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From: Botwinick, Alexandra (HHS/OCIIO) Sent: Friday, September 24, 2010 4:45 PM To: 'ceinsmann@ual.org' Subject: Waiver of the Annual Limits Requirements of the PHS Act Section 2711 Attachments: OCIIO_Waiver_Acceptance_Letter.pdf Dear Applicant, Thank you for submitting an application for a Waiver of the Annual Limits Requirements of the PHS Act Section 2711. HHS has reviewed your application and made its determination. Please see the attached letter. Please confirm receipt of this letter by replying to this e-mail with a copy to OCIIOOversight@hhs.gov. Please let me know if I can be of further assistance. Sincerely, Alexandra Botwinick Office of Oversight HHS/OCIIO
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From: Pham, Erica (HHS/OCIIO) Sent: Tuesday, October 05, 2010 4:21 PM To: 'Wainblat, Neal B.' Subject: RE: Waiver Application-United Food & Commercial Workers Union-Employer Health & Welfare Fund
Mr. Wainblat: Thank you for sending us the updated information following our requests. Wed like the salary information regarding the individuals who are enrolled on the following plans: 03U 5T 05U 05L 81G 81J 81S 88U 92E 94I 94U 94L 95I 95R 88M 07M 17R 18M 20R 40R 72R 22M 47M 49R 50M 53R 58R 71M 76C Specifically, were interested in whether these are part-time or full-time workers, and the average salary of those individuals who are enrolled onto these plans. In addition, can you please confirm that the retiree plans listed in the application package do not have any current full-time employees? Kind Regards, Erica Pham From: Madry, Elaine G. [mailto:EMadry@littler.com] On Behalf Of Wainblat, Neal B. Sent: Wednesday, September 22, 2010 1:41 PM To: Pham, Erica (HHS/OCIIO) Subject: Waiver Application-United Food & Commercial Workers Union-Employer Health & Welfare Fund
Ms. Pham, Response attached. Regards Neal Wainblat
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Neal B. Wainblat, Attorney At Law
1 -216 -623 -6132 direct < NWainblat@littler.com 216 -696 -7600 Main/216 -696 -2038 Fax 1100 Superior Avenue 20th Floor | Cleveland , OH 44114
| littler.com
Employment & LaborLaw Solutions Worldwide
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To reply to our email administrator directly, send an email to postmaster@littler.com Littler Mendelson, P.C. http://www.littler.com
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This email may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender by reply email and delete all copies of this message.
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From: Clare Marie Einsmann, Esq. [ceinsmann@ual.org] Sent: Monday, October 18, 2010 6:57 PM To: Andrews, Jane (HHS/OCIIO) Cc: Botwinick, Alexandra (HHS/OCIIO) Subject: RE: Plans effective date clarification today. Follow Up Flag: Follow up Flag Status: Blue Hi Jane Ive d Ben Mulkey, UABTs independent actuary, to get you his opinion on what the rates would increase for the $Ex. 4 Tanimura & Antle benefit plan if it were forced to increase its annual limit to $750,000. I know that he will le to get back to you this evening so relax! As for the Teixeira Farms $Ex. 4 Plan yes it is a $Ex. 4 annual maximum plan! If you look on page B2, you will Ex. 4 see that it specifically refere e Plan Maximum . And again, all the plans will show unlimited lifetime benefits as of 1/1/2011! Thanks for all your efforts on our behalf. And as soon as I receive word from our actuary, I will pass it along to you!!!
Clare.
C please provide me with the actuarys estimate of what an annual limit of $Ex. 4 would increase rates by? There is a Ex. 4 $ annual limit on the tamura antil plan, but that type of annual limit and pe rease it is not provided on the actuarys letter, and I will need that. Also, I am not clear on what the Texeira Farms $Ex. 4 plan means. Is $Ex. 4 the annual limit? Please let me know. Generally, I note that your annual plan maximums are followed by a lifetime limit. As you know lifetime limits are not permitted, so please confirm that the lifetime limit language will not be included in future plan descriptions. I have completed my reviews and once I hear back on the tamura antil and Texiera Farms questions, I should be able to get you a decision on your applications. Thanks. Jane W. Andrews OCIIO 7501 Wisconsin Ave Bethesda, MD 20814
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From: Andrews, Jane (HHS/OCIIO) [mailto:Jane.Andrews@hhs.gov] Sent: Monday, October 18, 2010 3:31 PM To: 'Clare Marie Einsmann, Esq.' Cc: Botwinick, Alexandra (HHS/OCIIO) Subject: RE: Plans effective date clarification today.
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301-492-4122 (desk) 202-536-6779 (Blackberry)
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW: This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
From: Clare Marie Einsmann, Esq. [mailto:ceinsmann@ual.org] Sent: Monday, October 18, 2010 5:45 PM To: Andrews, Jane (HHS/OCIIO) Cc: Botwinick, Alexandra (HHS/OCIIO) Subject: RE: Plans effective date clarification today.
September 15 th letter. Unfortunately, when I received the paper binder for application review several weeks ago, the cover letter was not on the binder, and there was nothing in the binder itself to indicate a January 1, 2011 effective date, so I went with the cover page effective date for each plan, which range widely. Again, that is why our original letter indicated approval for October effective dates as those are the only plans I had reviewed. However, as I indicated in our phone call, between your actuarys letter with the percent increases for the varying annual limits for the plans, I dont foresee a problem in approving any of your plans, if they all fall within that range. In fact, I will stay late to review them, so I can confirm with you before the end of your day today. Again, I appreciate the clarification today on the effective date for all of the plans as January 1, 2011. Be back with you soon. Thanks Jane Andrews Jane W. Andrews OCIIO 7501 Wisconsin Ave
with the person who did the original data intake (unpackaged the paper application) and she had scanned in your September 15 th cover letter, so now I can see the application is for a January 1, 2011 effective date. Therefore, you dont need to send me the
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Clare thanks for speaking with me this afternoon. I appreciate the clarification around your application effective date. I checked
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From: Andrews, Jane (HHS/OCIIO) [mailto:Jane.Andrews@hhs.gov] Sent: Monday, October 18, 2010 2:16 PM To: 'ceinsmann@ual.org' Cc: Botwinick, Alexandra (HHS/OCIIO) Subject: Plans effective date clarification today.
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Jane Thank you so very much for your understanding. And I really appreciate your extra effort.
Bethesda, MD 20814 301-492-4122 (desk) 202-536-6779 (Blackberry)
From: Clare Marie Einsmann, Esq. [mailto:ceinsmann@ual.org] Sent: Monday, October 18, 2010 11:53 AM To: Botwinick, Alexandra (HHS/OCIIO) Subject: RE: THIRD REQUEST FOR CONFIRMATION
Clare.
I have changed your plans effective date in our file and have attached an approval for your January 1st effective date. Please confirm with me that you received this e-mail and the attachment. Sincerely,
Alexandra Botwinick Office of Oversight HHS/OCIIO
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Ms. Einsmann, Thank you for your prompt response.
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From: Botwinick, Alexandra (HHS/OCIIO) [mailto:Alexandra.Botwinick@hhs.gov] Sent: Monday, October 18, 2010 8:52 AM To: 'Clare Marie Einsmann, Esq.' Subject: RE: THIRD REQUEST FOR CONFIRMATION
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Dear Ms. Botwinick Thank you so very much for changing the effective date of our plan waiver. We are most appreciative of this change as it now coincides with our plan year effective date. I have received the attachment which has the appropriate January effective date. And I thank you for your assistance.
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From: Clare Marie Einsmann, Esq. [mailto:ceinsmann@ual.org] Sent: Monday, October 18, 2010 11:14 AM To: Botwinick, Alexandra (HHS/OCIIO) Subject: RE: THIRD REQUEST FOR CONFIRMATION Importance: High
Clare.
Dear Applicant, Can you please confirm that you received the approval letter for a waiver of the annual limits requirements of PHS Act Section 2711 on September 24, 2010. Your cooperation is greatly appreciated.
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From: Botwinick, Alexandra (HHS/OCIIO) [mailto:Alexandra.Botwinick@hhs.gov] Sent: Monday, October 18, 2010 7:15 AM To: 'ceinsmann@ual.org' Subject: THIRD REQUEST FOR CONFIRMATION Importance: High
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Dear Ms. Botwinick Yes, United Agricultural Benefit Trust did receive our notice of approval. (Im sorry I didnt get this response to you sooner, I was unexpectedly out of the office for a couple of days.) And please be advised that I did originally attempt to respond to the email address provided, however each time that I submitted my response, I received an error message. We would, however, like to request a change in the effective dates of the approval. Our plan year is January 1st. The approval is for October 1st. How should I go about requesting that the plan year be changed on our waiver approval? To whom should this request be sent? Thank you for your assistance in this matter.
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From: Andrews, Jane (HHS/OCIIO) Sent: Monday, October 18, 2010 5:16 PM To: 'ceinsmann@ual.org' Cc: Botwinick, Alexandra (HHS/OCIIO) Subject: Plans effective date clarification today. Follow Up Flag: Follow up Flag Status: Blue
Clare.
Clare Marie Einsmann, Esq. Executive Vice President United Agribusiness League 54 Corporate Park
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file:///T|/...12600%20Response%20[YELLOW]/UABT/Clarification%20of%20change%20in%20effective%20date-approval%20letter.htm[08/01/2011 10:55:46 AM]
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September 15 th letter. Unfortunately, when I received the paper binder for application review several weeks ago, the cover letter was not on the binder, and there was nothing in the binder itself to indicate a January 1, 2011 effective date, so I went with the cover page effective date for each plan, which range widely. Again, that is why our original letter indicated approval for October effective dates as those are the only plans I had reviewed. However, as I indicated in our phone call, between your actuarys letter with the percent increases for the varying annual limits for the plans, I dont foresee a problem in approving any of your plans, if they all fall within that range. In fact, I will stay late to review them, so I can confirm with you before the end of your day today. Again, I appreciate the clarification today on the effective date for all of the plans as January 1, 2011. Be back with you soon. Thanks Jane Andrews Jane W. Andrews OCIIO 7501 Wisconsin Ave Bethesda, MD 20814 301-492-4122 (desk) 202-536-6779 (Blackberry)
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ceinsmann@ual.org
Clare.
Clare Marie Einsmann, Esq. Executive Vice President
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United Agribusiness League 54 Corporate Park Irvine, CA 92606.5105 800.223.4590 or 949.975.1424 Fax: 949.975.1573 ceinsmann@ual.org
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From: Andrews, Jane (HHS/OCIIO) Sent: Monday, October 18, 2010 5:54 PM To: 'Clare Marie Einsmann, Esq.' Cc: Botwinick, Alexandra (HHS/OCIIO) Subject: RE: Plans effective date clarification today. Follow Up Flag: Follow up Flag Status: Blue
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file:///T|/...cations%20with%20NO%2012600%20Response%20[YELLOW]/UABT/Request%20for%20more%20info%2010-18-2010.htm[08/01/2011 10:55:47 AM]
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You are welcome. Quick question. Wherever the current plan summary descriptions state that there is a lifetime limit, that language will no longer be there for the January 1, 2011 effective date plans, right? Jane W. Andrews OCIIO 7501 Wisconsin Ave Bethesda, MD 20814 301-492-4122 (desk) 202-536-6779 (Blackberry)
ceinsmann@ual.org
Ms. Einsmann,
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Thank you for your prompt response.
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From: Botwinick, Alexandra (HHS/OCIIO) [mailto:Alexandra.Botwinick@hhs.gov] Sent: Monday, October 18, 2010 7:15 AM To: 'ceinsmann@ual.org' Subject: THIRD REQUEST FOR CONFIRMATION
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Importance: High Dear Applicant, Can you please confirm that you received the approval letter for a waiver of the annual limits requirements of PHS Act Section 2711 on September 24, 2010. Your cooperation is greatly appreciated.
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From: Andrews, Jane (HHS/OCIIO) Sent: Monday, October 18, 2010 6:31 PM To: 'Clare Marie Einsmann, Esq.' Cc: Botwinick, Alexandra (HHS/OCIIO) Subject: RE: Plans effective date clarification today. Follow Up Flag: Follow up Flag Status: Blue
Clare.
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C please provide me with the actuarys estimate of what an annual limit of $Ex. 4 would increase rates by? There is a Ex. 4 $ annual limit on the tamura antil plan, but that type of annual limit and percent increase it is not provided on the actuarys letter, and I will need that. Also, I am not clear on what the Texeira Farms $Ex. 4 plan means. Is $Ex. 4 the annual limit? Please let me know. Generally, I note that your annual plan maximums are followed by a lifetime limit. As you know lifetime limits are not permitted, so please confirm that the lifetime limit language will not be included in future plan descriptions. I have completed my reviews and once I hear back on the tamura antil and Texiera Farms questions, I should be able to get you a decision on your applications. Thanks. Jane W. Andrews OCIIO 7501 Wisconsin Ave Bethesda, MD 20814 301-492-4122 (desk) 202-536-6779 (Blackberry)
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Clare.
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Clare.
Clare Marie Einsmann, Esq. Executive Vice President United Agribusiness League 54 Corporate Park Irvine, CA 92606.5105
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800.223.4590 or 949.975.1424 Fax: 949.975.1573 ceinsmann@ual.org

