the industry who suggest (and field suggestions about) new course topics. They have a great feel for what the industry needs and is looking for.” ICCIE is constantly seeking feedback from its students, instructors, and the captive community to tailor instruction and course work to be the most beneficial. As many students come into the captive industry from an accountancy or law background, ICCIE needs to be flexible to get the education right for its students. Staying on top of student and industry needs has been a priority for ICCIE, allowing it to grow along with its student population.

Another reason for ICCIE’s success is their ability to attract quality instructors. “Once we know what we want to teach we reach out to leading industry professionals able to teach the new courses,” said Cantor. “Students have been very clear that the biggest strength of ICCIE is its faculty, so we are constantly on the lookout for great instructors–very knowledgeable people who are also excellent presenters–who want to serve the industry via its education program. We have had terrific success attracting such people.”

December 2016 | The Self-Insurer

CAPTIVE EDUCATION | FEATURE

College-Level Captive Education

As captive insurance continues to grow and claim a larger piece of the insurance sector, educating future leaders in the captive industry is becoming a key issue. Most college-level risk management courses only briefly touch on the subject of captive insurance and none offer a complete course. “Captives are ‘almost’ ignored at the college level,” said Cantor. “They usually get a brief mention, but considering the size and importance of the industry there should be a much greater presence.” To bridge this gap in education, ICCIE is launching a new initiative that will bring some of their curriculum to established risk management programs at colleges and universities. According to Cantor, “ICCIE will work with instructors to integrate the ICCIE course material into their current courses, providing they do so under certain guidelines. This material and guidance will be provided by ICCIE at no cost to the students or the college/university, but just as a service to the captive and risk management industries.” This new initiative is still in its planning phase, but Cantor hopes to launch the program in 2017. ICCIE is currently reaching out to potential programs. The Institute hopes to start out with four or five programs and if the initiative proves successful, then continue adding more programs.

“It’s not a revenue thing for us,” added Cantor. “It’s not going to cost the students or the universities anything. We think it’s

important that people are exposed to captives as much as possible and that they have the opportunity to enter into a career in captives when they get out of their risk management program. If they decide to go into the captive arena, depending on which college program they do, they will have finished either one or two ICCIE courses which will be a big benefit.”

Creating Captive Professionals for the Future

A growing worry among captive professionals is how to cultivate talent for the burgeoning industry. Many of those professionals who worked to build the captive industry in the 1980s and 1990s are nearing retiring age, yet not as many new professionals are entering the sector as will be needed. ICCIE hopes to be a leader in cultivating new talent. Cantor is taking a proactive approach by canvassing captive managers and captive owners about how they are approaching this issue. Next spring, he will be presenting a panel at the Captive Insurance Companies Association’s (CICA) annual meeting to go over his findings and connect with captive professionals to see how to go forward. But if ICCIE’s first 12 years of operation is any indication, it will become a touchstone for training up new talent with its innovative way of tailoring course work and instruction. It will continue to grow and adapt just as the captive industry has proved so adept at doing.

The Self-Insurer | www.sipconline.net

Karrie Hyatt is a freelance writer who has been involved in the captive industry for more than ten years. More information about her work can be found at: www.karriehyatt.com.

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OUTSIDE

the Beltway written by Dave Kirby

SIIA Launches “2nd Half” Campaign To Support NY Groups of 51-100 A couple of months prior to opening day of the 2017-18 New York Legislature in Albany, SIIA launched the second half of its campaign to protect stop-loss plans for the state’s self-insured employer groups of 51-100, which are deemed vital to continue viable employee benefit plans for thousands of New Yorkers.

“We considered the time between the end of the 2016 legislative session and the beginning of the new session as halftime in our campaign to protect self-insured employers’ health plans,” said Adam Brackemyre, SIIA vice president for state government relations. “It’s important to be ready to hit the ground running when the new legislature convenes in January.”

At issue is the repeal of an earlier New York bill that would end the access to stop-loss insurance for self-insuring employers of groups of 51-100 that was passed to bring the state into compliance with definitions under the federal Affordable Care Act (ACA). Earlier this year SIIA succeeded in supporting legislation that pushed back the prohibition until 2018 for existing stop-loss plans. “Now our focus is to block this prohibition entirely when the temporary fix expires,” Brackemyre said.

To launch next year’s campaign, SIIA convened a meeting of two dozen members in New York City where they discussed the best ways to leverage the political strength of the state’s small and medium-sized employers as well as the self-insurance industry. 16

The Self-Insurer | www.sipconline.net

“Everyone is familiar with the concept of grassroots political advocacy, and we want to add the element of ‘grasstops’ activism by business people who are well positioned to influence members of the New York Senate and Assembly in their home towns,” said lobbyist Tom Faist of Albany who assists SIIA in communicating with the New York Legislature. “If SIIA members can convince enough legislators to support this issue to their chamber and committee leaders of the Senate and Assembly, we’ll stand a better chance of success.”

“There’s really no reason that every SIIA member in New York can’t participate in this campaign,” said Larry Thompson, chairman of SIIA’s Government Relations Committee, who led the New York City meeting. He said that the political strength of SIIA members can be multiplied many times by bringing self-insuring employers into the campaign.

“Availability of stop-loss insurance is what enables employers to self-insure,” says Dr. Aalap Majmudar of Signal Health, a care management company headquartered in New York City with board-certified medical specialists located throughout the U.S., who participated in SIIA’s New York meeting. “Our mission is to serve the most severe patient cases according to the best practices of leading treatment centers with local geographic convenience and high-value outcomes.”

Left to Right: Tom Gibbons, Swiss Re, Dr. Aalap Majmudar, Signal Health, George Breen, EthiCare Advisors, Kate Thurson, Pareto Health Thompson’s outline of SIIA members’ political advocacy tactics begins with identifying employers and union benefits plans that would be affected by the stop-loss prohibition and mobilizing them to contact their own members of the legislature.

“Key people in each constituent organization can appreciate that it is in their self-interest to support SIIA’s efforts to protect their employee benefits plans. The flow of communications will include SIIA-developed model letters and talking points for use in making the case to legislators.”

Thompson believes the New York campaign is indicative of increasing political activity for SIIA in federal and state government. “I believe 2017 will be one of our most active years since we joined in the successful effort to forestall Hillarycare back in 1994,” he said. “Everyone knows that something has to be done about the ACA where many will lose health coverage because of higher costs. Self-insurance will continue to face mounting opposition by some state insurance commissioners and the traditional for-profit health insurance industry.”

In New York it will be important to convince legislators that the prohibition of stop-loss programs for groups of 51-100 will have devastating impact on employer plans serving many thousands of employees and dependents.

Signal Health focuses on smaller employee groups. “These can be the most flexible plans that allow for the greatest innovation in care,” says Dr. Majmudar. “They really drive the market for optimized, value-based medical outcomes.

