The Front Burner July 2010

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The official news magazine of the Washington Restaurant Association / July 2010

Health Care Reform

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Gets Real for Restaurants Your guide to meeting the new federal health care requirements


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Being Your Primary Source of Information on Health Care Reform as it Affects Your Business 6 Key Health Care Definitions 7 Health Insurance Exchanges 8 Determine the Size and Responsibility of Your Business 10 Providing Minimum Essential Coverage 11 Grandfathered Plans 12 Health Care Reform FAQs 14 Market Provisions Timeline 16 Washington’s Governor and Attorney General Update on Health Care 18 Tax Credits for Health Coverage 20 How Health Care Reform is Funded 21 Health Coverage Options Available Through the WRA 23 Calendar of Events 25 New Members 26 Marketplace These articles should not be considered legal guidance. They are subject to change based on emerging changes to the rules and regulation within the Patient Protection and Affordable Care Act. Anthony Anton, Publisher Camille St. Onge, Editor Heather Donahoe, Assistant Editor Jennifer Lang, Associate Editor Lisa Ellefson, Graphic Designer

The Front Burner is published monthly for Association members. Readership: 6,310. We welcome your comments and suggestions. email: news@WRAhome.com, phone: 800.225.7166

July 2010 | 3


Industry Outlook | WRA President & CEO

Anthony Anton, president and CEO

Being Your Primary Source of Information on Health Care Reform as it Affects Your Business

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alongside the most up-to-the-minute information pertaining to health care reform.

Not surprisingly the reform passage has generated hundreds of questions about how the massive reform will impact individual businesses.

Unfortunately, many of the questions still don’t yet have answers. There are some big decisions around health care reform that have not yet been determined. So while we would love for this edition to be your one-stop shop for information around the reform, the reality is, this is your one-stop shop for now. As late as press time, we were still updating based on new information so you can start getting clear answers in order to run your business.

n March 23, 2010, President Obama signed the Patient Protection and Affordable Care Act into law (P.L. 111148). This was followed on March 30, 2010, with the signing of the Health Care and Education Reconciliation Act, designed to modify the first Act. The result is an extensive and complex health care reform law aimed at expanding access to health care coverage for millions of Americans.

Following the reform’s passage we promised to break down health care reform in the July edition of The Front Burner in the best “give me what I need for my restaurant” format. And I am proud to say, “Here ya go!” This edition was a collaborative effort from several sources. The National Restaurant Association and our health care partner JLR, really stepped up to provide great content. A special thanks also goes to Congressman Adam Smith’s office (D-9th Dist.) and Congresswoman Cathy McMorris Rodgers’ office (R-5th Dist). It is not easy to try to ensure bi-partisan accuracy on an issue that has been so politically volatile the past 30 months and beyond, but both offices lent a hand to ensure just that in a very professional manner. Our intention for this issue of The Front Burner is simply to “lay out the facts” objectively. When it comes to politics and opinion, we are pleased to bring you information directly from the offices of Gov. Christine Gregoire and State Attorney General Rob McKenna. Providing perspective from varying voices within this issue is essential to your understanding of health care reform. So whether you feel the reform is way overdue and necessary OR is way over-reaching and harmful to jobs and your business, the WRA’s goal is to simply bring you the facts

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Announcements, tweaks, rule making and clarifications will occur this fall through the reform’s full enactment in 2014, and probably in the years following as ideas on paper become adjusted to real world applications. Check www.WRAhome.com or call us to get the latest updates. Throughout the regulatory process, the NRA and WRA will continue to represent the restaurant industry’s interests before Congress and the federal agencies charged with implementing this law. These include the Departments of Health and Human Services, Labor and Treasury, particularly the Internal Revenue Service and state government. We are proud to work hand in hand with the National Restaurant Association and others to provide the enclosed overview of the new law. This information should not be considered legal guidance, but rather serve as a starting point for understanding the new federal law. We are striving to ensure that, as your primary source of information, we are staying current, developing new communication vehicles and being ever-vigilant to make sure you have available to you the data and information you need to be successful.


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Key Health Care Definitions Large employers

Starting in 2014, large employers will be required to provide affordable health insurance coverage for their full time employees. Large employers are defined under the health care law as those with 50 or more full time equivalent employees. Employers who do not provide “affordable” coverage to their employees may be liable to pay an annual penalty of up to $2,000 per full time employee. The penalty is calculated on a monthly basis; federal agencies will need to issue regulations to explain exactly how this will work.

Small employers

Businesses with fewer than 50 full time equivalents are exempt from the law’s health care coverage requirements and penalties.

Full time employee

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A full time employee is defined as a person who averages at least 30 hours of service per week in any given month.

Full time equivalent

Part time workers’ combined hours count toward the number of full time equivalent employees for the purposes of the 50 full time employee equivalent threshold. However, businesses are not required to provide health coverage or pay a penalty for any part time employees.

Part time employee A part time employee is defined as a person

who averages fewer than 30 hours a week in any given month. Employers are not required to provide health care coverage or pay penalties for part time employees. Employers must use part time employees’ hours solely for purposes of determining whether the business qualifies for the small business threshold.

Seasonal workers Seasonal workers are defined as those who work 120 or fewer days a year.

Seasonal employees’ hours are not counted for purposes of determining whether an employer meets the 50 full time equivalent small business threshold.

This article should not be considered legal guidance. It is subject to change based on emerging changes to the rules and regulation within the Patient Protection and Affordable Care Act. 6 | www.WRAhome.com

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Health Insurance Exchanges Each state is required to set up an “exchange” or a marketplace for offering qualified health insurance plans by Jan. 1, 2014. A state may defer, if unable to set up an exchange, to the U.S. Department of Health and Human Services to establish and operate an exchange in that state. Individual and small group plans will be offered on the exchanges. States have discretion whether to open up the exchanges in 2017 to the large group market.

The Department of Health and Human Services will determine the minimum benefits as defined by law, and insurance companies subsequently may determine premiums per benefit package based on coverage level. States can require insurers to justify rate increases and prices. Insurers will have to be more transparent about their pricing, and how they spend their revenues, especially if they want to be included on the exchanges.

Who Will Be Able to Use Them? Are There Any Subsidies?