From: Botwinick, Alexandra (HHS/OCIIO) [mailto:Alexandra.Botwinick@hhs.gov] Sent: Monday, October 18, 2010 7:15 AM To: 'ceinsmann@ual.org' Subject: THIRD REQUEST FOR CONFIRMATION Importance: High Dear Applicant, Can you please confirm that you received the approval letter for a waiver of the annual limits requirements of PHS Act Section 2711 on September 24, 2010. Your cooperation is greatly appreciated.
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From: Botwinick, Alexandra (HHS/OCIIO) Sent: Monday, October 18, 2010 11:52 AM To: 'Clare Marie Einsmann, Esq.' Subject: RE: THIRD REQUEST FOR CONFIRMATION Attachments: Updated Jan 1 Approval Letter .pdf Ms. Einsmann, Thank you for your prompt response.
Clare.
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file:///T|/...20with%20NO%2012600%20Response%20[YELLOW]/UABT/Updated%20Approval%20Letter%20Sent%2010-18-2010.htm[08/01/2011 10:55:48 AM]
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From: Clare Marie Einsmann, Esq. [ceinsmann@ual.org] Sent: Monday, October 18, 2010 11:14 AM To: Botwinick, Alexandra (HHS/OCIIO) Subject: RE: THIRD REQUEST FOR CONFIRMATION Importance: High Dear Ms. Botwinick Yes, United Agricultural Benefit Trust did receive our notice of approval. (Im sorry I didnt get this response to you sooner, I was unexpectedly out of the office for a couple of days.) And please be advised that I did originally attempt to respond to the email address provided, however each time that I submitted my response, I received an error message. We would, however, like to request a change in the effective dates of the approval. Our plan year is January 1st. The approval is for October 1st. How should I go about requesting that the plan year be changed on our waiver approval? To whom should this request be sent? Thank you for your assistance in this matter.
Clare.
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From: Botwinick, Alexandra (HHS/OCIIO) Sent: Friday, October 15, 2010 1:43 PM To: 'ceinsmann@ual.org' Subject: Second Request For Confirmation of Receipt of Approval Letter Importance: High Good Afternoon, The e-mail you received containing the Approved Waiver of the Annual Limits Requirements of PHS Act Section 2711 instructed you to confirm receipt of the e-mail and attached Approval Letter. Please e-mail back to confirm receipt as soon as possible. Sincerely,