“We care for the sickest of the sick where we can provide the most value to selfinsured employers. Without stop-loss insurance, those employers would be forced back into the traditional market where they would experience vastly more expensive fee-for-service healthcare.” Dr. Majmudar said his SIIA-member organization looks forward to participating in the campaign to repeal New York’s prohibition of stop-loss insurance for groups of 51-100.

SIIA members who wish to join the state government relations advocacy team are invited to contact Adam Brackemyre at the Washington, DC, office, (202) 463-8161 or abrackemyre@siia.org.

December 2016 | The Self-Insurer

ACA, HIPAA AND FEDERAL HEALTH BENEFIT MANDATES:

Practical

Q& A T

he Affordable Care Act (ACA), the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and other federal health benefit mandates (e.g., the Mental Health Parity Act, the Newborns and Mothers Health Protection Act, and the Womenâ&#x20AC;&#x2122;s Health and Cancer Rights Act) dramatically impact the administration of self-insured health plans. This monthly column provides practical answers to administration questions and current guidance on ACA, HIPAA and other federal benefit mandates. Attorneys John R. Hickman, Ashley Gillihan, Carolyn Smith, and Dan Taylor provide the answers in this column. Mr. Hickman is partner in charge of the Health Benefits Practice with Alston & Bird, LLP, an Atlanta, New York, Los Angeles, Charlotte and Washington, D.C. law firm. Ashley Gillihan, Carolyn Smith and Dan Taylor are members of the Health Benefits Practice. Answers are provided as general guidance on the subjects covered in the question and are not provided as legal advice to the questionerâ&#x20AC;&#x2122;s situation. Any legal issues should be reviewed by your legal counsel to apply the law to the particular facts of your situation. Readers are encouraged to send questions by E-MAIL to Mr. Hickman at john.hickman@alston.com.

The Self-Insurer | www.sipconline.net

• If the wellness program is made available to all employees without regard to whether the employee participates in the employer’s group health plan, then furnishing the group health plan’s privacy notice to employees who participate in the wellness program but not the group health plan may cause confusion or cause the employee to ignore the information. The EEOC recommends against sending the ADA notice with a lot of information unrelated to the wellness program.

Navigating the Winding Highway of Wellness Program Compliance A GPS for the EEOC’s Wellness Program Rules The road to health plan compliance has never been straight and narrow, but it has become more winding over the years, due in large part to the Affordable Care Act (ACA). The road to compliance just became even more difficult with the issuance of two new final regulations by the Equal Employment Opportunity Commission (EEOC) that implement certain provisions of the Americans with Disabilities Act (ADA) and the Genetic Information Nondiscrimination Act (GINA). The final ADA-related regulations (“Final ADA Regulations”) and the final GINA-related regulations (“Final GINA Regulations”) join the existing wellness regulations previously issued by the tri-agencies—Departments of Labor (DOL), Treasury and Health and Human Services (HHS)—that implement the bona fide wellness program rules of the Health Insurance Portability and Accountability Act (HIPAA), as amended by the ACA and Title I of GINA. This article will serve as part 2 of a GPS for sponsors and administrators of wellness programs to help navigate the road to compliance with the ADA and GINA rules. Part 1 can be found in the November issue of The Self-Insurer.

How does the notice requirement in the Final ADA Regulations align with HIPAA’s privacy rules? Many wellness programs that are group health plans or that are offered in connection with group health plans are also subject to HIPAA’s privacy rules, which require health plans to furnish a notice to covered individuals that contains information similar to the information required in the ADA notice. Will the HIPAA privacy notice operate to satisfy the notice requirement of Final ADA Regulations? Perhaps, but we recommend employers consider the following before relying on the HIPAA privacy notice to satisfy the ADA notice requirements:

• HIPAA’s privacy rules only require plans to provide the notice after an individual becomes covered and only after there is a change in the notice. Otherwise, plans are merely furnishing covered individuals with reminders every three years of its existence and where to locate it. If the wellness program is made available every year, we recommend that employers provide the ADA notice every year. This may not coincide with the frequency with which the HIPAA notice is furnished.

What are the applicable limitations on inducements? A wellness program that includes DRIs or requires an ME must be voluntary. While some would argue that a financial inducement does not make a program involuntary1, the EEOC does not necessarily see it that way. According to the EEOC, if a wellness program that includes DRIs or requires an ME offers inducements (reward or penalty) to participate, the inducement cannot exceed the 30 Percent Limit (i.e., 30 percent of the total cost of self-only coverage for the Benchmark Plan). Any inducement that exceeds the 30 Percent Limit is, according to the EEOC, coercion. The Final ADA Regulations provide rules for calculating the 30 Percent Limit in each of these instances. The chart below summarizes these rules for various common situations. December 2016 | The Self-Insurer

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Situation

Benchmark Plan

Employer maintains only one group health plan option. This situation is a combination of the categories described in 1630.14(d)(2)(i) and (ii) This situation includes programs that are limited to employees who enroll in the group health plan or that are made available to employees without regard to whether they enroll in the health plan.

30% of the total cost of self-only coverage under the one health plan option offered to employees.

The employer maintains multiple group health plan options and limits the inducement to those employees who enroll in a specific health plan option. For example, the employer offers a PPO and HDHP but limits the inducement to those who enroll in the HDHP. Although this situation is not clearly described in one of the categories in 1630.14(d)(2), a close examination of the rules and the manner in which EEOC interprets the term “plan” indicates this situation falls within the category described in 1630.14(d)(2)(i)

30% of the total cost of self-only coverage for the specified option in which the employees must enroll to receive the inducement.

This situation includes programs that are made available to all employees without regard to whether they enroll in the health plan but that limit the inducements to employees who enroll in a specific health plan option. Employer maintains multiple group health plan options but does not limit the inducement to those who enroll in a specific health plan option. This situation includes a program that is made available to all employees but limits the inducement to those who enroll in any of the health plan options. It also includes a program that is limited to those who enroll in any of the health plan options and provides the inducement to any such employee Employer maintains multiple group health plan options but offers a different wellness program with each option and limits the inducement for each program to those who enroll in the plan. For example, the employer maintains a PPO and HDHP. Those that enroll in the PPO are eligible for a premium reduction if they complete a health risk assessment. Employees who enroll in the HDHP are eligible for a premium reduction if they complete a biometric screening. The program is not available to employees who do not participate in the program. Employer does not offer any group health plan options.