Definition of Employer in Health Care Reform Legislation

Those eligible for use of the exchange must meet one or more of the following criteria: Work at companies with fewer than 100 employees Work for a company that does not provide health insurance Self-employed Unemployed Retired, but not eligible for Medicare Small business After 2017, medium and large businesses

For purposes of calculating the number of full time employees employed by a single employer:

If you can’t afford to purchase health insurance, under the health care reform bill, subsidies are available from the government to assist with the payment of insurance premiums, up to 400% of the federal poverty line. A sliding scale, based on need, will be used to determine how much help you can get in terms of paying your premiums. How Will They Operate? How Will They be Funded? Federal money will be provided to help fund state exchange start-ups. States can also cooperate with each other in multistate exchanges, creating larger pools of “customers.” However, there are rules to being listed on the exchanges. To participate on an exchange, plans must provide standard information such as enrollment details, number of claims denied and cost share requirements. The exchange must offer plans that cover a specific essential health benefits package, which has still not been determined by the Department of Health and Human Services. Overseers are expected to make sure that the insurers listed on their exchanges follow certain criteria. Plans must be “in the interest” of buyers, according to the authors of the bill. State health insurance regulators must have rubrics for determining which insurers certify to offer their products on the exchange. Additionally, there has to be a standard format for presenting the options and costs in a way that allows buyers to efficiently compare their options. Presumably, this means that states will bar insurance companies that do not meet “quality standards” from selling on the exchanges.

A single employer is defined by “common control” as laid out in Internal Revenue Code Section 414 (b), (c), (m), (o)2 and is based on percentage of ownership and control in two or more restaurants. The threshold to be defined as a single employer: If two or more restaurants have the same five or fewer owners, collectively owning at least 80% of the shares or interest (either by vote or value), those restaurants shall be considered a single employer. Examples: 1. If a single restaurateur owns 100% of three individual S-Corps, for the purposes of health care, the three S-Corps would be treated as a single employer because the same owner controls at least 80% of each. The full time employees of all three would be added together to determine if the employer is above or below the small business (50 full-time employee) exemption threshold. 2. If restaurateur 1 and 2 own 90% of restaurant A (split 45/45) and 50% of restaurant B (split 25/25), restaurants A and B would not be considered a single employer since restaurateur 1 and 2 only own 50% of restaurant B. 3. If restaurateur 1 and 2 own 90% of restaurant A (split 45/45) and 80% of restaurant B (split 40/40), restaurants A and B would be considered a single employer since restaurateur 1 and 2 own 80% of restaurant B. The full time employees of restaurants A and B would be added together to determine if the employer is above or below the small business (50 full-time employee) exemption threshold.

This article should not be considered legal guidance. It is subject to change based on emerging changes to the rules and regulation within the Patient Protection and Affordable Care Act. July 2010 | 7


DETERMINE Who is Considered a Large Employer? Only employers with more than 50 full time equivalent employees are subject to the coverage requirements and possible penalty liability of the Patient Protection and Affordable Health Care Act. Employers must determine if they fall above or below the threshold of 50 full time equivalents using a formula. It is based on a definition of full time employment as 30 hours or more a week on average in a given month. If an employer is above the threshold of 50 full time equivalents using this formula, they are subject to the coverage requirements and possible penalty liabilities in the law:

Number of full time employees (employees who average 30 hours or more a week during a month)

+

Hours worked by all part time employees in a month, divided by 120 hours

=

Number of full time equivalents

REMINDER: Part time workers’ combined hours count toward the number of full time equivalent employees for the purposes of calculating the 50 full time equivalent threshold. However, businesses are not required to offer minimum essential health coverage or pay a penalty for any part time employees. If an employer’s workforce exceeds 50 full time equivalent employees (not including seasonal workers), the employer must offer coverage for those seasonal employees who are full time.

The employer does not pay a penalty on the first 30 full time employees if they do not provide coverage. Example: If a restaurant has 80 part time workers (who work the equivalent of 40 full time employees) and 40 full time employees, the employer has 80 full time equivalent employees. The restaurant must then offer coverage to the 40 full time employees or pay a penalty because it has more than 50 full time equivalents.

Large Employer Responsibilities Starting in 2014, the health reform law requires large employers to offer affordable health insurance coverage to their full time employees. If an employer does not provide affordable minimum essential coverage, they may be liable to pay a penalty of up to $2,000 per full time employee annually. The penalty is assessed on a monthly basis, at a rate of $167 per full time employee. Penalty payments are not tax-deductible for employers. Penalties are triggered only if a full time employee of a large employer receives a federal premium tax credit to purchase a health insurance plan in a health insurance “exchange” (see page 7). The exchanges will be established in each state and also across state lines, and are designed to serve as a marketplace for individuals and small groups to purchase private health insurance plans. Individuals are eligible for tax credits on a sliding scale if their incomes are up to four times the federal poverty level ($10,830 for an individual and $22,050 for a family of four in 2010).

Possible Outcomes for Large Employers The following provides examples of how large employers— i.e., those with more than 50 full time equivalents—will be affected by the penalties and other requirements. 1) If a large employer DOES NOT OFFER minimum

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the Size and Responsibility of

YOUR BUSINESS essential health care coverage to all of their full time employees and their dependents* and at lease one full time employee uses the premium tax credit to obtain coverage on the exchange:

Employers must pay an annual penalty of $2,000 per

full time employee ($167 with respect to any month). In calculating the assessment, an employer may discount the number of full time employees by 30. 2) If a large employer DOES OFFER minimum essential coverage to their full time employees and dependents, but it is unaffordable to at least one full time employee who uses a federal premium tax credit to obtain coverage on the exchange:

Employers must pay the lesser of: An annual penalty of $3,000 for each full time

employee receiving a federal premium tax credit ($250 with respect to any month), or, $2,000 multiplied by the total number of full time employees (minus the first 30 employees)—this is to assure that those who offer coverage are not penalized more than those who do not offer coverage. In general, employees whose employers offer coverage are not eligible to receive premium tax credits to obtain coverage in the exchange. However, Congress wanted to ensure that employer-sponsored coverage would be affordable for employees.

the employee’s previous years’ tax filings and certified by the IRS and state exchange). 3) If a large employer DOES OFFER minimum essential coverage to their full time employees and dependents, but a full time employee’s required contribution under the employer’s plan would be between 8% and 9.5% of household income.

At the employee’s request, the employer must provide a free choice voucher—in the amount equal to the monthly employer contribution (to individual or family plan)—to those full time employees to buy coverage on the exchange. If the voucher exceeds the cost of the coverage premium purchased on the exchange, then the full time employee retains the excess. Employees are not eligible both for the free choice voucher and the federal premium tax credit to purchase coverage on the exchange. Employer is allowed a deduction in the amount of the voucher paid as is the case currently for employer contributions. If the employer provides a voucher to a full time employee, the employer is not subject to penalties. * Dependents include spouses and children until their 26th birthday. The Health and Human Services Secretary will announce regulations to further define dependents.