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From: Botwinick, Alexandra (HHS/OCIIO) Sent: Monday, October 18, 2010 11:52 AM To: 'Clare Marie Einsmann, Esq.' Subject: RE: THIRD REQUEST FOR CONFIRMATION Attachments: Updated Jan 1 Approval Letter .pdf Ms. Einsmann, Thank you for your prompt response.
Clare.
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file:///T|/...th%20NO%2012600%20Response%20[YELLOW]/UABT/RE%20THIRD%20REQUEST%20FOR%20CONFIRMATION.htm[08/01/2011 10:55:50 AM]
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From: Clare Marie Einsmann, Esq. [ceinsmann@ual.org] Sent: Monday, October 18, 2010 11:53 AM To: Botwinick, Alexandra (HHS/OCIIO) Subject: RE: THIRD REQUEST FOR CONFIRMATION Dear Ms. Botwinick Thank you so very much for changing the effective date of our plan waiver. We are most appreciative of this change as it now coincides with our plan year effective date. I have received the attachment which has the appropriate January effective date. And I thank you for your assistance.
Clare.
ceinsmann@ual.org
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Dear Ms. Botwinick -
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Yes, United Agricultural Benefit Trust did receive our notice of approval. (Im sorry I didnt get this response to you sooner, I was unexpectedly out of the office for a couple of days.) And please be advised that I did originally attempt to respond to the email address provided, however each time that I submitted my response, I received an error message. We would, however, like to request a change in the effective dates of the approval. Our plan year is January 1st. The approval is for October 1st. How should I go about requesting that the plan year be changed on our waiver approval? To whom should this request be sent? Thank you for your assistance in this matter.
Our e-mails literally crossed in the mail. I will review this and get back to you tomorrow. Thanks. Jane W. Andrews OCIIO 7501 Wisconsin Ave Bethesda, MD 20814 301-492-4122 (desk) 202-536-6779 (Blackberry)
From: Andrews, Jane (HHS/OCIIO) Sent: Tuesday, October 19, 2010 7:20 PM To: 'Clare Marie Einsmann, Esq.' Cc: Botwinick, Alexandra (HHS/OCIIO); Habit, Sandra (HHS/OCIIO) Subject: RE: Plans effective date clarification today.
From: Clare Marie Einsmann, Esq. [mailto:ceinsmann@ual.org] Sent: Tuesday, October 19, 2010 7:15 PM To: Andrews, Jane (HHS/OCIIO) Cc: Botwinick, Alexandra (HHS/OCIIO) Subject: RE: Plans effective date clarification today.
Dear Jane Attached is the letter from United Agricultural Benefit Trusts ABTs) consulting actuary stating that the anticipated increase for the Tanimura & Antle Mexican Panel Plan will be Ex. 4 % if it were required to increase the annual maximum to $750,000. This number is comparatively lower than our oth cost trends because all the medical benefits for this plan are rendered in Mexico where medical costs average 1/3 rd of the costs of those in the United States. (So it can be factored that the trend would be significantly greater if applied to U.S. medical rates maybe Ex. 4 %.) The Tanimura & Antle Mexican Panel Plan is a very unique benefit plan design. Their seasonal growing operation is along the California/Ariz d Mexican border s a seasonal plan and is active October through May each year. Ex. 4 There are approximately farm laborers and Ex. 4 dependents whose only health benefits are those that they receive from United Agricultural it Trusts contract doctor panel in the towns and cities along the border of Mexico. Tanimura & Antles workforce is low income farm laborers. They are documented workers but many of the workers reside in Mexico and cross the border each day to work in the agricultural fields and return to Mexico each evening. Because they are working for a U.S. firm, they are not eligible for the Mexican socialized medical program. The only medical care they could receive if the Tanimura & Antle plan were discontinued would be Medicaid. Despite the fact that benefits are provided in Mexico, the Tanimura & Antle Mexican Plan is a comprehensive major medical benefit plan providing hospital, physician, diagnostic testing, prescription medication, etc. The physicians and hospitals are vetted and excellent quality. And most important, the participants are pleased with their health benefits. The plan is priced at a rate which the Tanimura & Antle can afford rates which enable the employer to provide their employees health benefits at no cost sharing. And the employer knows that these employees cannot afford to share the cost of benefits. And if the employer were to cease providing benefits the employee would not be able to obtain health benefits independently. In discussions with our employer it would appear that Tanimura & Antle may not be able to afford to continue to offer benefits if the cost increases even Ex. 4 %. There is little profit margin in the wholesale production agriculture. It is
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virtually impossible for an agricultural producer to increase costs and pass them along to the consumer. If the cost of a head lettuce increases, the consumer will bypass a salad with dinner and opt for broccoli or zucchini. As I have indicated, UABT relied on our notice of September 24, 2010 notice from Steve Larsen, Director of the Office of oversight and notified all of our participating employers, including Tanimura & Antle, that UABT received a waiver of the annual limits for all of its plans, including the Tanimura & Antle plan. I now ask that Tanimura & Antle continue to be included in the waiver granted UABT on September 24th as amended on October 18th . Thank you for your consideration and efforts on our behalf. And if you have any questions, please let me know. Very truly yours, Clare Marie Einsmann, Esq. Executive Vice President United Agribusiness League 54 Corporate Park Irvine, CA 92606.5105 800.223.4590 or 949.975.1424 Fax: 949.975.1573 ceinsmann@ual.org
From: Clare Marie Einsmann, Esq. [mailto:ceinsmann@ual.org] Sent: Monday, October 18, 2010 06:57 PM To: Andrews, Jane (HHS/OCIIO) Cc : Botwinick, Alexandra (HHS/OCIIO) Subject : RE: Plans effective date clarification today.
Hi Jane Ive d Ben Mulkey, UABTs independent actuary, to get you his opinion on what the rates would increase for the $Ex. 4 Tanimura & Antle benefit plan if it were forced to increase its annual limit to $750,000. I know that he will not be able to get back to you this evening so relax! As for the Teixeira Farms $Ex. 4 Plan yes it is a $Ex. 4 nual maximum plan! If you look on page B2, you will Ex. 4 see that it specifically refere e Plan Maximum at $ . And again, all the plans will show unlimited lifetime benefits as of 1/1/2011! Thanks for all your efforts on our behalf. And as soon as I receive word from our actuary, I will pass it along to you!!!
Clare.
Clare Marie Einsmann, Esq. Executive Vice President United Agribusiness League
UABT:000041
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That's helpful. I will look for your e-mail tomorrow regarding Tanamura and Antle. Have a good evening.
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From: Andrews, Jane (HHS/OCIIO) [mailto:Jane.Andrews@hhs.gov] Sent: Monday, October 18, 2010 4:07 PM To: 'ceinsmann@ual.org' Cc: Botwinick, Alexandra (HHS/OCIIO) Subject: Re: Plans effective date clarification today.
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54 Corporate Park Irvine, CA 92606.5105 800.223.4590 or 949.975.1424 Fax: 949.975.1573 ceinsmann@ual.org

From: Andrews, Jane (HHS/OCIIO) [mailto:Jane.Andrews@hhs.gov] Sent: Monday, October 18, 2010 3:31 PM To: 'Clare Marie Einsmann, Esq.' Cc: Botwinick, Alexandra (HHS/OCIIO) Subject: RE: Plans effective date clarification today. C please provide me with the actuarys estimate of what an annual limit of $ would increase rates by? There is a $Ex. 4 annual limit on the tamura antil plan, but that type of annual limit and percent increase it is not provided on the actuarys letter, and I will need that. Also, I am not clear on what the Texeira Farms $Ex. 4 plan means. Is $Ex. 4 the annual limit? Please let me know. Generally, I note that your annual plan maximums are followed by a lifetime limit. As you know lifetime limits are not permitted, so please confirm that the lifetime limit language will not be included in future plan descriptions. I have completed my reviews and once I hear back on the tamura antil and Texiera Farms questions, I should be able to get you a decision on your applications. Thanks. Jane W. Andrews OCIIO 7501 Wisconsin Ave Bethesda, MD 20814 301-492-4122 (desk) 202-536-6779 (Blackberry)
Ex. 4
Clare.
Clare Marie Einsmann, Esq. Executive Vice President United Agribusiness League 54 Corporate Park Irvine, CA 92606.5105 800.223.4590 or 949.975.1424
UABT:000042
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Fax: 949.975.1573 ceinsmann@ual.org

Clare.
Clare Marie Einsmann, Esq. Executive Vice President United Agribusiness League
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54 Corporate Park Irvine, CA 92606.5105 800.223.4590 or 949.975.1424 Fax: 949.975.1573

