Self-Insurer Sept 2010

September 2010

InSurance MedIa cover

SIIA’s RRG Initiatives

PPaca, HIPaa and Federal BeneFIt MandateS:

A Guide for Compliance

Benefit Solutions Administrative and Partner Services Self Funded Plans

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the Self-Insurer | September 2010 1Benefit Solutions Administrative and Partner Services Self Funded Plans



September 2010 | Volume 27

SIIA OFFICERS

chairman of the Board*Armando Baez, Vice PresidentGlobal Benefits GroupFoothill Ranch, CA

President*Freda Bacon, AdministratorAlabama Self-Insured WC FundBirmingham, AL

vice President operations*Alex Giordano, Executive Vice President /Chief Marketing OfficerStarr Global Accident & HealthGreenwich, CT

vice President Finance/cFo/corporate Secretary*Robert Repke, PresidentGlobal Medical Conexions, Inc.San Francisco, CA

SIIA DIRECTORS

Les Boughner, Executive Vice President & Managing DirectorWillis North American Captive and Consulting PracticeBurlington, VT

James E. Burkholder, President/CEOTPABenefits, Inc. San Antonio, TX

John Jones, PartnerMoulton Bellingham PC Billings, MT

Daniel Lebish, President & CEOHM Insurance GroupPittsburgh, PA

Steven J. Link, Executive Vice PresidentMidwest Employers Casualty CompanyChesterfield, MO

SIIA COMMITTEE CHAIRS

chairman, alternative risk transfer committeeKevin M. Doherty, PartnerBurr & Forman LLP, Nashville, TN

chairman, Government relations committeeJay Ritchie, Senior Vice PresidentHCC Life Insurance Co.Kennesaw, GA

chairwoman, Health care committeeBeata A. Madey, Senior Vice President, UnderwritingHM Insurance GroupPittsburgh, PA

chairman, International committeeLiz Mariner, Executive Vice PresidentRe-Solutions Intermediaries, LLCMinneapolis, MN

chairman, Workers’ compensation committeeChris Mason, Chief Operating OfficerUSATPA, Inc., Syracuse, NY

September 2010 The Self-Insurer (ISSN 10913815) is published monthly by Self-Insurers’ Publishing Corp. (SIPC), PO. Periodical Postage Rates paid at Tustin, California and at additional mailing offices. Postmaster: Send address changes to The Self-Insurer, P.O. Box 1237, Simpsonville, SC 29681

The Self-Insurer is the official publication of the Self-Insurance Institute of America, Inc. (SIIA). Annual dues are $1495. Annual subscription price is $195.50 per year (U.S. and Canada) and $225 per year (other country). Members of SIIA subscribe to The Self-Insurer through their dues. Copyright 2010 by Self-Insurers’ Publishing Corp. All rights reserved. Reproduction in whole or part is prohibited without permission. Statements of fact and opinion made are the responsibility of the authors alone and do not imply an opinion of the part of the officers, directors, or members of SIIA or SIPC.

Publishing Director - James A. KinderManaging Editor - Erica MasseyEditor - Gretchen Grote Design/Graphics - Indexx PrintingContributing Editor - Tom Mather and Mike FergusonDirector of Advertising - Justin MillerAdvertising Sales - Amanda Perry

Editorial and Advertising OfficeP.O. 1237, Simpsonville, SC 29681 • (864) 962-2201

Self-Insurers’ Publishing Corp. Officers (2010)James A. Kinder, CEO/Chairman Erica M. Massey, PresidentLynne Bolduc, Esq. Secretary

2010 Editorial Advisory BoardJohn Hickman, Attorney, Alston & BirdDavid Wilson, Esq., Wilson & Berryhill P.C.Randy Hindman, Deloitte & Touche, LLPArmando Baez, Global Benefits Group

The Self-InsurerP.O. Box 1237, Simpsonville, SC 29681Tele: (704) 781-5328 • Fax: (704) 781-5329 e-mail: [email protected].

The Self-Insurance Institute of America, Inc. (SIIA) is the world’s largest trade association dedicated exclusively to the advancement of the self-insurance industry. Its goal is to improve the quality and efficiency of self-insurance plans through education and to create a general acceptance in the public and business communities of this viable alternative to conventional insurance.