Consequently, a full time employee with an offer of employer-sponsored coverage is eligible for a premium tax credit only if the plan’s share of the total allowed costs of benefits is less than 60% of the costs OR the full time employee’s required contribution under the employer’s plan exceeds 9.5% of the employee’s income. (It is anticipated that household income will be determined by July 2010 | 9


Providing Minimum Essential Coverage Beginning in 2014, large employers must provide minimum essential coverage to full time employees (and their dependents). If this requirement is not met, employers could be liable for penalties. The minimum essential coverage requirement applies to all health insurance plans offered after the date of enactment (March 23, 2010) by employers with 50 or more full time equivalents. The law defines an essential health benefits package as one that covers vital health benefits, limits cost-sharing and has a specified actuarial value (pays for a specified percentage of costs) as follows: 1. For the individual and small group markets* the law requires the U.S. Secretary of Health and Human Services to define essential health benefits, which must be equal in scope to the benefits of a typical employer plan. 2. For all plans in all markets** the law prohibits out-of-pocket limits that are greater than the limits for health savings accounts (2010: $5,950 self, $11,900 family). For the small group market, the law prohibits deductibles that are greater than $2,000 for individuals and $4,000 for families. Indexes the limits and deductible amounts by the percentage increase in average per capita premiums. Limits cost-sharing for such coverage (deductibles, coinsurance, copayments or similar charges—does not include premiums). 3. For the individual and small group markets, the law requires individuals to enroll in one of the following levels of coverage, as offered, under which the plan pays for the specified percentage of costs: Bronze (60% actuarial value), Silver (70%), Gold (80%) or Platinum (90%) level of coverage. The U.S. Secretary of Health and Human Services may issue regulations under which employer contributions to a health savings account may be taken into account in determining the level of coverage for a plan of the employer. 10 | www.WRAhome.com

4. In the individual market, individuals under 30 years, not using the tax credit to obtain coverage, can enroll in a catastrophic plan to satisfy the individual responsibility requirement in the legislation. However, a catastrophic plan is not minimum essential coverage and thus cannot be offered by an employer to meet health coverage requirements. A catastrophic plan must cover essential health benefits and at least three primary care visits, but must require cost-sharing up to the health savings account out-of-pocket limits. Also, if an insurer offers a qualified health plan, it must offer a childonly plan (under 21) at the same level of coverage in the individual market. * Individual market refers to an individual health insurance policy purchased apart from the group market. Small group market contains small group health plans that are open to an employer with 100 or fewer employees. Large group market applies to employers with 101 or more employees. However, in plan years beginning before January 1, 2016, a state may substitute 51 for 101 employees in defining small group market. If employer was considered small and offered a plan through the small group market through the exchange, and increases in size so as not to be, as long as they continue to offer such enrollment to employees they would still be considered small. ** Applies to individual, small group and large group plans. This article should not be considered legal guidance. It is subject to change based on emerging changes to the rules and regulation within the Patient Protection and Affordable Care Act.


Grandfathered Plans If you are an employer who offered health care coverage as of March 23, 2010, you’ll want to be familiar with aspects of the law pertaining to grandfathered plans. These existing plans are recognized by the U.S. Secretary of Health and Human Services. Enrollment in a grandfathered plan satisfies the law’s individual mandate to obtain qualified coverage. If an employer offered coverage to their employees as of March 23, 2010, and maintains that plan as a grandfathered plan, the employees can stay in the grandfathered plan to satisfy the individual mandate in the law that requires everyone to obtain qualified coverage for themselves and their dependents. The grandfathered plan coverage can be continued even if the employee renews their coverage after the March 23, 2010, date. Family members may be added to a grandfathered plan if that was previously allowed by the plan and new hires and current employees can also enroll in the grandfathered plan as well. A grandfathered plan does not lose its status just because an enrollee is no longer covered, assuming someone was continuously covered by the plan since March 23, 2010. All grandfathered health insurance plans will have to conform to certain insurance reforms six months after enactment. Other reforms are implemented starting in 2014.

Beginning September 2010: Prohibition on lifetime limits or ‘unreasonable’

annual limits. Prohibition on rescission of coverage. Requirement to provide coverage to children and adult children up to age 26 (if a plan already provides dependent coverage). 2014: Prohibition on pre-existing condition exclusions Prohibition on annual limits. Limitations on excessive waiting periods (not longer than 90 days).

In general, businesses offering health care coverage may continue to offer such coverage to their employees under a “grandfather” provision. However, the government recently laid out rules effective July 12, 2010, that grandfathered plans must follow to maintain such status. Permissible changes to plans include those to premiums, changes to comply with federal or state laws, changes to voluntarily comply with the provisions of the new health care law, and the changing of third party administrators. To maintain their status, grandfathered plans must disclose its status in any plan materials. Recordkeeping by the plan or issuer is also required. The rules list specific changes that will cause a grandfathered plan to lose its status: elimination of benefits, increases in the percentage of cost-sharing required by an enrollee (coinsurance), increases in the fixed-amount cost-sharing required (copayments, deductibles, out-ofpocket limits), decreases of more than 5% of the employers’ contribution rate based on the rate as of March 23, 2010, and changes to annual limits. Additionally, there are transition rules that apply for those who might have made changes before the filing of these rules on June 14, 2010, and also for any changes to plans made between June 14 and September 23, 2010. More information about the rules that govern grandfathered status can be found at www.restuarant.org/healthcare.

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Health Care Reform FAQs Q: A:

As an employer, do I need to do anything this year now that this is law?

Q: A:

Do I have to provide coverage for my part time employees?

The bulk of the employer requirements for coverage and penalties do not begin until 2014. All of the details are not yet known, and action by several federal agencies is required to further define some of the requirements. See page 14 for the implementation timeline.

No. Part time employees are counted only in determining whether an employer meets the smallbusiness threshold for coverage under the law. In no case do employers have to provide health care coverage for part time employees or pay penalties for part time employees.

Q: A:

Q: A:

I heard about small business tax credits. When do they begin and am I eligible?

Beginning Jan. 1, 2010, certain small businesses with 10 to 25 full time equivalent employees may qualify for a tax credit for contributing to their employees’ health coverage now. More details are coming soon. Check out page 18 for details.