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Clare Marie Einsmann, Esq.
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Executive Vice President United Agribusiness League 54 Corporate Park Irvine, CA 92606.5105 800.223.4590 or 949.975.1424 Fax: 949.975.1573 ceinsmann@ual.org
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Hi Jane Ive d Ben Mulkey, UABTs independent actuary, to get you his opinion on what the ould increase for the $Ex. 4 Tanimura & Antle benefit plan if it were forced to increase its annual limit to $ Ex. 4 I know that he will le to get back to you this evening so relax! As for the Teixeira Farms $Ex. 4 Plan yes it is a $Ex. 4 nual maximum plan! If you look on page B2, you will Ex. 4 see that it specifically refere e Plan Maximum . And again, all the plans will show unlimited lifetime benefits as of 1/1/2011! Thanks for all your efforts on our behalf. And as soon as I receive word from our actuary, I will pass it along to you!!!
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Clare just checking back to see if you were able to get the information on what percent increase in rates for the $250,000 annual limits plan. Thanks Jane W. Andrews OCIIO 7501 Wisconsin Ave Bethesda, MD 20814 301-492-4122 (desk) 202-536-6779 (Blackberry)
From: Andrews, Jane (HHS/OCIIO) Sent: Tuesday, October 19, 2010 7:18 PM To: 'Clare Marie Einsmann, Esq.' Cc: Habit, Sandra (HHS/OCIIO); Botwinick, Alexandra (HHS/OCIIO) Subject: RE: Plans effective date clarification today.
UABT:000046
file:///T|/...0with%20NO%2012600%20Response%20[YELLOW]/UABT/2nd%20Request%20for%20additional%20info%2010.19.10.htm[08/01/2011 10:55:52 AM]
Jane Thank you so very much for your understanding. And I really appreciate your extra effort. Clare Marie Einsmann, Esq. Executive Vice President United Agribusiness League 54 Corporate Park Irvine, CA 92606.5105 800.223.4590 or 949.975.1424 Fax: 949.975.1573 ceinsmann@ual.org
with the person who did the original data intake (unpackaged the paper application) and she had scanned in your September 15 th
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Can you please provide me with the actuarys estimate of what an annual limit of $Ex. 4 would increase rates by? There is a $Ex. 4 annual limit on the tamura antil plan, but that type of annual limit and per rease it is not provided on the actuarys letter, and I will need that. Also, I am not clear on what the Texeira Farms $Ex. 4 plan means. Is $Ex. 4 the annual limit? Please let me know. Generally, I note that your annual plan maximums are followed by a lifetime limit. As you know lifetime limits are not permitted, so please confirm that the lifetime limit language will not be included in future plan descriptions. I have completed my reviews and once I hear back on the tamura antil and Texiera Farms questions, I should be able to get you a decision on your applications. Thanks. Jane W. Andrews OCIIO 7501 Wisconsin Ave Bethesda, MD 20814 301-492-4122 (desk) 202-536-6779 (Blackberry)
Clare.
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cover letter, so now I can see the application is for a January 1, 2011 effective date. Therefore, you dont need to send me the
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Clare.
From: Botwinick, Alexandra (HHS/OCIIO) [mailto:Alexandra.Botwinick@hhs.gov] Sent: Monday, October 18, 2010 7:15 AM
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To: 'ceinsmann@ual.org' Subject: THIRD REQUEST FOR CONFIRMATION Importance: High Dear Applicant, Can you please confirm that you received the approval letter for a waiver of the annual limits requirements of PHS Act Section 2711 on September 24, 2010. Your cooperation is greatly appreciated.
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From: Andrews, Jane (HHS/OCIIO) Sent: Tuesday, October 19, 2010 7:53 AM To: Botwinick, Alexandra (HHS/OCIIO) Cc: Pham, Erica (HHS/OCIIO); Andrews, Jane (HHS/OCIIO) Subject: UABT data for inputting Follow Up Flag: Follow up Flag Status: Blue
These are all self-insured, group plans. Annual plan 10, Ex. 4 individuals, AL w ady approved Annual plan 25, Ex. 4 individuals, AL $Ex. 4 , Ex. 4 % ease Annual Plan 30, Ex. 4 ndividuals, AL Ex. 4 about a Ex. 4 % increase Ex. 4% in Annual plan 50, Ex. 4 individuals, AL $Ex. 4 se Ex. 4 Ex. Ex. 4 Annual Plan 75, individuals, AL $ 4 % increase Ex. 4 Annual Plan 100 Ex. 4 individuals, A Ex. 4 % increase(already approved) Ex. 4 Ex. 4 Ex. 4 Annual Plan 125, individuals L Medical Expense benefits, plan 1, Ex. 4 ndividuals, $Ex. 4 AL, Ex. 4 increase Ex. 4 Ex. 4 Medical Expense Benefit an 2, indi ,$ AL, Ex. 4 % increase Ex. 4 Major Medical A83 n, Ex. 4 individua , Ex. 4 % increase Ex. 4 Ex. 4 Ex. 4 Major Medical B83, individuals, AL % increase Ex. 4 Ex. 4 % increase Major Medical , Ex. 4 individual Ex. 4 Field 96 P individuals, AL Ex. 4 , Ex. 4 % increase Ex. 4 Ex. 4 Ex. 4 Plan 25A, individuals, AL % increase Ex. 4 Ex. 4 Plan 30A, Ex. 4 vidu % increase Ex. 4 Produce p , AL Ex. 4 , Ex. 4 s Ex. 4 Ex. 4 Conversion pla , , , Ex. 4 % increase Artichoke and Veg , Ex. 4 individuals, AL Ex. 4 , Ex. 4 % increase Ex. 4 Ex. 4 Artichoke and Veg Trust Plan III, ndividuals, AL , Ex. % increase 4 Ex. 4 Ex. 4 Ex. 4 Earthbound Farms Mexican P individu AL cre Foothill Packing Plan 50/152, Ex. 4 individuals, Ex. 4 individuals, Ex. 4 AL, Ex. 4% increase about Ex. 4 % increase Hiji Brothers Inc. and Seaview, Ex. 4 individual Ex. 4 individuals, AL Ex. 4 Ex. 4 Ex. 4 Ex. 4 JE Farms Seasonal Plan, individuals, A % increase Ex. 4 Mann Packi lan 60, Ex. 4 ind , AL Ex. 4 b % increase Ex. 4 Ex. 4 Ex. 4 Oro 1 Plan, individuals, AL , %i se Plata 1 Plan Ex. 4 individuals, Ex. 4 AL out Ex. 4 % increase Tanamura and Antle Mexican Plan To Be Determined , Ex. 4% increase Taylor Farms Pacific Inc. Plan, Ex. 4 individuals, AL Ex. 4 Teixeira Farms, To be Determined Thanks Jane W. Andrews OCIIO 7501 Wisconsin Ave Bethesda, MD 20814 301-492-4122 (desk) 202-536-6779 (Blackberry)
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW: This information has not been publicly disclosed and may be privileged and confidential. It is for internal government
UABT:000051
file:///T|/...LLOW/Applications%20with%20NO%2012600%20Response%20[YELLOW]/UABT/Requested%20Info%2010-19-2010.htm[08/01/2011 10:55:52 AM]
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use only and must not be disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
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file:///T|/...LLOW/Applications%20with%20NO%2012600%20Response%20[YELLOW]/UABT/Requested%20Info%2010-19-2010.htm[08/01/2011 10:55:52 AM]
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Dear Jane Attached is the letter from United Agricultural Benefit Trusts ABTs) consulting actuary stating that the anticipated increase for the Tanimura & Antle Mexican Panel Plan will be Ex. 4 % if it were required to increase the annual maximum to $750,000. This number is comparatively lower than our oth cost trends because all the medical benefits for this plan are rendered in Mexico where medical costs average 1/3 rd of the costs of those in the United States. (So it can be factored that the trend would be significantly greater if applied to U.S. medical rates maybe Ex. 4 %.) The Tanimura & Antle Mexican Panel Plan is a very unique benefit plan design. Their seasonal growing operation is along the California/Ariz nd Mexican border. s a seasonal plan and is active October through May each year. Ex. 4 There are approximately farm laborers and Ex. 4 dependents whose only health benefits are those that they receive from United Agricultural fit Trusts contract doctor panel in the towns and cities along the border of Mexico. Tanimura & Antles workforce is low income farm laborers. They are documented workers but many of the workers reside in Mexico and cross the border each day to work in the agricultural fields and return to Mexico each evening. Because they are working for a U.S. firm, they are not eligible for the Mexican socialized medical program. The only medical care they could receive if the Tanimura & Antle plan were discontinued would be Medicaid. Despite the fact that benefits are provided in Mexico, the Tanimura & Antle Mexican Plan is a comprehensive major medical benefit plan providing hospital, physician, diagnostic testing, prescription medication, etc. The physicians and hospitals are vetted and excellent quality. And most important, the participants are pleased with their health benefits.
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Clare we did a review of your e-mail letter below dated 10/19/2010 as well as your actuarys letter and can approve the Tanimura & Antle plan to be included in UABTs waiver approval letter dated October 18, 2010. Therefore, all plans included in your application dated September 15, 2010 are considered to be approved for a waiver of annual limits for a one-year period as indicated in the October 18, 2010 approval letter. Thanks and let me know if you have questions. Jane Jane W. Andrews OCIIO 7501 Wisconsin Ave Bethesda, MD 20814 301-492-4122 (desk) 202-536-6779 (Blackberry)
From: Andrews, Jane (HHS/OCIIO) Sent: Wednesday, October 20, 2010 4:08 PM To: 'Clare Marie Einsmann, Esq.' Cc: Botwinick, Alexandra (HHS/OCIIO); Habit, Sandra (HHS/OCIIO) Subject: RE: Plans effective date clarification today.
UABT:000053
file:///T|/...%20NO%2012600%20Response%20[YELLOW]/UABT/Correspondence%20regarding%20plan%20inclusion%2010.20.10.htm[08/01/2011 10:55:53 AM]
Clare.
Hi Jane Ive contacted Ben Mulkey, UABTs independent actuary, to get you his opinion on what the rates would increase for the $Ex. 4 Tanimura & Antle benefit plan if it were forced to increase its annual limit to $750,000. I know that he will le to get back to you this evening so relax! As for the Teixeira Farms $Ex. 4 Plan yes it is a $ Ex. 4 annual maximum plan! If you look on page B2, you will see that it specifically refere e Plan Maximum a Ex. 4 . And again, all the plans will show unlimited lifetime benefits as of 1/1/2011!
UABT:000054
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The plan is priced at a rate which the Tanimura & Antle can afford rates which enable the employer to provide their employees health benefits at no cost sharing. And the employer knows that these employees cannot afford to share the cost of benefits. And if the employer were to cease providing benefits the employee would not be able to obtain health benefits independently. In discussions with our employer would appear that Tanimura & Antle may not be able to afford to continue to offer benefits if the cost increases even Ex. 4 %. There is little profit margin in the wholesale production agriculture. It is virtually impossible for an agricul ral producer to increase costs and pass them along to the consumer. If the cost of a head lettuce increases, the consumer will bypass a salad with dinner and opt for broccoli or zucchini. As I have indicated, UABT relied on our notice of September 24, 2010 notice from Steve Larsen, Director of the Office of oversight and notified all of our participating employers, including Tanimura & Antle, that UABT received a waiver of the annual limits for all of its plans, including the Tanimura & Antle plan. I now ask that Tanimura & Antle continue to be included in the waiver granted UABT on September 24th as amended on October 18th . Thank you for your consideration and efforts on our behalf. And if you have any questions, please let me know. Very truly yours,
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Thanks for all your efforts on our behalf. And as soon as I receive word from our actuary, I will pass it along to you!!!
Clare.
UABT:000055
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C please provide me with the actuarys estimate of what an annual limit of $Ex. 4 would increase rates by? There is a Ex. 4 $ annual limit on the tamura antil plan, but that type of annual limit and per ease it is not provided on the actuarys le I will need that. Also, I am not clear on what the Texeira Farms $Ex. 4 plan means. Is $ Ex. 4 the annual limit? Please let me know. Generally, I note that your annual plan maximums are followed by a lifetime limit. As you know lifetime limits are not permitted, so please confirm that the lifetime limit language will not be included in future plan descriptions. I have completed my reviews and once I hear back on the tamura antil and Texiera Farms questions, I should be able to get you a decision on your applications. Thanks. Jane W. Andrews OCIIO 7501 Wisconsin Ave Bethesda, MD 20814 301-492-4122 (desk) 202-536-6779 (Blackberry)
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Clare.
Dear Ms. Botwinick Thank you so very much for changing the effective date of our plan waiver. We are most appreciative of this change as it now coincides with our plan year effective date.