30% of the total cost of self-only coverage for the lowest-cost group health plan option maintained by the employer without regard to the option in which the employee actually enrolls

Although not specifically addressed in the Final ADA Regulations, we believe it is a reasonable interpretation of the Final ADA Regulations to conclude that the Benchmark Plan in this situation is the plan in which the employee is enrolled since the wellness program is different for each health plan option

0% of the total cost of self-only coverage for the second-lowest-cost silver plan for a 40-year-old nonsmoker in the state or federal health care exchange in the state of the employer’s principal place of business

December 2016 | The Self-Insurer

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NOTE: In light of guidance issued by EEOC in an information letter addressed to Alston & Bird LLP dated August 21, 2016, it is clear that the EEOC interprets the reference to “plan” in the rules to mean health plan option. The Final ADA Regulations do not prescribe a method for calculating the “total cost” of self-only coverage. Presumably, employers may follow the rules for calculating the applicable premium under COBRA; however, the regulations do not foreclose the use of alternative methods.2 The Final ADA Regulations also clarify that the 30 Percent Limit applies to any financial or in-kind incentives, such as DRI or MEs. Thus, the 30 Percent Limit might apply to an inducement in the form of a gift card or other non-cash item, such as an iPad or gym membership.

What if the participant can obtain If an employer the full inducement without the offers a minimum essential DRIs or MEs? coverage (MEC) only plan that provides only ACA mandated preventive care How do the inducement rules apply when (a so-called “skinny plan”) the employee health program includes DRIs as one of its options, the or MEs but participants can obtain the full total cost of the self-only inducement offered without responding to coverage for the MEC will the DRIs or completing the MEs? Consider the following illustration: be the Benchmark Plan in ABC Company provides employees with most cases. This may have a $300 per month premium reduction if an adverse impact on the wellness program due to the they complete any two of the following five action items: relatively low cost of an MEC plan. • They record their physical activity Practice Pointer:

during the week

•

They record the food that they have eaten during the week

•

They take a stress relief class

•

They take a class on healthy eating

• They complete a health risk assessment In the above list, only the health risk assessment is a DRI. Moreover, the $300 per month premium reduction exceeds the 30 Percent Limit. In the above example, the wellness program includes a DRI—the health risk assessment—but the participants in the program can obtain the full inducement— the $300 per month premium reduction— without completing the health risk assessment. Does this program violate the Final ADA Regulations merely because the program includes a DRI, even though the participants can obtain the inducement without completing the health risk assessment? EEOC officials indicate that the inducement offered by the wellness program would not be subject to the 30 Percent Limit (or the notice requirement) to the

December 2016 | The Self-Insurer

extent that the inducement was available to participants without regard to the DRI or ME. Thus, even though a program might include DRIs and/or MEs, the 30 Percent Limit will not apply if the employees or participants do not have to respond to the DRIs or take the MEs to obtain the full inducement. Likewise, if a program includes various components with different inducements that can be satisfied separately, only the inducements related to DRIs or require MEs must comply with the 30 Percent Limit. Consider the following illustration: ABC Company maintains a wellness program that has three components, each of which has a corresponding inducement: •

Complete a health risk assessment in exchange for a $100 premium reduction

•

Complete a biometric screening in exchange for a $50 premium reduction

• Participate in an educational session on nutrition in exchange for a $50 premium reduction In this situation, the 30 Percent Limit applies to the combined inducements for the health risk assessment and the biometric screening, but not to the inducement for the educational session because it does not contain any DRIs or MEs.

Is it permissible to offer the wellness program to all employees but limit the inducement to those who enroll in the employer’s health plan? According to informal conversations with EEOC officials, it is permissible; however, the employer must follow the rules described above to determine the 30 Percent Limit. Practice Pointer:

When is a program reasonably designed to promote health and prevent disease?

An employee health program, including DRIs and MEs offered as part of the employee health program, must be reasonably designed to promote health and prevent disease, even those that do not include disability-related inquiries or medical exams. According to the Final ADA Regulations, the program must have a reasonable chance of improving health or preventing disease, must not be overly burdensome or time consuming, and must not be a subterfuge for violating the ADA or any other federal law. Examples of programs that do not satisfy this standard include: •

A program that requires a significant amount of time to obtain a reward.

•

A program that imposes unreasonably intrusive procedures.

• A program that imposes significant costs related to medical examinations.

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•

A program that exists mainly

to shift costs to targeted

employees. •

A program that exists simply

to collect information for the

employer to estimate future health care costs.

In addition, wellness programs that collect medical information through a measurement, screening or test without follow-up information or advice designed to improve health would not be reasonably designed to promote health or prevent disease unless the collected information is actually used to design a wellness program that addresses at least a subset of the conditions identified through the program.

What are the applicable confidentiality requirements?

Under the ADA’s confidentiality provisions, employer-sponsored wellness programs may not: •

Disclose identifiable medical information to the employer except as necessary for the employer to administer the health plan.

•

Require employees to waive confidentiality protections or agree to the sale or

exchange of medical information as a condition of participating in the program.

Read literally, employers who sponsor wellness programs that are not limited to health plan participants arguably will not be able to obtain any identifiable medical information obtained through the wellness program. Such employers will be limited to information regarding participation (did the employee participate or not). Likewise, employers who sponsor wellness programs that are limited to health plan participants will not be able to receive any identifiable medical information obtained through the wellness program unless the information is necessary to administer the health plan. The ADA’s confidentiality requirements are similar to HIPAA’s privacy requirements; however, there is a key difference between the two. HIPAA’s rules only apply to health plans, while wellness programs subject to the ADA might not qualify as a health plan subject to HIPAA. For example, if a wellness program provides an inducement to employees who log physical activity each week, the wellness program is likely not a health plan subject to HIPAA but it would be a wellness program subject to the ADA’s confidentiality requirements.

Under what circumstances would an employer be required to make a reasonable accommodation for a wellness program?

If an employee is unable to participate in the wellness program due to a disability, the employer must provide an alternative in accordance with the ADA’s rules. For example, if the employer provides a reward for employees who walk or exercise a specified amount of time each week, the employer would be obligated to provide a reasonable alternative to an employee who is unable to satisfy the requirements due to a disability.

December 2016 | The Self-Insurer

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Does the ADA’s bona fide employee benefit plan exception apply?

Despite two recent court decisions indicating that it does, the EEOC does not agree. 3 The Final ADA Regulations make clear, in no uncertain terms, that the EEOC does not believe that the bona fide employee benefit plan exception to the ADA’s requirements applies in the context of employee health programs. A recent court decision seems to support this position.4

The Road to Compliance—the Final GINA Regulations

Which wellness programs are subject to the Final GINA Regulations?

A wellness program is generally subject to the Final GINA Regulations if the wellness program is maintained by a private or state or local governmental employer with 15 or more employees for each working day in at

least 20 calendar weeks in the current or preceding calendar year (similar to Title I of the ADA).

In what ways do the Final GINA Regulations regulate wellness programs?