Q: A:

Will I be required to provide health care to my employees?

Employers with 50 or more full time equivalent employees (see below) will be required to offer their full time employees a “minimum essential coverage” health benefits package starting in 2014, or pay a penalty for not doing so. Minimum essential coverage has not been fully defined; see more below. See page 10 for specifics.

Q: A:

Will small businesses be required to provide coverage too?

No. Employers who have fewer than 50 full time equivalents will not be required to provide coverage.

How much will the new requirements cost me?

Cost will vary depending on your operation and how minimum coverage is defined through the regulatory process. The National Restaurant Association is conducting an economic impact study to further determine overall costs to the restaurant industry.

Q: A:

Are there penalties for employers, subject to the law, who do not provide coverage?

Yes. Employers covered by the law who do not provide coverage will be subject to a penalty of $2,000 annually per full time employee assessed on a monthly basis, or $166.67 per month per uninsured employee. Employers may exclude 30 full time employees in calculating their penalty. For example, a covered employer who has 60 full time employees and chooses not to provide coverage would face an annual penalty of $60,000. [60 total full time employees—30 full time employees excluded from the calculation = 30; 30 x $2,000 penalty = $60,000].

Q: A:

If I provide coverage, do I have to offer it to my new full time employees on day one?

No. Employers subject to the law in 2014 are allowed a waiting period of 90 days without penalty. On day 91, they must provide new hires coverage or pay the penalty for not doing so. This article should not be considered legal guidance. It is subject to change based on emerging changes to the rules and regulation within the Patient Protection and Affordable Care Act.

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Health Care Reform Bill Insurance Market Provisions Timeline (as revised by the House Reconciliation Bill)*

Summary of Select Requirements

State grants to establish or expand ombudsman programs are awarded New federal rate review process is established National risk-pool is created 90 days from enactment Temporary retiree reinsurance program is established Small business tax credit is established

Allows restricted annual limits for essential benefits (as determined by HHS) Recissions are prohibited (except for fraud or intentional misrepresentation) Cost-sharing obligations for preventive services are prohibited Dependent coverage up to age 26 is mandated Internal and external appeal processes must be established

Discrimination based on salary is prohibited Internet portal to facilitate consumer and small employer shopping is created Coverage for emergency services at in-network cost-sharing level with no prior-authorization is mandated Pre-existing condition exclusions for dependent children (under 19 years of age) are prohibited New health plan disclosure and transparency requirements are created

Health insurance fee to fund Comparative Effectiveness is imposed

Uniform coverage documents and standard definitions are developed by HHS (in consultation with NAIC) 85% MLR for large group (with refund) is mandated 80% MLR for individual and small group (with refund) is mandated January 1

October 1

January 1

2010

Impact

Prohibits lifetime benefit limits

2011

2012

Health plans develop and file new rates

Health plans create and file new policy forms

States approve (or disapprove) new rate filings

Health plans develop and file new rate filings

HHS Secretary and states create new rate review process

States approve (or disapprove) new policy forms

HHS Secretary establishes new national risk-pool HHS Secretary establishes temporary retiree reinsurance program 14 | www.WRAhome.com

January 1

January 1

2013

States approve (or disapprove) new rate filings HHS Secretary and states approve (or disapprove) premium rate increase requests HHS Secretary establishes new internet portal

2


Health insurance exchange is established Guarantee issue is required Rating restrictions that, among other things, limits use of age as a rating factor are imposed Individual and employer responsibility requirements are established

Grandfathered Plans Prohibits lifetime benefit limits

Grandfathered Plans Pre-existing condition exclusions are prohibited

Individual affordability tax credits are created and small business tax credits are expanded

Recissions are prohibited (except for fraud or intentional misrepresentation)

Prohibits annual benefit limits

Essential benefit plan is created

Dependent coverage up to age 26 is mandated

Pre-existing condition exclusions are prohibited

Pre-existing condition exclusions for dependents are prohibited

CO-OPs are established

Allows restricted annual limits for essential benefits (as determined by HHS)

Lifetime and annual dollar limits are prohibited for essential benefits Coverage for approved clinical trials is mandated Multi-state qualified health plans are created and offered through the Exchange

Health insurance provider fee imposed $8 billion

2014

Health insurance provider fee increased $11.3 billion

January 1

Health insurance provider fee remains at $11.3 billion

Health insurance provider fee increased $13.9 billion January 1

January 1

2015

High-cost insurance excise tax is established

2016

Health insurance provider fee increased $14.3 billion** January 1

2017

Health plans develop and file new rates

Health plans create and file new policy forms

States approve (or disapprove) new rate filings

Health plans develop and file new rate filings

HHS Secretary and states approve (or disapprove) premium rate increase requests

States approve (or disapprove) new policy forms

* Assumes April 1, 2010 enactment. ** In years following 2018, the tax amount would increase in an amount proportionally equal to overall premium growth. This article should not be considered legal guidance. It is subject to change based on emerging changes to the rules and regulation within the Patient Protection and Affordable Care Act.

2018

States approve (or disapprove) new rate filings HHS Secretary and states approve (or disapprove) premium rate increase requests HHS Secretary establishes new internet portal July 2010 | 15


Washington’s Governor and Attorney The Washington Restaurant Association reached out to the offices of Gov. Christine Gregoire and State Attorney General Rob McKenna for updates on health care reform as it applies to Washington state. We are pleased that both leaders responded with the information below. The opinions expressed here are not endorsed by the WRA and are presented in effort to illuminate two perspectives within the ongoing debate over health care reform. By Kate Lykins Brown, Executive Communications Advisor, Gov. Gregoire’s Executive Policy Office