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I have received the attachment which has the appropriate January effective date. And I thank you for your assistance.
Clare.
ceinsmann@ual.org
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Dear Ms. Botwinick Yes, United Agricultural Benefit Trust did receive our notice of approval. (Im sorry I didnt get this response to you sooner, I was unexpectedly out of the office for a couple of days.) And please be advised that I did originally attempt to respond to the email address provided, however each time that I submitted my response, I received an error message. We would, however, like to request a change in the effective dates of the approval. Our plan year is January 1st. The
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approval is for October 1st. How should I go about requesting that the plan year be changed on our waiver approval? To whom should this request be sent? Thank you for your assistance in this matter.
Clare.
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UABT:000058
From: Clare Marie Einsmann, Esq. [ceinsmann@ual.org] Sent: Wednesday, October 20, 2010 4:57 PM To: Andrews, Jane (HHS/OCIIO) Cc: Botwinick, Alexandra (HHS/OCIIO); Habit, Sandra (HHS/OCIIO) Subject: RE: Plans effective date clarification today. Jane Thank you so much for your efforts at getting all of the UABT plans approved for the plan year of January 2011. I really appreciate your cooperation and understanding of our benefit programs. Clare Marie Einsmann, Esq. Executive Vice President United Agribusiness League 54 Corporate Park Irvine, CA 92606.5105 800.223.4590 or 949.975.1424 Fax: 949.975.1573 ceinsmann@ual.org
UABT:000059
file:///T|/...ith%20NO%2012600%20Response%20[YELLOW]/UABT/Resp%20Correspondence%20regarding%20plan%20inclusion.htm[08/01/2011 10:55:54 AM]
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From: Andrews, Jane (HHS/OCIIO) [mailto:Jane.Andrews@hhs.gov] Sent: Wednesday, October 20, 2010 1:08 PM To: 'Clare Marie Einsmann, Esq.' Cc: Botwinick, Alexandra (HHS/OCIIO); Habit, Sandra (HHS/OCIIO) Subject: RE: Plans effective date clarification today.
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Dear Jane Attached is the letter from United Agricultural Benefit Trusts (UABTs) consulting actuary stating that the anticipated increase for the Tanimura & Antle Mexican Panel Plan will be Ex. 4 % if it were required to increase the annual maximum to $750,000. This number is comparatively lower than our othe cost trends because all the medical benefits for this plan are rendered in Mexico where medical costs average 1/3 rd of the costs of those in the Uni d States. (So it can be factored that the trend would be significantly greater if applied to U.S. medical rates maybe Ex. 4 %.) The Tanimura & Antle Mexican Panel Plan is a very unique benefit plan design. Their seasonal growing operation is along the California/Ariz nd Mexican border. It is a seasonal plan and is active October through May each year. Ex. 4 There are approximately farm laborers and Ex. 4 dependents whose only health benefits are those that they receive from United Agricultural fit Trusts contract octor panel in the towns and cities along the border of Mexico. Tanimura & Antles workforce is low income farm laborers. They are documented workers but many of the workers reside in Mexico and cross the border each day to work in the agricultural fields and return to Mexico each evening. Because they are working for a U.S. firm, they are not eligible for the Mexican socialized medical program. The only medical care they could receive if the Tanimura & Antle plan were discontinued would be Medicaid. Despite the fact that benefits are provided in Mexico, the Tanimura & Antle Mexican Plan is a comprehensive major medical benefit plan providing hospital, physician, diagnostic testing, prescription medication, etc. The physicians and hospitals are vetted and excellent quality. And most important, the participants are pleased with their health benefits. The plan is priced at a rate which the Tanimura & Antle can afford rates which enable the employer to provide their employees health benefits at no cost sharing. And the employer knows that these employees cannot afford to share the cost of benefits. And if the employer were to cease providing benefits the employee would not be able to obtain health benefits independently. In discussions with our employer it would appear that Tanimura & Antle may not be able to afford to continue to offer benefits if the cost increases even 4 %. There is little profit margin in the wholesale production agriculture. It is virtually impossible for an agricul ral producer to increase costs and pass them along to the consumer. If the cost of a head lettuce increases, the consumer will bypass a salad with dinner and opt for broccoli or zucchini. As I have indicated, UABT relied on our notice of September 24, 2010 notice from Steve Larsen, Director of the Office of oversight and notified all of our participating employers, including Tanimura & Antle, that UABT received a waiver of the annual limits for all of its plans, including the Tanimura & Antle plan. I now ask that Tanimura & Antle continue to be included in the waiver granted UABT on September 24th as amended on October 18th . Thank you for your consideration and efforts on our behalf. And if you have any questions, please let me know. Very truly yours,
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Clare.
C please provide me with the actuarys estimate of what an annual limit of $Ex. 4 would increase rates by? There is a Ex. 4 $ annual limit on the tamura antil plan, but that type of annual limit and percent increase it is not provided on the actuarys letter, and I will need that. Also, I am not clear on what the Texeira Farms $Ex. 4 plan means. Is $ Ex. 4 the annual limit? Please let me know. Generally, I note that your annual plan maximums are followed by a lifetime limit. As you know lifetime limits are not permitted, so please confirm that the lifetime limit language will not be included in future plan descriptions. I have completed my reviews and once I hear back on the tamura antil and Texiera Farms questions, I should be able to get you a decision on your applications. Thanks.
UABT:000061
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Hi Jane Ive d Ben Mulkey, UABTs independent actuary, to get you his opinion on what the rates would increase for the $Ex. 4 Tanimura & Antle benefit plan if it were forced to increase its annual limit to $750,000. I know that he will le to get back to you this evening so relax! Ex. 4 As for the Teixeira Farms $ Ex. 4 Plan yes it is a $ annual maximum plan! If you look on page B2, you will Ex. 4 see that it specifically refere e Plan Maximum . And again, all the plans will show unlimited lifetime benefits as of 1/1/2011! Thanks for all your efforts on our behalf. And as soon as I receive word from our actuary, I will pass it along to you!!!
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Jane W. Andrews OCIIO 7501 Wisconsin Ave Bethesda, MD 20814 301-492-4122 (desk) 202-536-6779 (Blackberry)
Clare.
September 15 th letter. Unfortunately, when I received the paper binder for application review several weeks ago, the cover letter was not on the binder, and there was nothing in the binder itself to indicate a January 1, 2011 effective date, so I went with the cover page effective date for each plan, which range widely. Again, that is why our original letter indicated approval for October effective dates as those are the only plans I had reviewed. However, as I indicated in our phone call, between your actuarys letter with the percent increases for the varying annual limits for the plans, I dont foresee a problem in approving any of your plans, if they all fall within that range. In fact, I will stay late to review them, so I can confirm with you before the end of your day today. Again, I appreciate the clarification today on the effective date for all of the plans as January 1, 2011. Be back with you soon. Thanks
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Jane Andrews Jane W. Andrews OCIIO 7501 Wisconsin Ave Bethesda, MD 20814 301-492-4122 (desk) 202-536-6779 (Blackberry)
ceinsmann@ual.org
Alexandra Botwinick
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Office of Oversight HHS/OCIIO
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From: Clare Marie Einsmann, Esq. [ceinsmann@ual.org] Sent: Monday, December 13, 2010 3:23 PM To: Andrews, Jane (HHS/OCIIO) Cc: Botwinick, Alexandra (HHS/OCIIO); Habit, Sandra (HHS/OCIIO) Subject: RE: Plans effective date clarification today. Good afternoon, Jane I was reviewing the HHS listing of the Approved Applications for Waiver of the Annual Limits and noticed that the listing still reflects that United Agricultural Benefit Trust (UABT) with a plan effective date of 10.1.2010. If you recall, I had requested and you had approved a change of our plan effective date to 01.01.2011. Your email of October 20th referenced an October 18th email from Alexandra Botwinick wherein UABT was granted the 01.01.2011 change. Is it possible for the next publication of the listing of Approved Applications for Waiver of the Annual Limits to reflect UABTs correct plan effective date? Thank you in advance for your assistance. And best wishes for the holiday season.
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UABT:000066
file:///T|/...ith%20NO%2012600%20Response%20[YELLOW]/UABT/RE%20Plans%20effective%20date%20clarification%20today..htm[08/01/2011 10:55:54 AM]
Dear Jane Attached is the letter from United Agricultural Benefit Trusts ABTs) consulting actuary stating that the anticipated increase for the Tanimura & Antle Mexican Panel Plan will be 4 % if it were required to increase the annual maximum to $750,000. This number is comparatively lower than our othe cost trends because all the medical benefits for this plan are rendered in Mexico where medical costs average 1/3 rd of the costs of those in the Uni States. (So it can be factored that the trend would be significantly greater if applied to U.S. medical rates maybe Ex. 4 %.) The Tanimura & Antle Mexican Panel Plan is a very unique benefit plan design. Their seasonal growing operation is along the California/Ariz nd Mexican border. s a seasonal plan and is active October through May each year. Ex. 4 There are approximately farm laborers and Ex. 4 dependents whose only health benefits are those that they receive from United Agricultural Benefit Trusts contract octor panel in the towns and cities along the border of Mexico. Tanimura & Antles workforce is low income farm laborers. They are documented workers but many of the workers reside in Mexico and cross the border each day to work in the agricultural fields and return to Mexico each evening. Because they are working for a U.S. firm, they are not eligible for the Mexican socialized medical program. The only medical care they could receive if the Tanimura & Antle plan were discontinued would be Medicaid. Despite the fact that benefits are provided in Mexico, the Tanimura & Antle Mexican Plan is a comprehensive major medical benefit plan providing hospital, physician, diagnostic testing, prescription medication, etc. The physicians and hospitals are vetted and excellent quality. And most important, the participants are pleased with their health benefits. The plan is priced at a rate which the Tanimura & Antle can afford rates which enable the employer to provide their employees health benefits at no cost sharing. And the employer knows that these employees cannot afford to share the cost of benefits. And if the employer were to cease providing benefits the employee would not be able to obtain health benefits independently. In discussions with our employer it would appear that Tanimura & Antle may not be able to afford to continue to offer benefits if the cost increases even Ex. 4 %. There is little profit margin in the wholesale production agriculture. It is virtually impossible for an agricul ral producer to increase costs and pass them along to the consumer. If the cost of a head lettuce increases, the consumer will bypass a salad with dinner and opt for broccoli or zucchini. As I have indicated, UABT relied on our notice of September 24, 2010 notice from Steve Larsen, Director of the Office of oversight and notified all of our participating employers, including Tanimura & Antle, that UABT received a waiver of the annual limits for all of its plans, including the Tanimura & Antle plan. I now ask that Tanimura & Antle continue to be included in the waiver granted UABT on September 24th as amended on October 18th . Thank you for your consideration and efforts on our behalf. And if you have any questions, please let me know. Very truly yours,
Clare.
Clare Marie Einsmann, Esq.