The 2010 GINA regulations set the stage by indicating that employers who offer health or genetic services, including a wellness program, are not in violation of GINA if the employer obtains an individual’s genetic information to the extent the following requirements are satisfied:

•

The individual’s identifiable genetic

information collected through the

program is used solely for purposes of the program and none of the information collected is disclosed to the employer except in aggregate, de-identified form.

The Final GINA Regulations were primarily issued to address a discrete issue—the extent to which inducements can be offered in exchange for information regarding the manifestation of disease or disorder (i.e., current or past medical history) of an employee’s family members. The Final GINA Regulations make the following clarifications:

• •

The individual voluntarily provides the information. Information is not considered to be voluntarily provided if a penalty is imposed on individuals who choose not to provide such information.

•

The individual provides prior,

written authorization.

An inducement may be provided to the employee only in exchange for information regarding a spouse’s manifestation of disease, and then only to the extent the spouse provides the authorization required by the 2010 GINA regulations. No inducement may be offered in exchange for a spouse’s genetic information (other than medical history) or the genetic information and/or medical history of a child.

December 2016 | The Self-Insurer

The regulations make no distinctions between adult or minor children and natural and adopted children. Moreover, the 2010 GINA regulations define “genetic information” to include the genetic information of a fetus carried by an employee or family member of an employee. Practice Pointer:

•

In accordance with the 2010 GINA regulations, the information

collected may only be used for the program, and no information may be provided

to the employer except in aggregate, de-identifiable form.

Unlike the Final ADA Regulations, the Final GINA Regulations, in conjunction with the 2010 GINA regulations, do not appear to allow disclosure of identifiable information to the employer to administer the health plan. It is unclear if this is an intentional limitation or an oversight. Such a limitation could have a significant impact on plans that use health risk assessments and screenings. Practice Pointer:

The wellness program must be reasonably designed to promote health. This is essentially the same standard espoused by the EEOC in the Final ADA Regulations.

•

The request for such information must be made as part of a health risk assessment. The Final GINA Regulations clarify that this may be through a questionnaire, medical exam or both.

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•

The employer may not exclude a spouse from participating in a health plan, restrict access to health plan options or otherwise retaliate against the employee or the spouse who chooses not to participate from participation in or restrict access to health coverage.

• If the employee and spouse are offered the opportunity to participate in the program, the

Arriving at Your Destination

inducement to each may not exceed 30 percent of the total cost of self-only coverage (30 Percent Limit) under the applicable group health plan (Benchmark Plan). Much like the Final ADA Regulations, the Final GINA Regulations provide specific rules for identifying the Benchmark Plan, which vary depending on whether the employer offers group health plan coverage or not. These rules are identical to the rules prescribed in the Final ADA Regulations for identifying the applicable Benchmark Plan.

Charting a course for compliance with the Final ADA and GINA Regulations is no small challenge, especially when you consider that the triagencies also have issued wellness program rules under both HIPAA and Title I of GINA. Part II will explore those rules and how they coordinate with the EEOC’s ADA and Title II GINA Rules. In the meantime, employers who sponsor wellness programs should input the following coordinates:

If the total cost of employee-only coverage for the Benchmark Plan is $3,000, then the total inducement offered for information regarding the spouse’s manifestation of disease would be $900. Practice Pointer:

•

The employer may not condition participation in the wellness program or provide any inducement to the employee or spouse in exchange for an agreement permitting the sale, exchange or disclosure of genetic information.

Practice Pointer: The

Final GINA Regulations clarify that tobacco usage is not considered “medical history” for purposes of GINA.

•

Carefully review your wellness programs to determine whether it includes DRIs or MEs.

•

Include an ADA-compliant notice in your wellness program materials and ensure that program participants receive that notice before they provide any information.

• If you offer inducements in connection with responses to DRIs or completion of MEs, ensure that all inducements related to DRIs and MEs (even if offered under different programs maintained by the same employer) do not exceed the 30 Percent Limit. •

If you provide inducements in exchange for information regarding a spouse’s manifestation of disease or disorder, be sure that the spouse provides a prior, written authorization for such information and that the information is kept confidential in accordance with the Final GINA Regulations.

References [1] EEOC v. Orion Energy Sys. Inc., 2016 WL 5107019 (E.D. Wis. 2016) (court held that a program shifting the entire cost of coverage to an employee was voluntary because “even a strong incentive is still no more than an incentive; it is not compulsion.”) [2] For example, the proposed regulations issued by the IRS on the “Cadillac tax” under Code Section 4980I have identified possible alternative methods for calculating the total cost of health coverage for purposes of the Cadillac tax, and those methods, once finalized, might be a sufficient basis for calculating the total cost under these rules. [3] Seff v. Broward County, 691 F. 3d 1221 (11th 2012); EEOC v. Flambeau, 2015 U.S. Dist. LEXIS 173482 (W.D. Wis. Dec. 30, 2015). [4] EEOC v. Orion Energy Sys., Inc., 2016 WL 5107019 (E.D. Wis. 2016). However, as noted above, the court disagreed with the EEOC’s determination of what is voluntary.

December 2016 | The Self-Insurer

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Section 1557: Removing the Gender Divide in Employer Medical Plans Written by: Jennifer M. McCormick

he fourth quarter is exciting. Not only do we have the holidays to look forward to, but we have so many opportunities and ideas to contemplate for the upcoming plan year. Generally, over the course of the year we see regulations take effect and guidance clarified, and even learn some new cost containment techniques. Unfortunately, this does not always mean that we know exactly what must be revised in our health plan documents for the upcoming plan year in order to ensure we fully implement these compliance updates and cost savings. To complicate matters, weâ&#x20AC;&#x2122;re on the edge of our seats to see whether (and how) the recent presidential election could further disrupt the Affordable Care Act (ACA). This is particularly true for some employer groups who are questioning what (if anything) they must modify in their health plan to comply with the ACA non-discrimination rule. In order to alleviate any heartburn this specific aspect of ACA may cause for the upcoming renewal season, letâ&#x20AC;&#x2122;s try and break down what Section 1557 really means for plan sponsors.

December 2016 | The Self-Insurer

What Is Section 1557? Section 1557 prohibits discrimination in certain health programs and activities on the basis of race, color, national origin, sex, age, or disability. It’s not news that discrimination against an individual on the basis of race, color, national origin or disability is prohibited – but – Section 1557’s expansion of these protected classes to now include discrimination on the basis of sex, is. As with other new regulations, the issued guidance leaves us with a lack of clarity and many unanswered questions; however, despite confusion and uncertainty, employers are still required to review and potentially revise internal processes and documents.