In February,

Congress passed the Patient Protection and Affordable Care Act. This landmark law will reduce premium costs for tens of millions of families and small business owners priced out of coverage. It will help 32 million Americans afford health care who do not have it today—and makes coverage more affordable for many more by providing the largest middle-class tax cut for health care in history. Here in Washington, thousands cannot afford health care. The governor knows firsthand about the effects of spiraling health care costs on commerce and the need for a national solution. The state’s Basic Health Plan, which provides partially subsidized coverage to our working poor who are not eligible for Medicaid, was scaled back due to the recession. Today, enrollees pay a higher share of costs and 40,000 fewer are enrolled—100,000 are on the waiting list. The governor knows that the costs of providing services to the uninsured are being passed on to our health care community, resulting in escalating health insurance premiums for us all. Given the opportunities under federal reform, those states ready to start assessing their health care systems will achieve the best outcomes. Smart states recognize that health care reform covers more than the issues of financing and coverage. They will also focus on the areas of wellness, prevention, use of electronic information systems and service delivery improvements to achieve comprehensive and lasting reform. To put our state in the strongest possible position to take advantage of the law, Gov. Gregoire created the Health Care Cabinet, composed of the leaders of the Department of Health, Health Care Authority, Department of Social and Health Services, Office of Financial Management and Office of the Insurance Commissioner. With several agencies having a role in health care reform, it is crucial to ensure a forum for information sharing, problem solving and strategic planning. As there will be multiple state agency initiatives to implement federal reform, citizen and stakeholder engagement will be handled by each agency, as appropriate, to inform decision making. However, to help the public see what activities are in progress, the governor’s office has designed a portal, www.governor.wa.gov/priorities/healthcare/reform.asp, to highlight

16 | www.WRAhome.com

how state agencies are implementing reform, list community meetings and direct readers to other sites for more information. The work of the governor’s Health Care Cabinet will run concurrently with that of the bipartisan Joint Select Committee on Health Reform Implementation. This group of nine state lawmakers will consider what legislation, if any, will be needed during the 2011 session to further Washington’s reform efforts. We expect that its work will enrich and inform the work of the Cabinet so that when the Legislature convenes in January, all parties will hit the ground running. In the meantime, a number of projects are underway. We are taking advantage of the opportunity provided under the new law to seek federal funding to subsidize the Basic Health Plan and the Disability Lifeline, both now totally reliant on state funding. The insurance commissioner is working to meet an early summer deadline for the establishment of a federally funded, high-risk pool to provide coverage to those now denied care in the individual market, and take the pressure off of our high-risk pool funded, in part, by premiums paid by our small employers. The insurance commissioner also is charged with implementing new regulations this fall that prohibit insurance company abuses. The Act includes a number of health-related funding opportunities which Washington or its citizens may be eligible for in the future. These include improving our public health system, enhancing health care quality and protecting seniors. We will choose carefully from these possibilities to ensure we assign resources to the most time- and cost-effective services. Already we are looking at grants to help new parents gain skills to keep their newborns healthy and thriving—thereby reducing costs for us all. There’s money available to help seniors better navigate the long-term care system and health care options available to them. And federal funds will help the insurance commissioner to review insurance rates to keep any increases within reasonable limits. An initial implementation plan by the Health Care Cabinet is due to the governor in August. Those recommendations will serve as a blueprint for a healthier and more prosperous future for Washington’s citizens.


General Update on Health Care

By Rob McKenna, Washington State Attorney General

Our nation

is in the midst of a severe obesity crisis. More than 30 percent of Americans are dangerously overweight. Because the obese suffer from an increased risk of certain diseases, from diabetes to cancer, they exact an expensive toll on our health care system. Given the obesity epidemic, should the government force all Americans to eat sugar-free and fat-free foods? Should portion sizes of restaurant meals be determined by Congress? And while we’re at it, should all Americans be required to join a gym? While these examples are fanciful, they touch on an important aspect of a case being considered by the courts. As you may have heard, I joined many of my fellow state AGs in a lawsuit challenging specific provisions of the federal health care bill. The lawsuit addresses the massive expansion of the Medicaid program, which will unconstitutionally require states to spend billions more when state budgets are already in crisis. Another part of the lawsuit deals with the unprecedented requirement that individuals lacking health insurance must purchase it or face a fine. We believe both of these mandates represent expansions of federal authority that violate the 10th Amendment, which protects states’ and individual rights. The states are also concerned the insurance mandate violates the Constitution’s Commerce Clause because never before has Congress required all Americans to purchase a specific product in the private marketplace. At its heart, the multistate lawsuit against parts of the health care bill addresses the ability of Congress to erase any remaining limits on its power to regulate what we buy—or what we choose not to buy. As written by members of Congress, the insurance mandate says that a person who refuses to purchase health coverage has a serious economic impact on others. For example, a person without insurance doesn’t pay into the risk pool when he’s healthy. And when he’s sick, he might end up in the emergency room, where the cost of care is higher—and shared by everyone else. Thus, the bill’s advocates say, those who can afford to pay must be compelled to engage in this particular kind of commerce—and they must buy a federally approved plan.

The need for health insurance reform is real. However, the cure—essentially deleting the Constitution’s Commerce Clause—is worse than the disease. The Commerce Clause was meant to allow the federal government to referee trade disputes between the states and thus promote economic stability. It was not meant to allow Congress to regulate the minute details of our purchases or to compel us, under threat of IRS fines, to buy federally approved services. If the federal government can require you to buy health insurance because your lack of coverage impacts other Americans, what else can they compel you to buy? Many of our purchases, including the food we eat and the cars we drive, impact others. If Congress has the ability to force Americans to buy health insurance, there are no longer any limits on federal intrusion into our buying decisions. As restaurant owners and operators engaged in commerce, your enterprise is one of hard work and low margins. It’s particularly susceptible to the effects—both intended and otherwise—of regulation. You understand the difficulty of complying with city, county and state rules. The destruction of the Commerce Clause removes any remaining limits on the federal government’s ability to add to the assortment of regulations that can stifle personal freedoms and slow economic growth. Our lawsuit is not about overturning or repealing the new health care reform legislation. In fact, it will not cancel most provisions of this 2,400-page bill. Our lawsuit is about defending our constitutional rights and the many benefits that flow from those rights. The need for health care reform is real—as is the need to respond to the nation’s obesity epidemic and a whole host of other problems. But reforms, above all else, need to be built on a constitutional foundation. Learn more about the multistate health care lawsuit at www.atg.wa.gov.

July 2010 | 17


Tax Credits for Health Coverage Does Your Small Business Qualify for a Break from the IRS? The Internal Revenue Service offers numerous resources on its website to help employers determine if they qualify for the Small Business Health Care Tax Credit. The site includes a 3-step calculator, Q&A, video and other tools. www.tinyurl.com/smallbiztaxcredit.com The tax guidance on the IRS website answers specific questions, but here are the basics:

Eligible small employers are those with no more than

25 full time equivalent employees for the taxable year, the average annual wages of those employees do not exceed $50,000 and the employer’s contribution for the employees for a qualified health plan in the exchange is not less than 50% of the premium. See page 7 for a definition of the exchange.