UABT:000067
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Executive Vice President United Agribusiness League 54 Corporate Park Irvine, CA 92606.5105 800.223.4590 or 949.975.1424 Fax: 949.975.1573 ceinsmann@ual.org
C lease provide me with the actuarys estimate of what an annual limit of $Ex. 4 would increase rates by? There is a Ex. 4 $ annual limit on the tamura antil plan, but that type of annual limit and percent increase it is not provided on the actuarys letter, and I will need that.
UABT:000068
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Hi Jane Ive d Ben Mulkey, UABTs independent actuary, to get you his opinion on what the rates would increase for the $Ex. 4 Tanimura & Antle benefit plan if it were forced to increase its annual limit to $750,000. I know that he will not be able to get back to you this evening so relax! As for the Teixeira Farms $ Ex. 4 Plan yes it is a $Ex. 4 nual maximum plan! If you look on page B2, you will Ex. 4 see that it specifically refere e Plan Maximum . And again, all the plans will show unlimited lifetime benefits as of 1/1/2011! Thanks for all your efforts on our behalf. And as soon as I receive word from our actuary, I will pass it along to you!!!
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Clare.
September 15 th letter. Unfortunately, when I received the paper binder for application review several weeks ago, the cover letter was not on the binder, and there was nothing in the binder itself to indicate a January 1, 2011 effective date, so I went with the cover page effective date for each plan, which range widely. Again, that is why our original letter indicated approval for October
UABT:000069
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Also, I am not clear on what the Texeira Farms $ Ex. 4 plan means. Is $Ex. 4 the annual limit? Please let me know. Generally, I note that your annual plan maximums are followed by a lifetime limit. As you know lifetime limits are not permitted, so please confirm that the lifetime limit language will not be included in future plan descriptions. I have completed my reviews and once I hear back on the tamura antil and Texiera Farms questions, I should be able to get you a decision on your applications. Thanks. Jane W. Andrews OCIIO 7501 Wisconsin Ave Bethesda, MD 20814 301-492-4122 (desk) 202-536-6779 (Blackberry)
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effective dates as those are the only plans I had reviewed. However, as I indicated in our phone call, between your actuarys letter with the percent increases for the varying annual limits for the plans, I dont foresee a problem in approving any of your plans, if they all fall within that range. In fact, I will stay late to review them, so I can confirm with you before the end of your day today. Again, I appreciate the clarification today on the effective date for all of the plans as January 1, 2011. Be back with you soon. Thanks Jane Andrews Jane W. Andrews OCIIO 7501 Wisconsin Ave Bethesda, MD 20814 301-492-4122 (desk) 202-536-6779 (Blackberry)
UABT:000070
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From: Andrews, Jane (HHS/OCIIO) Sent: Monday, December 13, 2010 3:37 PM To: 'ceinsmann@ual.org' Cc: Botwinick, Alexandra (HHS/OCIIO); Habit, Sandra (HHS/OCIIO); Pham, Erica (HHS/OCIIO) Subject: Re: Plans effective date clarification today.
From: Clare Marie Einsmann, Esq. [mailto:ceinsmann@ual.org] Sent: Monday, December 13, 2010 03:23 PM To: Andrews, Jane (HHS/OCIIO) Cc : Botwinick, Alexandra (HHS/OCIIO); Habit, Sandra (HHS/OCIIO) Subject : RE: Plans effective date clarification today.
Yes - Alex has fixed the spreadsheet. We will ensure that the office that does the posting captures this change. Thanks
Clare we did a review of your e-mail letter below dated 10/19/2010 as well as your actuarys letter and can approve the Tanimura & Antle plan to be included in UABTs waiver approval letter dated October 18, 2010. Therefore, all plans included in your application dated September 15, 2010 are considered to be approved for a waiver of annual limits for a one-year period as indicated in the October 18, 2010 approval letter. Thanks and let me know if you have questions. Jane Jane W. Andrews
UABT:000073
file:///T|/...0Response%20[YELLOW]/UABT/Re%20Plans%20effective%20date%20clarification%20today%2012.13.10..htm[08/01/2011 10:55:55 AM]
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Good afternoon, Jane I was reviewing the HHS listing of the Approved Applications for Waiver of the Annual Limits and noticed that the listing still reflects that United Agricultural Benefit Trust (UABT) with a plan effective date of 10.1.2010. If you recall, I had requested and you had approved a change of our plan effective date to 01.01.2011. Your email of October 20th referenced an October 18th email from Alexandra Botwinick wherein UABT was granted the 01.01.2011 change. Is it possible for the next publication of the listing of Approved Applications for Waiver of the Annual Limits to reflect UABTs correct plan effective date? Thank you in advance for your assistance. And best wishes for the holiday season.
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OCIIO 7501 Wisconsin Ave Bethesda, MD 20814 301-492-4122 (desk) 202-536-6779 (Blackberry)
Dear Jane Attached is the letter from United Agricultural Benefit Trusts (UABTs) consulting actuary stating that the anticipated increase for the Tanimura & Antle Mexican Panel Plan will be Ex. 4 % if it were required to increase the annual maximum to $750,000. This number is comparatively lower than our othe cost trends because all the medical benefits for this plan are rendered in Mexico where medical costs average 1/3 rd of the costs of those in the United States. (So it can be factored that the trend would be significantly greater if applied to U.S. medical rates maybe Ex. 4%.) The Tanimura & Antle Mexican Panel Plan is a very unique benefit plan design. Their seasonal growing operation is along the California/Ariz d Mexican border. It is a seasonal plan and is active October through May each year. There are approximately Ex. 4 farm laborers and Ex. 4 dependents whose only health benefits are those that they receive from United Agricultural fit Trusts contract octor panel in the towns and cities along the border of Mexico. Tanimura & Antles workforce is low income farm laborers. They are documented workers but many of the workers reside in Mexico and cross the border each day to work in the agricultural fields and return to Mexico each evening. Because they are working for a U.S. firm, they are not eligible for the Mexican socialized medical program. The only medical care they could receive if the Tanimura & Antle plan were discontinued would be Medicaid. Despite the fact that benefits are provided in Mexico, the Tanimura & Antle Mexican Plan is a comprehensive major medical benefit plan providing hospital, physician, diagnostic testing, prescription medication, etc. The physicians and hospitals are vetted and excellent quality. And most important, the participants are pleased with their health benefits. The plan is priced at a rate which the Tanimura & Antle can afford rates which enable the employer to provide their employees health benefits at no cost sharing. And the employer knows that these employees cannot afford to share the cost of benefits. And if the employer were to cease providing benefits the employee would not be able to obtain health benefits independently. In discussions with our employer would appear that Tanimura & Antle may not be able to afford to continue to offer benefits if the cost increases even Ex. 4 %. There is little profit margin in the wholesale production agriculture. It is virtually impossible for an agricul ral producer to increase costs and pass them along to the consumer. If the cost of a head lettuce increases, the consumer will bypass a salad with dinner and opt for broccoli or zucchini. As I have indicated, UABT relied on our notice of September 24, 2010 notice from Steve Larsen, Director of the Office of oversight and notified all of our participating employers, including Tanimura & Antle, that UABT received a waiver of the annual limits for all of its plans, including the Tanimura & Antle plan. I now ask that Tanimura & Antle continue to be included in the waiver granted UABT on September 24th as amended on October 18th .
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UABT:000074
Thank you for your consideration and efforts on our behalf. And if you have any questions, please let me know. Very truly yours,
Clare.
Clare.
From: Andrews, Jane (HHS/OCIIO) [mailto:Jane.Andrews@hhs.gov] Sent: Monday, October 18, 2010 3:31 PM
UABT:000075
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Hi Jane Ive d Ben Mulkey, UABTs independent actuary, to get you his opinion on what the rates would increase for the $Ex. 4 Tanimura & Antle benefit plan if it were forced to increase its annual limit to $750,000. I know that he will le to get back to you this evening so relax! As for the Teixeira Farms $Ex. 4 Plan yes it is a $ Ex. 4 nual maximum plan! If you look on page B2, you will Ex. 4 see that it specifically refere e Plan Maximum a And again, all the plans will show unlimited lifetime benefits as of 1/1/2011! Thanks for all your efforts on our behalf. And as soon as I receive word from our actuary, I will pass it along to you!!!
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To: 'Clare Marie Einsmann, Esq.' Cc: Botwinick, Alexandra (HHS/OCIIO) Subject: RE: Plans effective date clarification today. C please provide me with the actuarys estimate of what an annual limit of $Ex. 4 would increase rates by? There is a $Ex. 4 annual limit on the tamura antil plan, but that type of annual limit and percent increase it is not provided on the actuarys letter, and I will need that. Also, I am not clear on what the Texeira Farms $ Ex. 4 plan means. Is $ Ex. 4 the annual limit? Please let me know. Generally, I note that your annual plan maximums are followed by a lifetime limit. As you know lifetime limits are not permitted, so please confirm that the lifetime limit language will not be included in future plan descriptions. I have completed my reviews and once I hear back on the tamura antil and Texiera Farms questions, I should be able to get you a decision on your applications. Thanks. Jane W. Andrews OCIIO 7501 Wisconsin Ave Bethesda, MD 20814 301-492-4122 (desk) 202-536-6779 (Blackberry)
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UABT:000076
Clare thanks for speaking with me this afternoon. I appreciate the clarification around your application effective date. I checked with the person who did the original data intake (unpackaged the paper application) and she had scanned in your September 15 th cover letter, so now I can see the application is for a January 1, 2011 effective date. Therefore, you dont need to send me the
Clare.
ceinsmann@ual.org
From: Botwinick, Alexandra (HHS/OCIIO) [mailto:Alexandra.Botwinick@hhs.gov] Sent: Monday, October 18, 2010 8:52 AM To: 'Clare Marie Einsmann, Esq.'
UABT:000077
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Subject: RE: THIRD REQUEST FOR CONFIRMATION
Clare.
UABT:000078
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From: Clare Marie Einsmann, Esq. [ceinsmann@ual.org] Sent: Monday, December 13, 2010 4:27 PM To: Andrews, Jane (HHS/OCIIO) Cc: Botwinick, Alexandra (HHS/OCIIO); Habit, Sandra (HHS/OCIIO); Pham, Erica (HHS/OCIIO) Subject: RE: Plans effective date clarification today. Thank you very much for your assistance.
Clare.
ceinsmann@ual.org
Yes - Alex has fixed the spreadsheet. We will ensure that the office that does the posting captures this change. Thanks
From: Clare Marie Einsmann, Esq. [mailto:ceinsmann@ual.org] Sent: Monday, December 13, 2010 03:23 PM To: Andrews, Jane (HHS/OCIIO) Cc : Botwinick, Alexandra (HHS/OCIIO); Habit, Sandra (HHS/OCIIO) Subject : RE: Plans effective date clarification today.
Good afternoon, Jane I was reviewing the HHS listing of the Approved Applications for Waiver of the Annual Limits and noticed that the listing still reflects that United Agricultural Benefit Trust (UABT) with a plan effective date of 10.1.2010. If you recall, I had requested and you had approved a change of our plan effective date to 01.01.2011. Your email of October 20th referenced an October 18th email from Alexandra Botwinick wherein UABT was granted the 01.01.2011 change. Is it possible for the next publication of the listing of Approved Applications for Waiver of the Annual Limits to reflect UABTs correct plan effective date? Thank you in advance for your assistance. And best wishes for the holiday season.
Clare.
UABT:000080
file:///T|/...0%20Response%20[YELLOW]/UABT/RE%20Plans%20effective%20date%20clarification%20today%20(3)%2012.13.10..htm[08/01/2011 10:55:56 AM]
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From: Andrews, Jane (HHS/OCIIO) [mailto:Jane.Andrews@hhs.gov] Sent: Monday, December 13, 2010 12:37 PM To: 'ceinsmann@ual.org' Cc: Botwinick, Alexandra (HHS/OCIIO); Habit, Sandra (HHS/OCIIO); Pham, Erica (HHS/OCIIO) Subject: Re: Plans effective date clarification today.
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800.223.4590 or 949.975.1424 Fax: 949.975.1573