This article focuses on the new classification of “sex” and the new corresponding considerations for plan sponsors. For instance, if Section 1557 is applicable to an employer’s health plan, that plan cannot discriminate based on gender identity, meaning it cannot deny coverage based on an individual’s sex or gender identity (i.e. an individual’s internal sense of gender, which may be male, female, neither or a combination). Prior to making any Section 1557 related updates, however, it is important to understand what is required, and of whom. For example: (1) who must comply with Section 1557; (2) what does Section 1557 exactly require; (3) are there exceptions; and (4) what must change?

Who Must Comply? When more closely examined, the scope of Section 1557 is not particularly vast as it is only applicable to particular covered entities. For the purpose of this rule, a covered entity is an entity that operates a health program or activity, any part of which receives Federal financial assistance. Specifically, covered entities include all health programs and activities, any part of which receive federal assistance from HHS, health programs and activities administered by HHS (including the Federal Marketplace), and health programs and activities administered by entities under Title I of the ACA (including State Marketplaces).

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This generally means that an entity that receives a grant, loan, or subsidy or has another arrangement whether the federal government provides funds, services of federal personnel or property (real or personal) is subject to the Section 1557. Entities likely subject to Section 1557 include those involved in the administration of health care. For example, health insurance issuers, hospitals, health clinics, physiciansâ&#x20AC;&#x2122; practices, pharmacies, nursing homes, dialysis facilities, community health centers, providers that accept Medicare, and issuers on the Marketplace are generally subject to Section 1557. Once applicability of Section 1557 is confirmed, the entity must next make compliance related changes. Ensuring compliance is difficult, particularly since the text of Section 1557 describes what must not be done, instead of what must be done.

Whatâ&#x20AC;&#x2122;s Required? According to the rule, an entity subject to Section 1557 must not: (1) deny, cancel, limit or refuse to issue health coverage based on sex; (2) deny or limit a claim; (3) impose additional cost sharing; or (4) employ discriminatory marketing or benefit design. Specifically, this means a health plan must not deny or limit treatment for any health care that is ordinarily or exclusively available to individuals of one gender based on the fact that the person seeking

services identifies as belonging to another or different gender. While effective as of July 18, 2016, if Section 1557 requires changes to a health plan, the rule does not become effective for the health plan until the first day of the first plan year beginning on or after January 1, 2017.

Changes to a health plan will be necessary if the plan design denies coverage based on gender identity, denies treatment or access to facilities for sex-specific ailments, categorically excludes services related to gender transition or excludes transition related treatment as experimental or cosmetic. As a result, health plan documents must be carefully reviewed and any relevant exclusionary language timely removed.

December 2016 | The Self-Insurer

Additionally, entities subject to Section 1557 must comply with certain notice and tagline requirements. Unlike the health plan changes, these notice requirements took effect 90 days after the July 18, 2016 effective date. One of the requirements is that notice be placed in significant publications and significant communications targeted to beneficiaries, enrollees, applicants, and members of the public. While the term â&#x20AC;&#x2DC;significant publications and significant communicationsâ&#x20AC;&#x2122; has not been explicitly defined, the agencies suggested they will interpret this term broadly and it will not be limited to those publications or communications intended for a broad audience, but could also include those

directed at individuals. As a result, it will be important for employers to review their communications to ensure compliance with the notice requirements. Section 1557 outlines what must not be done with respect to benefits and requires that notices be included in certain materials, and hints at potential exceptions to these requirements.

Are There Any Exceptions? This rule does not include an exception, unlike other ACA requirements which allow for certain exemptions and accommodations (i.e. the contraceptive piece of the preventive care requirement). The rule, however, does state that certain protections already exist and Section 1557 would not displace regulations issued under the ACA related to preventive health services. Further, HHS did note that application of any requirement under Section 1557 which would violate applicable federal statutory protections for religious freedom and conscience is not required. Cases in multiple jurisdictions are currently underway and we expect to see additional guidance on this issue as a result of the litigation.

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(as long as it resulted from â&#x20AC;&#x153;a neutral rule or principleâ&#x20AC;? when adopted and the reason for its coverage decision was not a pretext for discrimination). If not subject to Section 1557, the health plan is not required to make benefit changes. The entity, however, should evaluate their risk tolerance as there is still the potential for the U.S. Equal Employment Opportunity Commission (EEOC) to investigate complaints of discrimination by the employer. Cases regarding plan exclusions of sex reassignment surgery are currently pending in the courts. Further, this should be a significant consideration after a federal court ruled on November 7, 2016 to deny a motion to dismiss a sex discrimination case that the EEOC had filed. Specifically, the EEOCâ&#x20AC;&#x2122;s motion explained that sexual orientation discrimination was a form of prohibited sex discrimination.

Additionally, a third party administrator (TPA) subject to Section 1557 does not render a plan for which it administers benefits automatically subject to Section 1557 (and vice versa). A TPA will only be liable for Section 1557 non-compliance if their own actions are discriminatory. As it relates to the notice requirement, the preamble to Section 1557 did note that entities subject to the rule may exhaust their current supplies of significant publications and communications prior to incorporating the required notice.

What Must Change? Guidance implies that Section 1557 will be interpreted broadly so entities must first decide if they are subject to the rule.

If subject to the rule, the health plan should be reviewed for compliance. Note that the rule does not explicitly require coverage of any particular service (either surgical or nonsurgical) to treat gender dysphoria, gender identity disorder, or any individual that is transitioning genders, exclusions or coverage limitations related to sex, gender dsyphoria or sexual orientation must be removed. However, if a plan has an exclusion for sex change surgery for individuals diagnosed with gender dysphoria, it should be removed or modified. Further, the rule does not require a plan to cover health care that is based on gender when the care is not deemed to be medically necessary (e.g. prostate exam for a woman that identifies as a transgender male). Additionally, a plan may use reasonable medical management to apply neutral, non-discriminatory standards

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Even if an entity has a high tolerance for risk (or is not concerned about potential employment discrimination), consider other reasons for complying with Section 1557, including the impact on potential claims. According to a June 2016 study from the Williams Institute, there are an estimated 1.4 million adults who identify as transgender in the United States, or 0.6 % of the population. Many entities are opting to cover these benefits and coverage could be seen as a competitive advantage or good public relations.

Summary Since the final rules were issued, insurers and other industry entities are taking a position on how to address Section 1557. Insurers are directly subject to 1557 and fully insured plans taking a conservative approach are being modified to include surgical and non-surgical treatment for gender dysphoria.

Employers subject to Section 1557, and those not subject but who wish to avoid EEOC scrutiny, should remove any exclusions from health plans which could be viewed as categorical exclusions of transgender services. The decision to cover or exclude transgender benefits, however, ultimately depends on the risk adversity of the employer. As a result, every employer and plan sponsor must review their situation on a case by case basis for Section 1557 applicability and modify relevant materials accordingly. Of course all of this could become irrelevant if the ACA is repealed or replaced, so I guess we’ll have to wait and see…

Jennifer M. McCormick joined The Phia Group, LLC as corporate counsel in 2008. She is admitted to the Bar of the Commonwealth of Massachusetts. As an attorney with The Phia Group, Attorney McCormick concentrates on a variety of healthcare and regulatory issues facing employee benefit plans and their administration. In addition, she focuses on health plan document design and drafting matters affecting employers, third party administrators, stop loss carriers, and health carriers.