The amount of the credit is phased out based on the

number of employees and their average wages using a formula. The full credit is available to employers with 10 or fewer employees with average wages less than $25,000. The amount of credit is 50% of the lesser of the aggregate amount of the employer contribution for employees’ premiums of qualified health plans offered by the employer in the exchange OR the average premium in the small group market. This small business tax credit is considered part of the general business credit and can be used against alternative minimum. The small business tax credit expires after six years. —National Restaurant Association

3 Simple Steps If you are a small employer (business or tax-exempt) that provides health insurance coverage to your employees, determine if you may qualify for the Small Business Health Care Tax Credit by following these three simple steps:

1

Determine the total number of your employees (not counting owners or family members): Full time employees: (enter the number of employees who work at least 40 hours per week) Full time equivalent of part time employees: (Calculate the number of full time equivalents by dividing the total annual hours of part time employees by 2080.)

+

= total employees

If the total number of employees is fewer than 25, you are eligible for STEP 2.

3

2

Calculate the average annual wages of employees (not counting owners or family members): Take the total annual wages paid to employees:

÷

Divide it by the number of employees from STEP 1: (total wages ÷ number of employees)

= average wages

If the result is less than $50,000, AND

You pay at least half of the insurance premiums for your employees at the single (employee-only) coverage rate, then you may be able to claim the Small Business Health Care Tax Credit. Find out more information at IRS.gov

This article should not be considered legal guidance. It is subject to change based on emerging changes to the rules and regulation within the Patient Protection and Affordable Care Act.

18 | www.WRAhome.com


WRA WEBINARS

“Seven Must-Dos to Controlling Labor Costs� Wednesday, August 4, 2010 9:30 - 10:30 a.m. PDT

Avoid profit draining labor practices and take back control of your time clock in this free webinar by, David Scott Peters, restaurant expert and session speaker. Learn how to correctly use your labor dollars, the greatest potential for time clock abuse, how to avoid cutting labor too soon and the key to a well trained and efficient staff.

Register today at www.WRAhome.com/calendar


How Health Care Reform is Funded An overview of health care reform can’t be presented without details on how the law will be funded. The law included several tax and information reporting changes and fees in order to pay for the legislation. The following are examples of changes that could impact the taxes or operation of a small or large restaurant company. Medicare Contribution Tax. Modifies the existing

3.8% Medicare tax to include unearned income (net investment income). Applies to modified adjusted gross income of more than $250,000 for joint filers, $200,000 for single filers. Net investment income is defined as interest, dividends, royalties, rents, gross income from trade or business involving passive activities and net gain from disposition of property (other than property held in a trade or business). Begins 2013. Broaden Medicare Hospital Insurance tax for highincome taxpayers. Increases FICA tax from 1.45% to 2.35% on individual taxpayers earning more than $200,000/$250,000 for married couples filing jointly. Begins in 2013. Expansion of information reporting. Requires businesses that pay any amount greater than $600 during the year to corporate providers of property and services to file an information report, a 1099 form, with each provider and with the IRS. Information reporting already is required on payments for services to noncorporate providers. Applies to payments made after December 31, 2011. Employer W-2 reporting of value of health benefits. Requires employers to disclose the value of health benefits provided by the employer for each employee’s health insurance coverage on the annual W-2 form. Begins in taxable years after December 31, 2010. Modification of itemized deduction for medical expenses. Raises the 7.5% AGI floor on medical expenses deduction to 10%; AGI floor for individuals 20 | www.WRAhome.com

age 65 and older (and their spouses) remains at 7.5% through 2016. Increase in additional tax on distributions from HSA and Archer MSA’s not used for qualified medical expenses from 10% to 20%. Limitation on health flexible spending arrangements under cafeteria plans. Limits amount of contributions to health FSAs to $2,500 per year beginning in 2011. Indexed by CPI-U starting in 2013. Elimination of Medicare Part D prescription subsidy deduction for employers as a business expense. Begins 2013. Excise tax on high cost employer-sponsored health coverage. Levies a 40% excise tax on insurance companies and plan administrators for any health care coverage plan that is above the premium threshold of $10,200 for single coverage and $27,500 for family coverage (subject to adjustment for unexpected increase in medical costs prior to effective date). The tax is applied to the amount in excess of the threshold amount. The tax applies to self-insured plans and plans sold in the group market, but not to plans sold on individual market. Threshold is indexed to CPI. Begins in 2018. Time for payment of corporate estimate taxes. Increase by 15.75% the required corporate estimated tax payments factor for corporations with assets of at least $1 billion for payments due in July, August and September 2014. Health insurance provider employee expenses. Limits deduction on remuneration to officers, employees, directors and service providers. This article should not be considered legal guidance. It is subject to change based on emerging changes to the rules and regulation within the Patient Protection and Affordable Care Act.


Health Coverage Options Available Through the WRA Hospitality Industry Health Insurance Trust (H.I.H.I.T.)

Membership with the Washington Restaurant Association allows special access to medical and dental benefits through the Hospitality Industry Health Insurance Trust (H.I.H.I.T.). This Trust is designed specifically for the WRA to provide cost effective medical and dental insurance products. By pooling financial risk over a larger population, premiums are generally more stable. H.I.H.I.T. is able to combine the purchasing power of many smaller employers to collectively buy benefits. The result is favorable coverage, terms, conditions and plan limits that are tailored to the needs of the Trust’s members. Employer Benefits: Minimum contribution is only 50% of premiums. Most other plans require an employer contribution of at least 75%. Enroll with as few as three eligible employees. Dual options available. Many other Trust plans allow you to offer only one plan, reducing your ability to tailor offerings to your employee’s needs. The Board of Trustees, which oversees the running of H.I.H.I.T., is composed of a chairman and six trustees. These volunteer positions are filled by Association members. Start your quote today by visiting www.WRAhome.com/ healthcare.