ceinsmann@ual.org
From: Andrews, Jane (HHS/OCIIO) [mailto:Jane.Andrews@hhs.gov] Sent: Wednesday, October 20, 2010 1:08 PM To: 'Clare Marie Einsmann, Esq.' Cc: Botwinick, Alexandra (HHS/OCIIO); Habit, Sandra (HHS/OCIIO) Subject: RE: Plans effective date clarification today. Clare we did a review of your e-mail letter below dated 10/19/2010 as well as your actuarys letter and can approve the Tanimura & Antle plan to be included in UABTs waiver approval letter dated October 18, 2010. Therefore, all plans included in your application dated September 15, 2010 are considered to be approved for a waiver of annual limits for a one-year period as indicated in the October 18, 2010 approval letter. Thanks and let me know if you have questions. Jane Jane W. Andrews OCIIO 7501 Wisconsin Ave Bethesda, MD 20814 301-492-4122 (desk) 202-536-6779 (Blackberry)
Dear Jane Attached is the letter from United Agricultural Benefit Trusts ABTs) consulting actuary stating that the anticipated increase for the Tanimura & Antle Mexican Panel Plan will be Ex. 4 % if it were required to increase the annual maximum to $750,000. This number is comparatively lower than our oth cost trends because all the medical benefits for this plan are rendered in Mexico where medical costs average 1/3 rd of the costs of those in the Uni d States. (So it can be factored that the trend would be significantly greater if applied to U.S. medical rates maybe Ex. 4 %.) The Tanimura & Antle Mexican Panel Plan is a very unique benefit plan design. Their seasonal growing operation is along the California/Arizona and Mexican border. It is a seasonal plan and is active October through May each year. There are approximately Ex. 4 farm laborers and Ex. 4 dependents whose only health benefits are those that they receive from United Agricultural it Trusts contracting doctor panel in the towns and cities along the border of Mexico. Tanimura & Antles workforce is low income farm laborers. They are documented workers but many of the workers reside in Mexico and cross the border each day to work in the agricultural fields and return to Mexico each evening. Because they are working for a U.S. firm, they are not eligible for the Mexican socialized medical program. The only medical care they could receive if the Tanimura & Antle plan were discontinued would be Medicaid.
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UABT:000081
Clare.
Hi Jane Ive contacted Ben Mulkey, UABTs independent actuary, to get you his opinion on what the rates would increase for the $Ex. 4 Tanimura & Antle benefit plan if it were forced to increase its annual limit to $750,000. I know that he will le to get back to you this evening so relax!
UABT:000082
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Despite the fact that benefits are provided in Mexico, the Tanimura & Antle Mexican Plan is a comprehensive major medical benefit plan providing hospital, physician, diagnostic testing, prescription medication, etc. The physicians and hospitals are vetted and excellent quality. And most important, the participants are pleased with their health benefits. The plan is priced at a rate which the Tanimura & Antle can afford rates which enable the employer to provide their employees health benefits at no cost sharing. And the employer knows that these employees cannot afford to share the cost of benefits. And if the employer were to cease providing benefits the employee would not be able to obtain health benefits independently. In discussions with our employer it would appear that Tanimura & Antle may not be able to afford to continue to offer benefits if the cost increases even Ex. 4 %. There is little profit margin in the wholesale production agriculture. It is virtually impossible for an agricul ral producer to increase costs and pass them along to the consumer. If the cost of a head lettuce increases, the consumer will bypass a salad with dinner and opt for broccoli or zucchini. As I have indicated, UABT relied on our notice of September 24, 2010 notice from Steve Larsen, Director of the Office of oversight and notified all of our participating employers, including Tanimura & Antle, that UABT received a waiver of the annual limits for all of its plans, including the Tanimura & Antle plan. I now ask that Tanimura & Antle continue to be included in the waiver granted UABT on September 24th as amended on October 18th . Thank you for your consideration and efforts on our behalf. And if you have any questions, please let me know. Very truly yours,
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As for the Teixeira Farms $Ex. 4 Plan yes it is a $ nual maximum plan! If you look on page B2, you will Ex. 4 see that it specifically references the Plan Maximum . And again, all the plans will show unlimited lifetime benefits as of 1/1/2011! Thanks for all your efforts on our behalf. And as soon as I receive word from our actuary, I will pass it along to you!!!
Ex. 4
Clare.
Co m
Can you please provide me with the actuarys estimate of what an annual limit of $ Ex. 4 would increase rates by? There is a $Ex. 4 annual limit on the tamura antil plan, but that type of annual limit and per ease it is not provided on the actuarys l I will need that. Also, I am not clear on what the Texeira Farms $Ex. 4 plan means. Is $ Ex. 4 the annual limit? Please let me know. Generally, I note that your annual plan maximums are followed by a lifetime limit. As you know lifetime limits are not permitted, so please confirm that the lifetime limit language will not be included in future plan descriptions. I have completed my reviews and once I hear back on the tamura antil and Texiera Farms questions, I should be able to get you a decision on your applications. Thanks. Jane W. Andrews OCIIO 7501 Wisconsin Ave Bethesda, MD 20814 301-492-4122 (desk) 202-536-6779 (Blackberry)
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UABT:000083
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UABT:000084
Clare.
ceinsmann@ual.org
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Dear Ms. Botwinick Yes, United Agricultural Benefit Trust did receive our notice of approval. (Im sorry I didnt get this response to you sooner, I was unexpectedly out of the office for a couple of days.)
UABT:000085
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And please be advised that I did originally attempt to respond to the email address provided, however each time that I submitted my response, I received an error message. We would, however, like to request a change in the effective dates of the approval. Our plan year is January 1st. The approval is for October 1st. How should I go about requesting that the plan year be changed on our waiver approval? To whom should this request be sent? Thank you for your assistance in this matter.
Clare.
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Ex. 4 Ex. 4 Ex. 4