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December 2016 | The Self-Insurer

SIIA

Endeavors written by Bruce Shuntan

Association Continues to Improve its Political Positioning During Times of Change Provided below are comments and updates from SIIA President & CEO Mike Ferguson in connection with the recent election results and how the association continues to position itself to best represent the interests of its members.

Like many of you, several members of the SIIA team had little sleep last night as we watched the election results come in. While Republicans maintaining a majority in the House comes at no surprise, Senate Republicans kept a thin majority, meaning a largely status quo policy perspective in Congress. What does bring change is the somewhat unexpected victory of Donald Trump in the presidential race, meaning a same-party Congress and Administration for the first time in a number of years. With congressional and presidential races now decided, questions loom: what does this mean and where do we stand?

Similarly, I think itâ&#x20AC;&#x2122;s important to note that the Self-Insurance Political Action Committee (SIPAC) has financially supported about three dozen members of Congress this election cycle who are positioned to support the self-insurance industry. As of today, I am pleased to say that SIPAC has a 100% election success rate with our candidate support, even in tough battleground states.

With a SIIA team that has been actively involved in political and policy activities in Washington, we are better prepared than ever to be strongly engaged and effective advocates for you. With a single political party controlling both the White House and both chambers of Congress, there will be a greater likelihood for substantive legislative activity, including changes to the Affordable Care Act and potential consideration of other health care reform proposals. You may be interested to know SIIA has met with more than 175 Members of Congress and their staff in the last two years to discuss the importance of the self-insurance marketplace generally, as well as specific policy proposals. With the House and Senate remaining largely status quo, these meetings have paved the way for SIIA to be actively engaged when the new Congress convenes.

SIIA President & CEO, Mike Ferguson

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With a change in Administration, so too will there be federal regulatory changes affecting self-insured group health plans, captive insurance companies and self-insured workers’ compensation programs. SIIA has been developing important relationships with “career” regulators who will maintain their current positions throughout the transition and we will be proactive in engaging with new political appointees who will have influence over our industry. In order to establish policy priorities for 2017, the SIIA Government Relations Committee will have a timely meeting in Washington, DC on November 30. During this time, we will review potential healthcare replacement blueprints and impacts on our industry, ranging from strengthening self-insurance in general to supporting employer based healthcare, among other

anticipated proposals. A new Congress and Administration will certainly mean new positioning and new issues that may arise, but we have worked hard to lay the groundwork to be an even more effective advocate for you. To help you stay informed and engaged in 2017, we have enhanced our educational offering in two ways. First, for the SelfInsured Health Plan Executive Forum, scheduled for March 28-29, 2017 in Tucson, AZ, we have included multiple sessions focused on the latest legislative/regulatory developments. Second, we are bringing back SIIA’s dedicated Legislative/Regulatory conference, which has been scheduled for May 2-4, 2017 in Washington, DC. This event will feature a great program of speakers and topics, along

with an opportunity for attendees to meet wither their elected representatives in their Capitol Hill offices. Supplementing this educational/informational initial, SIPAC will be holding multiple fundraising events over the course of the year where members will have the opportunity to help SIIA build and deploy its political contribution “war chest.” Watch for the event schedule announcement before the end of the year. While political and policy uncertainty may remain, SIIA is poised to be a constant advocate for you, fighting for your interests in Washington and in states across the country. If you have questions, would like to better understand policy issues, or wish for a political/policy briefing from the SIIA team, please do not hesitate to reach out to me directly at mferguson@siia.org.

December 2016 | The Self-Insurer

NEWS

from SIIA

Members

2016 DECEMBER MEMBER NEWS

SIIA Diamond, Gold & Silver Member News SIIA Diamond, Gold, and Silver member companies are leaders in the selfinsurance/captive insurance marketplace. Provided below are news highlights from these upgraded members. News items should be submitted to Wrenne Bartlett at wbartlett@siia.org. All submissions are subject to editing for brevity. Information about upgraded memberships can be accessed online at www.siia.org. For immediate assistance, please contact Jennifer Ivy at jivy@siia.org. If you would like to learn more about the benefits of SIIA’s premium memberships, please contact Jennifer Ivy and jivy@siia.org.

Diamond Members PartnerRe Ltd. Announces Acquisition of Aurigen PEMBROKE, Bermuda, October 20, 2016 -- PartnerRe Ltd. (“PartnerRe”) and Aurigen Capital Limited (“Aurigen” or the “Company”) today announced a definitive agreement for PartnerRe to acquire 100% of the outstanding ordinary shares of Aurigen, a North American life reinsurance company. Since its formation in 2007, Aurigen has leveraged its technical expertise, longstanding relationships, and local knowledge to serve clients and is today a top-five life reinsurer in Canada based on recurring new reinsurance business. The Company has also been providing mortality risk solutions in the U.S. since 2013. Aurigen’s gross premiums written in 2015 were USD 110 million, with the Company delivering a gross premiums CAGR of 16% over the last five years. 40

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PartnerRe’s President and CEO, Emmanuel Clarke, welcomed the deal saying: “Aurigen is a well-respected life reinsurance partner in the North American market and will be a highly complementary addition to PartnerRe’s existing business. This acquisition is expected to be financially accretive to PartnerRe’s book value per share in 2017 and aligns particularly well with our overall strategy to grow our Life and Health business. Aurigen will expand our life reinsurance footprint in Canada and the U.S. with virtually no overlap in market coverage.