Strata Limited Benefit Health Insurance*

Strata Health Plan ™ is an affordable health insurance that WRA members can offer to full or part time employees. Strata utilizes an extensive network of physicians, is available to employees with pre-existing conditions and does not exclude smokers. Employer Benefits: No required employer contribution Employer determines staff eligibility Can be offered alongside your current major medical plan WRA Member Pricing: Offered exclusively to WRA members. Enrollee Benefits: Broad health care benefits** plus vision, dental and accident coverage Simple enrollment without medical questions

Cash payments for your health claims without any

copayments or deductible (unless you specify otherwise)

Cash to spend as you need for un-reimbursed expenses, treatments, home help, travel or any other purpose

Discounted networks, prescriptions and laboratory tests Easy to afford and easy to pay through low group rate coverage Fast, responsive claims service through knowledgeable professionals

Strata Limited Benefit Health Insurance To sign up or get more information contact your local Area Coordinator: Central Washington Victoria Olson victoria@WRAhome.com 800.225.7166, ext. 136

Pierce County Judy Decker judy.decker@WRAhome.com Cell: 253.514.2621

Eastern Washington Donna Tikker donna@WRAhome.com Cell: 509.953.6245

Seattle Ronda Krizan ronda.krizan@WRAhome.com Cell: 206.941.5646

Greater King County Laurie Jones laurie.jones@WRAhome.com Cell: 206.999.6526

Snohomish County Darla Lau darla.lau@WRAhome.com Cell: 360.815.7511

Kitsap and Peninsula Victoria Olson victoria@WRAhome.com 800.225.7166, ext. 136

Southwest Washington Thelma Mosebar thelma@WRAhome.com Cell: 360.701.3359

* Limited Benefit Health Insurance is not basic health insurance or major medical coverage and is not designed as a substitute for basic health insurance of major medical coverage. ** Value Added Benefits, unless otherwise specified, these items are not insurance. These coverages and services (except for the vision coverage) are neither underwritten nor provided by the Accident and Health Division. National Union Fire Insurance Company of Pittsburgh, Pa. assumes no responsibility or liability for any of the listed services, the providers of the services, the quality of the services, the delivery of the services, or the outcomes of the services. Benefits may vary from state to state. The policies contain reductions, limitations, exclusions and termination provisions. Full details of the coverage are contained in each policy. If there are any conflicts between this document and each Policy, the Policy (series N20000 through N20010) shall govern. Not all coverages are available in every state. Limited Benefit Health Insurance is underwritten by National Fire Insurance Company of Pittsburgh, Pa. with its principal place of business in New York, NY. HSC3B_0704.069 06/07 July 2010 | 21


Choices H.I.H.I.T. understands that choices are as important as affordability.

Did you know...

You can choose your own doctor. Keep an existing relationship and continue to use your existing doctor or choose from over 17,000 physicians statewide and over 5,000 dental providers statewide. H.I.H.I.T. is the plan of choice when it comes to offering benefits and options to the hospitality industry. Enroll in a health care plan today. Call Pam Moynahan toll free at 877.892.9203.

more traffic

more sales with

email marketing & online reservations for more information contact:

This member benefit is brought to you by:

800.836.2818 or visit fishbowl.com WRA MEMBERS SAVE 10%

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1/13/09 5:40:25 PM


Visit www.WRAhome.com/calendar for a full list of events.

INDUSTRY CALENDAR Training | Meetings | Events July & August

WRA Education Foundation & Washington State Chef’s Association’s annual

Golf FORE! Education

August 9, 2010

Events July 14

WRA Webinar: Competitive Edge Marketing Series -Best Practices for Email Marketing July 14 NRA Webinar: Health Care Reform and You July 16 – 18 Kirkland Uncorked August 4 WRA Webinar: Seven Must-Dos to Controlling Labor Costs August 9 WRA Education Foundation & Washington State Chef’s Association’s annual Golf FORE! Education August 18 WRA Webinar: 10 SMART Systems for Reducing Profit Robbing Theft

Training July 6 July 15 July 19 July 19 July 28 August 3 August 14 August 25 August 26

ServSafe®, Seattle ServSafe®, Tacoma ServSafe®, Everett ServSafe®, Post Falls ServSafe®, Vancouver ServSafe®, Seattle ServSafe®, Tukwila Train the Trainer, King County ServSafe®, Kent

Meetings

July 6 Executive Committee Meeting July 13 Spokane Chapter Meeting July 20 Finance Committee Meeting July 25 – 27 WRA Board of Directors Meeting July 25 WRAEF Board Meeting August 3 Executive Committee Meeting August 4 Seattle Chapter Board Meeting August 10 Spokane Chapter Meeting August 11 Retro Investment Committee Meeting August 11 Retro Trustees Meeting

Visit www.WRAhome.com/calendar for a full list of events.

July 2010 | 23


S

tretch Your Healthcare Benefits

without Stretching Your Wallet Strata offers employees flexible healthcare coverage without costing the employer. Strata Limited Benefit Health Plan™ is an affordable limited benefit health insurance* program that WRA members can offer to full or part time employees. Strata includes an extensive network of physicians, are available to employees with pre-existing conditions.

Enrollees can be covered for the cost of a month of daily lattés.

For more information or to sign up contact your local area coordinator at www.WRAhome.com/healthcare * Limited Benefit Health Insurance is not basic health insurance or major medical coverage and is not designed as a substitute for basic health insurance of major medical coverage. Benefits may vary from state to state. The policies contain reductions, limitations, exclusions and termination provisions. Full details of the coverage are contained in each policy. If there are any conflicts between this document and each Policy, the Policy (series N20000 through N20010) shall govern. Not all coverages are available in every state. Limited Benefit Health Insurance is underwritten by National Fire Insurance Company of Pittsburgh, Pa. with its principal place of business in New York, NY.


Welcome New Allied Members American Underwriters Insurance Lavonne Northcutt 6429 South Tacoma Way Tacoma, WA 98409-4004 253.473.1415 lavonne@americanunderwriters.com www.auiagency.com American Underwriters Insurance Agency provides a variety of insurance products designed specifically for the restaurant & catering industries. Coldwell Banker Commercial Jim West 1500 D. St. Vancouver, WA 98663-3439 360.823.5109 jimw@cbcworldwidenw.com www.seavenreasonswhy.com Take the mysteries out of leasing! Avoid the many pitfalls, negative outcomes and lease rates too high to support a profitable business. We help you determine an affordable lease rate on the front end so that you can stay in business for the long haul. Eden Advanced Pest Technologies Jack Dein 1818 W. Francis Ave. Spokane, WA 99205-6834 509.327.3700 edenpest@aol.com Pest Control. Chef’s Club Special Offer: 5% discount on initial setup. Edge Creative, Inc. Heidi King 5447 Leary Ave. N.W. Seattle, WA 98107-4011 206.448.2222 www.theedgecreative.com The Edge Creative specializes in corporate communications including live events, video, motion graphics and campaigns. Gerard & Dominque Seafoods Karen Woodard 605 30th St. Anacortes, WA 98221-2884 800.454.0023 karenc@seabear.com www.seabear.com Gerard & Dominique Seafoods, under the direct supervision of Chef Dominique Place, services white table cloth restaurants, including the Morton’s of Chicago, La Pierre Hotel in NYC, and the WAC in Seattle with Chef Dominique’s signature small batch, European style smoked salmon, seafood soups and bases, and several other specialty smoked products.