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Pages 7 through 10 redacted for the following reasons: ---------------------------Exemption 4

Pages 14 through 18 redacted for the following reasons: ---------------------------Exemption 4

file:///T|/...LOW/Applications%20with%20NO%2012600%20Response%20[YELLOW]/UABT/Acceptance%20Letter%209-24-2010.htm[08/01/2011 10:55:42 AM]

Ms. Pham, Response attached. Regards Neal Wainblat

file:///T|/...%20with%20NO%2012600%20Response%20[YELLOW]/UABT/Additional%20Information%20Requested%2010-5-2010.htm[08/01/2011 10:55:45 AM]

Neal B. Wainblat, Attorney At Law

Employment & LaborLaw Solutions Worldwide

file:///T|/...%20with%20NO%2012600%20Response%20[YELLOW]/UABT/Additional%20Information%20Requested%2010-5-2010.htm[08/01/2011 10:55:45 AM]

file:///T|/...h%20NO%2012600%20Response%20[YELLOW]/UABT/Communication%20regarding%20more%20info%2010-18-2010.htm[08/01/2011 10:55:45 AM]

301-492-4122 (desk) 202-536-6779 (Blackberry)

file:///T|/...h%20NO%2012600%20Response%20[YELLOW]/UABT/Communication%20regarding%20more%20info%2010-18-2010.htm[08/01/2011 10:55:45 AM]

Bethesda, MD 20814 301-492-4122 (desk) 202-536-6779 (Blackberry)

Alexandra Botwinick Office of Oversight HHS/OCIIO

file:///T|/...h%20NO%2012600%20Response%20[YELLOW]/UABT/Communication%20regarding%20more%20info%2010-18-2010.htm[08/01/2011 10:55:45 AM]

Ms. Einsmann, Thank you for your prompt response.

Alexandra Botwinick Office of Oversight HHS/OCIIO

file:///T|/...h%20NO%2012600%20Response%20[YELLOW]/UABT/Communication%20regarding%20more%20info%2010-18-2010.htm[08/01/2011 10:55:45 AM]

file:///T|/...12600%20Response%20[YELLOW]/UABT/Clarification%20of%20change%20in%20effective%20date-approval%20letter.htm[08/01/2011 10:55:46 AM]

Irvine, CA 92606.5105 800.223.4590 or 949.975.1424 Fax: 949.975.1573

Clare Marie Einsmann, Esq. Executive Vice President

Alexandra Botwinick Office of Oversight HHS/OCIIO

Ms. Einsmann, Thank you for your prompt response.

file:///T|/...12600%20Response%20[YELLOW]/UABT/Clarification%20of%20change%20in%20effective%20date-approval%20letter.htm[08/01/2011 10:55:46 AM]

Alexandra Botwinick Office of Oversight HHS/OCIIO

file:///T|/...12600%20Response%20[YELLOW]/UABT/Clarification%20of%20change%20in%20effective%20date-approval%20letter.htm[08/01/2011 10:55:46 AM]

file:///T|/...cations%20with%20NO%2012600%20Response%20[YELLOW]/UABT/Request%20for%20more%20info%2010-18-2010.htm[08/01/2011 10:55:47 AM]

file:///T|/...cations%20with%20NO%2012600%20Response%20[YELLOW]/UABT/Request%20for%20more%20info%2010-18-2010.htm[08/01/2011 10:55:47 AM]

Thank you for your prompt response.

Alexandra Botwinick Office of Oversight HHS/OCIIO

file:///T|/...cations%20with%20NO%2012600%20Response%20[YELLOW]/UABT/Request%20for%20more%20info%2010-18-2010.htm[08/01/2011 10:55:47 AM]

Alexandra Botwinick Office of Oversight HHS/OCIIO

file:///T|/...cations%20with%20NO%2012600%20Response%20[YELLOW]/UABT/Request%20for%20more%20info%2010-18-2010.htm[08/01/2011 10:55:47 AM]

file:///T|/...20with%20NO%2012600%20Response%20[YELLOW]/UABT/Request%20for%20more%20information%2010-18-2010.htm[08/01/2011 10:55:48 AM]

file:///T|/...20with%20NO%2012600%20Response%20[YELLOW]/UABT/Request%20for%20more%20information%2010-18-2010.htm[08/01/2011 10:55:48 AM]

Alexandra Botwinick Office of Oversight HHS/OCIIO

Ms. Einsmann, Thank you for your prompt response.

file:///T|/...20with%20NO%2012600%20Response%20[YELLOW]/UABT/Request%20for%20more%20information%2010-18-2010.htm[08/01/2011 10:55:48 AM]

800.223.4590 or 949.975.1424 Fax: 949.975.1573 ceinsmann@ual.org

Alexandra Botwinick Office of Oversight HHS/OCIIO

file:///T|/...20with%20NO%2012600%20Response%20[YELLOW]/UABT/Request%20for%20more%20information%2010-18-2010.htm[08/01/2011 10:55:48 AM]

file:///T|/...20with%20NO%2012600%20Response%20[YELLOW]/UABT/Updated%20Approval%20Letter%20Sent%2010-18-2010.htm[08/01/2011 10:55:48 AM]

Alexandra Botwinick Office of Oversight HHS/OCIIO

800.223.4590 or 949.975.1424 Fax: 949.975.1573 ceinsmann@ual.org

Alexandra Botwinick Office of Oversight HHS/OCIIO

file:///T|/...20with%20NO%2012600%20Response%20[YELLOW]/UABT/Updated%20Approval%20Letter%20Sent%2010-18-2010.htm[08/01/2011 10:55:48 AM]

Alexandra Botwinick Office of Oversight HHS/OCIIO

file:///T|/...0%20Response%20[YELLOW]/UABT/CONFIRMATION%20of%20receipt%20of%20approval%20letter%2010-18-2010.htm[08/01/2011 10:55:49 AM]

Alexandra Botwinick Office of Oversight HHS/OCIIO

file:///T|/...nse%20[YELLOW]/UABT/Second%20Request%20For%20Confirmation%20of%20Receipt%20of%20Approval%20Letter.htm[08/01/2011 10:55:49 AM]

file:///T|/...th%20NO%2012600%20Response%20[YELLOW]/UABT/RE%20THIRD%20REQUEST%20FOR%20CONFIRMATION.htm[08/01/2011 10:55:50 AM]

Alexandra Botwinick Office of Oversight HHS/OCIIO

800.223.4590 or 949.975.1424 Fax: 949.975.1573 ceinsmann@ual.org

Alexandra Botwinick Office of Oversight HHS/OCIIO

file:///T|/...th%20NO%2012600%20Response%20[YELLOW]/UABT/RE%20THIRD%20REQUEST%20FOR%20CONFIRMATION.htm[08/01/2011 10:55:50 AM]

Alexandra Botwinick Office of Oversight HHS/OCIIO

Ms. Einsmann, Thank you for your prompt response.

Dear Ms. Botwinick -

file:///T|/...sponse%20[YELLOW]/UABT/Confirmation%20of%20Receipt%20of%20Updated%20Approval%20Letter%2010-18-2010.htm[08/01/2011 10:55:50 AM]

Alexandra Botwinick Office of Oversight HHS/OCIIO

file:///T|/...sponse%20[YELLOW]/UABT/Confirmation%20of%20Receipt%20of%20Updated%20Approval%20Letter%2010-18-2010.htm[08/01/2011 10:55:50 AM]