“We look forward to welcoming Aurigen to PartnerRe and to bringing all the benefits of PartnerRe’s strong balance sheet, excellent ratings and global franchise to existing and future clients in this market.” Aurigen’s CEO, Alan Ryder, said: “We are very excited to be joining PartnerRe and look forward to helping grow its life reinsurance General Counsel and Chief Compliance Officer of business. We believe there is a strong strategic fit between our two Zelis Healthcare, John Camperlengo, Esq. organizations and that the combination of Aurigen’s expertise in the life reinsurance market and PartnerRe’s strength and international presence will be of tremendous benefit to our clients. Under PartnerRe’s ownership, our clients can expect the innovative reinsurance solutions and Zelis Announces New exceptional service they’ve come to know from Aurigen to continue and, over time, a Addition to Executive Team broadened product offering and extended risk appetite.” Zelis Healthcare, a market-leading healthcare The cash consideration for the transaction is CAD 375 million (about USD 286 million). The information technology company, is pleased acquisition will be financed through the utilization of PartnerRe’s excess cash on hand and to announce that John Camperlengo, Esq., no debt or equity financing will be required. The acquisition is subject to customary closing is the new General Counsel and Chief conditions including the receipt of required regulatory approvals and is expected to be Compliance Officer of Zelis Healthcare. completed by the first quarter of 2017. Mr. Camperlengo has served as the top legal Willis Capital Markets & Advisory is acting as the financial advisor to PartnerRe and Evercore executive for privately-held and publiclyis acting as the financial advisor to Aurigen. traded healthcare and finance firms for more than 25 years. Note: Exchange rate of 1.00 USD = 1.31 CAD applies to all relevant foreign exchange conversions Previously, he was General Counsel & Chief About PartnerRe Ltd. PartnerRe Ltd. is a leading global reinsurer that helps insurance companies reduce their earnings volatility, strengthen their capital and grow their businesses through reinsurance solutions. Risks are underwritten on a worldwide basis through PartnerRe’s three business segments: Property & Casualty, Specialty Lines and Life & Health. For the year ended December 31, 2015, total revenues were USD 5.4 billion. At June 30, 2016, total assets were USD 22.4 billion, total capital was USD 7.8 billion and total shareholders’ equity attributable to PartnerRe was USD 7.0 billion. PartnerRe enjoys strong financial strength ratings as follows: A.M. Best A / Moody’s A1 / Standard & Poor’s A+.

Compliance Officer at Quartet Health where he oversaw legal, compliance and risk management departments. Mr. Camperlengo was also previously General Counsel, Chief Compliance Officer & Corporate Secretary of Gentiva Health Services, Chief Compliance Officer for drug chain Duane Reade Holdings, and he held senior legal positions with Prudential.

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Earlier in his career, Mr. Camperlengo was a Military Judge Advocate for the Marine Corps. He retired holding the rank of Lieutenant Colonel. “We look forward to John’s contributions as a member of our executive team,” said Doug Klinger, CEO of Zelis Healthcare. “I am excited to be joining Zelis Healthcare,” said Mr. Camperlengo. “I look forward to bringing my diverse experiences and legal expertise to the Zelis team and to supporting our efforts to achieve growth objectives and ensure our client experiences continue to remain extremely positive.”

About Zelis Healthcare

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Zelis Healthcare is the brand name for Premier Healthcare Exchange, Stratose, Pay-Plus® Solutions and GlobalCare, which merged in 2016 forming a healthcare information technology company and market-leading provider of end-to-end healthcare claims cost management and payments solutions including network management, claims integrity and electronic payments serving more than 500 healthcare payer clients, more than 200,000 healthcare providers and millions of healthcare consumers in the medical, dental and workers’ compensation markets nationwide.

Mphasis, a leading IT services

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and solutions provider, today announced the launch of DigiOps driven by InfraGenie™, an intelligent automation platform (IAP), powered by Arago, a pioneer in artificial intelligence (AI) and leader in intelligent IT automation.

DigiOps delivers solutions by reducing manual effort across IT functions. This solutions-based model is fully autonomous and includes self-managing predictive analytics and diagnostic tools, delivering seamless management for top organizations in banking, financial services & insurance, energy & utilities, industrial mining, automotive and transport & logistic industries. InfraGenie™ intelligently predicts incidents before they arise so that companies have a reliable and consistent way of solving errors in their industry-specific IT operations. This smart infrastructure solution unites the proficiencies of advanced analytics (“prescriptive”) and artificial intelligence based automation to offer resolutions for all types of infrastructure related events. Through InfraGenie™, Mphasis will bring both automation and analytics together to reliably and consistently identify, predict and resolve the infrastructure problems of today’s complex hybrid IT environment.

“Success in the digital era is pivoted on technological innovation allowing companies to perform better and smarter. Artificial intelligence has revolutionized operations that have become dormant in today’s hybrid IT environment. We are confident that DigiOps driven by InfraGenie™ will help our customers drastically improve their IT functions, provide better customer service and satisfaction and reach optimal IT costs over time ,” said Dinesh Venugopal, President – Mphasis Digital and Strategic Customers.

Easily integrated to an existing system, InfraGenie™ helps 50 to 80 percent of all operational activities to become automated by incorporating machine learning capabilities and internal automation processes. This comprehensive end-to-end solution will significantly reduce manual effort and drive cost reduction, helping clients achieve total savings of up to 30 to 50 percent. InfraGenie™ will ultimately increase operational efficiency and improve the effectiveness and quality maintenance of IT systems, causing customers to see ROI on day one of system integration.

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About Mphasis Mphasis enables chosen customers to meet the demands of an evolving market place. Recently named by American Banker and BAI as one of the top companies in FinTech and as the “Most Distinguished Digital Company in 2015” by The Economic Times, Mphasis fuels this by combining superior human capital with cutting edge solutions in hyper-specialized areas. Contact Mphasis on www.mphasis.com.

Munich Re using big data to develop new coverage and services Big data is now being used to improve the identification, modelling and insurance of risks. Munich Re is taking advantage of these opportunities to develop new insurance solutions and services in conjunction with clients and partners. Extended IT and analytic competence is already being utilised – for example, in the early detection and trend analysis of fire losses.

Digitalisation and new technologies mean that far greater volumes of data are becoming available for evaluation within a much shorter time frame. Data analysis can be used to examine client portfolios to reveal trends, improve processes, optimise holdings, and provide targeted support to sales. The more global and comprehensive the data basis, the more valuable the data will be. The new dimensions of data and their analysis require some competences that not all insurance companies have. New competitors may be able to analyse data sets more quickly and apply the results in new applications – thus placing traditional insurers under pressure. So there is also a strategic dimension to big data.

“The most important aspects are the will and ability to invest in sufficient resources and work together with the right partners”, explained

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Ludger Arnoldussen, member of the Board of Management of Munich Re.

“That is exactly what we are doing when building up our own know-how and IT structures.” In order to be able to harvest information more quickly, the topic of big data is a key part of innovation processes at Munich Re. “It means new, clearly defined and more flexible insurance solutions and support services for our clients. We are seizing these opportunities – with our own resources, and supported by external specialists. We are also regularly involving the clients at an early stage in order to develop perfectly customised solutions and applications that can also be adopted at a global level.” There are already examples of how big data tools can be used to improve the pooling of information and make processes more efficient so as to create customised or totally new insurance solutions:

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A fully automated monitoring of 7,000 digital news channels with a daily volume of 250 gigabytes allows fire losses in the United Kingdom and the USA to be recorded more quickly and cheaply. Comparing this data with the risks in portfolios allows for better identification of risk patterns, so that claims management can be faster and more effective.