Welcome New Members

Ms J’s Environmental Services Inc. Jerita Young 7015 95th Ave. S.W. Lakewood, WA 98498-4056 253.973.8831 msjyou@msn.com

2 Bit Saloon, Seattle

Commercial sanitation, janitorial services 24 hours. State of the art equipment and supplies. Also carpet and upholstery cleaning. Chef’s Club Special Offer: Initial cleaning free with free estimates.

Crossroads Bar & Grill, Bellevue

New Customers For Me, LLC Doug Farber 2218 Cedardale Rd. Mount Vernon, WA 98274-9561 360.661.0514 donna@newcustomersforme.com www.newcustomersforme.com

Fireside Café, Vancouver

Verifiable, trackable new high income customers for your business. Chef’s Club Special Offer: 40% off initial set up fee for WRA members. Thin Pig Branding Greg Gillard 36116 S.E. Turnberry St. Snoqualmie, WA 98065-8718 425.246.7893 gregg@thinpigbranding.com www.thinpigbranding.com

Blackbird Coffeehouse LLC, Port Angeles Cedarcrest Restaurant & Grill, Marysville

Delfino’s Pizzeria, Seattle DR Francom LLC, Mill Creek

French Bakery, The, Bellevue Higher Grounds Espresso Corp., Port Angeles IrishTown Bar & Grill, Vancouver Kristall’s Restaurant & Lounge, Cashmere Lake Forest Bar & Grill, Lake Forest Park Loose Wheel Bar & Grill, Tacoma Parkside Café, Easton

Thin Pig Branding is an irreverent social media management and consultation company. We effectively customize and manage clients social media profile sites and provide our best practiced methods to implement online promotional campaigns. Additionally Thin Pig Branding brings an online customer service level to our clients through chat sites, social media messages and blogs.

Pig Heaven Barbecue, Vancouver

Where to Eat Guide Seattle Metro John Herbik PO Box 6224 Bend, OR 97708-6224 541.610.4122 info@theeatguide.com www.theeatguide.com

Washington Restaurant Group Inc., Issaquah

We are a restaurant guide in print and online for tourism. Chef’s Club Special Offer: $100 off published print advertising rates.

Zeek’s Pizza, Issaquah

Road Runner Express Espresso & Café, Yelm Stacia’s Gourmet Pizza & Pasta, Seattle Verite Coffee Corp., Seattle

Wild Berry Restaurant, Ashford Woods Coffee Inc., Lynden

July 2010 | 25


Marketplace SELLING OR BUYING?

Thinking about selling or buying an existing restaurant, or adding a new location? Call Allan Boden, Sunbelt restaurant specialist at 206.229.4717, or email a.boden@sunbeltnetwork.com. Sunbelt has been serving clients since 1982 with offices nationwide. www.sunbeltseattle.com

PROFESSIONAL SELLER REPRESENTATION BY IBA

Thinking of selling a restaurant or food & hospitality related manufacturing, distribution, or service company? We have completed over 4000 transactions since 1975. Please contact us at (425) 454-3052 or by email at info@ibainc.com for additional information. All conversations held in strict confidence. www.ibainc.com

Have You Ever Considered Buying or Selling a Restaurant?

Get a FREE business evaluation and consultation today. Buyers and sellers are waiting to hear from YOU. Call Steve Hynds today at 425.343.2500, or shynds@balcosbusinessbrokers.com. www.stevehynds.com

SERVSAFE®

The WRA Education Foundation holds ServSafe food safety courses throughout Washington. Visit www. WRAhome.com/training for schedule information. Fee is $125 for members and includes the text, class and exam.

Drive-In Restaurant in Columbia Basin

Established and successful Columbia Basin drive-in restaurant for sale. Excellent location, stable client base with year round revenue. Picnic area outside and large seating capacity inside. RV parking and excellent highway access. Great opportunity for business investment. 1.877.664.3704.

July Chef’s Club SESAC

Susan Edwards 55 Music Sq. E. Nashville, TN 37203-4324 615.320.0055 www.sesac.com sedwards@sesac.com

Chef’s Club Special Offer:

10% discount plus an additional 10% discount to members who pay by January 31st of each year.

Established in 1930, SESAC’s mission is to ensure that creators of music are properly compensated and to provide businesses with a simple and cost effective process to obtain the required authorization to perform copyrighted music.

26 | www.WRAhome.com

Sonofresco

Robert Penrose 1365 Pacific Dr. Burlington, WA 98233-3128 360.757.2800 robert@sonofresco.com www.sonofresco.com

Chef’s Club Special Offer: 10% discount on all products.

Coffee Kinetics LLC is a team of dedicated professionals passionate about coffee. Located in Burlington, WA, north of Seattle, Coffee Kinetics began manufacturing and marketing the Sonofresco Tabletop Coffee Roaster in 2000 with the objective of bringing coffee roasting to the retail level and providing customers with the best coffee experience possible.


Ready to go anywhere. The horizon is wide open to franchise Seattle’s Best Coffee in your area. Our well-established brand has broad customer appeal, 40 years of operational excellence and the support of a national leader, Starbucks Corporation. The time is now. So if you’re ready to go, we are too.

Seattle’s Best Coffee is a featured brand within the Starbucks Corporation brand portfolio

SeattlesBestAnywhere.com • 206-318-8094 This is not an offer to sell a franchise. Offerings made by prospectus only. © 2010 Seattle’s Best Coffee, LLC. All rights reserved.


Golf FORE! Education Join the Washington State Chef’s Association and Washington Restaurant Association Education Foundation at the second annual Golf FORE! Education. Your participation in this year’s golf tournament helps sustain the future of our industry by supporting culinary students’ programs and scholarships.

Monday, August 9, 2010 McCormick Woods Golf Club 5155 McCormick Woods Drive SW Port Orchard, WA 98367

* Golfing ONLY $125 each player * Save $100 and register a golf foursome with a hole sponsorship! $700 * Hole sponsorship ONLY $300 * Reception/Awards Ceremony ONLY $35 each ticket

Register today at www.WRAhome.com/scholarships

For sponsorship information contact Lyle Hildahl at lyle@WRAhome.com, or 800.225.7166, ext. 108.


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