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In order to allow for better loss assessment and resource management, 16 terabytes of data volume from Munich Re, its clients and third parties have been combined on a nat cat platform for risk management purposes. The platform is already in use in Mexico, and will shortly be available in the UK.

Columbia, S.C. – Companion Life Insurance Company announced today that it has acquired Indiana-based Spectrum Underwriting Managers, Inc., a full-service managing general underwriter (MGU) of specific, aggregate and integrated medical stop loss insurance.

Artificial intelligence will play an increasingly important role in the collection and processing of big data volumes in the future. It is already a fixed part of such processes – for example, in the analysis of large volumes of text and in loss assessments using photo analysis, based on data derived from satellites and drones. Such technology was recently used in the USA, for example, in the wake of Hurricane Matthew. Artificial intelligence should be of great assistance to people in supporting their work and standardising routine processes. “But even in the long term, automation cannot replace strategic decision-making and maintaining good customer relations,” stressed Arnoldussen.

Companion Life Acquires Spectrum Underwriting Managers

“Spectrum has been a client of ours for many years, and we are pleased that they are now part of the Companion family. Spectrum is our seventh MGU acquisition and is proof not only of the success of our acquisition strategy, but also of our commitment to the stop loss industry as a market leader,” said Phil Gardham, Companion Life’s current COO and president effective January 2017. “For more

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than 25 years, Spectrum has been a leader in the stop loss industry, and we have shared values, a commitment to high-quality customer service and we understand the importance of strong relationships.” Founded in 1990 and headquartered in Indianapolis, Spectrum (www.spectrumhq.com) has represented Companion Life since 2006. Its services include underwriting, marketing, claims adjudication, premium administration, policy issue and product design. Spectrum offers a variety of products for single employer groups with as few as 15 employees. “When considering acquisition, Companion was the logical choice,” said Kurt Ridder, president of Spectrum. “We have a long-standing relationship with Companion, and most impressive is their ‘owned MGU’ model: Separate, focused and independent MGUs that continue to run post- sale just as they did pre-sale – same management, same staff and, most importantly, same identity. It showcases Companion’s unique commitment to the stop loss market – recognizing excellence and allowing it to flourish under the safety net of a large, respected and growing stop loss organization.” About Companion Life Headquartered in Columbia, Companion Life (www.CompanionLife.com) has specialized in employee benefits since 1971. The company markets life, dental, disability, accident, specialty health including medical stop loss, limited benefit health plans and group supplemental retiree prescription drug plans, as well as other insurance programs, through a network of independent agents and brokers, general agents and managing general underwriters. Companion Life is licensed in 49 states and the District of Columbia. It holds an A.M. Best Rating of A+ (Superior).

Healthcare Management Administrators, Inc. Names Steve Suter as President Healthcare Management Administrators, Inc. (HMA) announced Steve Suter has been named President. Steve will be responsible for growing the business and will continue to focus on delivering excellent service, flexible options, and innovative solutions that help make healthcare more affordable and easier to understand. Since joining HMA in 2014 as Chief Operating Officer, Steve has spearheaded the launch of multiple new products and services, an enterprise grade reporting platform and has attracted a number of talent leaders to join HMA. Prior to joining HMA, he served as the Chief Operating Officer at UnitedHealth Groups’ Optum division where he ran their Payment Integrity portfolio of businesses.

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“Promoting Steve to President was the next natural step as he has the experience, drive and intellect to take HMA into the future,” said David Snodgrass, HMA’s founder and CEO. “He has built great relationships with the broker community, our clients and business partners and I look forward to working with him throughout 2017 as we work together to provide new and innovative services to the market.” “Steve’s ability to improve operating efficiencies, promote excellent quality and focus on launching new products are valuable assets in helping to simplify healthcare,” said Angela Dowling, president, Regence BlueCross BlueShield of Oregon, and chief sales officer. “He is a seasoned executive and we’re fortunate to have someone of his caliber leading HMA.” Steve will be based at HMA’s Bellevue office.

About Healthcare Management Administrators, Inc. HMA has been a leading third party benefits administrator of health plans for over thirty years, expertly serving employers who choose to self-fund their healthcare. We are dedicated to partnering with brokers to help self-insured employers create and customize the ideal benefits plans to suit their unique needs. HMA provides unparalleled access to doctors and hospitals nationwide through well-known preferred provider networks. We create a healthier future for our client’s employees by making healthcare more affordable and easy to understand. Contact Courtney Bowman, MBA Marketing Specialist at Courtney.Bowman@accesstpa.com and visit accesshma.com.

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SIIA would like to Recognize our Leadership and Welcome New Members 2016 Board of Directors CHAIRMAN* Steven J. Link Executive Vice President, Midwest Employers Casualty Co. Chesterfield, MO PRESIDENT/CEO Mike Ferguson SIIA, Simpsonville, SC TREASURER & CORPORATE SECRETARY* Duke Niedringhaus Senior Vice President, J.W. Terrill, Inc. Chesterfield, MO CHAIRMAN-ELECT Jay Ritchie Senior Vice President, Tokio Marine HCC - Stop Loss Group Kennesaw, GA

Directors Joseph Antonell Chief Executive Officer/Principal A&M International Health Plans Miami, FL Adam Russo Chief Executive Officer The Phia Group, LLC Braintree, MA Andrew Cavenagh President Pareto Captive Services, LLC Philadelphia, PA Mark L. Stadler CEO Bridgehealth Irving, TX Robert A. Clemente Chief Executive Officer Specialty Care Management LLC Lahaska, PA

David Wilson President Windsor Strategy Partners, LLC Junction, NJ

Committee Chairs CAPTIVE INSURANCE COMMITTEE Michael P. Madden Senior Vice President Artex Risk Solutions, Inc. San Francisco, CA GOVERNMENT RELATIONS COMMITTEE Lawrence Thompson Senior Vice President, Sales & Client Services POMCO Group Syracuse, NY

HEALTH CARE COMMITTEE Kari L. Niblack Executive Vice President of Client Engagement & Services Apex Benefits Indianapolis, IN INTERNATIONAL COMMITTEE Robert Repke President Global Medical Conexions, Inc. Novato, CA WORKERSâ&#x20AC;&#x2122; COMP COMMITTEE Stu Thompson CEO The Builders Group Eagan, MN

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SIIA New Members Regular Corporate Members William Breidenbach Principal Breidenbach Associates Northborough, MA

Tana Taylor Direct Care Administrators Bountiful, UT

Jeff Costin VP of Risk Management Group Management Services Richfield, OH

Kristina Brooks Principal Innovative Insurance Solutions Cross Lanes, WV

Mark Davenport Senior Vice President of Sales PriceMDs.com

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Zelis Healthcare is a healthcare information technology company that provides solutions which address pre-payment to payment needs across the claims life cycle.