Founded in 1981, SIIA represent the interest of self-funded employers, independent administrators, utilization review companies, managed care companies, underwriting management companies, insurance companies, reinsurers, agents, brokers, CPAs, attorneys, financial institutions, manufacturers, trade associations, retail and service companies, municipalities, and others.

SIIA designs and implements programs and services for the benefit of its members, the industry, and the general public to increase the general level of knowledge about self-insurance plans, achieve greater professionalism in the industry, and enhance the general well-being and mutual interests of its membership.

SIIA achieves its goals and objectives through several means:n International/national conferences and industry forums which provide educational opportunities, with substantial discounts onthe registration fees offered to SIIA members.n Distributed monthly, The Self-Insurer, features useful technicalarticles as well as updates on topical issues of importance to theself-insurance industry.n The Self-Insurance Educational Foundation (SIEF) conductsstatistical research regarding the industry and grants educationalscholarships to promising students whose studies focus on theself-insurance industry.

SIIA enjoys federal representation in our nation’s capital through counsel and staff on key legislative and regulatory issues. SIIA is the only national voice encompassing the whole self-insurance industry.

If your company is involved or interested in self-funding risk for workers’ compensation insurance programs, employee benefit plans, or property and casualty exposures, then it should be a member of the association serving the industry - the Self-Insurance Institute of America, Inc.

REpORTS

4 Minimum Loss Ratio Requirements & Other Things Not to Do Into the Wind

8 From the Bench: Mediation of Stop Loss Cases – Doughnuts as Teachable Moments

12 A Case for Captives

18 PPACA, HIPAA and Federal Health Benefit Mandates: Practical Q & A

24 Mather’s Grapevine

26 ART Gallery: Scared of Obamacare? Here’s One Cure

DEpARTMEnTS

2 President’s Message: Hot Times

28 Chairman’s Report: Sharing 30 Years of Success in Chicago




FEATuRES

6 Insurance Media Cover SIIA’s RRG Initiatives

14 SAS 70 No More: SSAE 16 Brings Convergence & Change

2 www.siia.org | September 2010

The on-line reference link Wikipedia gives one definition of the Dog Days of Summer as “a

time period or event that is very hot or stagnant, or marked by dull lack of progress”. Wikipedia, by the way, was invented by an Alabamian, Jimmy Wales. While it certainly has been hot in most of the country, with record setting temperatures reported almost daily, I see nothing stagnant in our industry, nor do I see a lack of progress in any area.

This summer, all eyes turned to the South, where the oil spill and potential devastation of one of our nation’s most valuable natural resources were in danger. As a frequent visitor to the Gulf Coast region and provider of coverage to many of the employers affected by this disaster, my thanks go to the many volunteers and industry professionals who pitched in to help. The heat was a challenge, but did not deter the many who came to help.

While we have been faced with legislation that overhauls the delivery of health care in the United States, careful attention is being paid to the ultimate regulatory guidelines that most of the self-funding community will be implementing. These regulations are being drafted and discussed on a daily basis, with no clear grasp on the final product. Your organization, SIIA, is unique in that a Washington office and staff are keeping up and providing needed input on these

PreSIdent’S MeSSaGeHot Times

proposals.

As we prepare for the 30th anniversary of SIIA, with its National Conference being held in Chicago October 12-14th, up-to-date information and “hot off the press” news on not only the health care provisions, but all aspects of the self-funded industry will be presented by excellent speakers and industry experts. Also, updates will be given on SIIA’s involvement with the self-insured group fund situations which have made headlines in several states.

“SIIA’s foresight and initiative in reaching out to the international self-funding community has not only been incredibly successful, it has given our membership an additional benefit that no other organization can provide.”

On a very personal note, I had the most endearing and proud moment as a parent to welcome my son home from his recent tour in Iraq. This incredible and emotional experience was shared with me by SIIA’s Executive Vice-President Erica Massey, as she has proved to be not only a visionary of SIIA, but a true friend. The commitment of these men and women who serve our country should give us all strength to rise to any occasion, under any circumstances, even the heat. n

God Bless Our Troops,

Freda Bacon

President of SIIA

Trying to solve today’s healthcare challenges on your own?

Why?

Symetra Stop Loss, fi led as a group Excess Loss policy, and Select Benefi ts group insurance policies are insured by Symetra Life Insurance Company, 777 108th Ave. NE Ste. 1200 Bellevue, WA 98004 and are not available in all states or any U.S. territories. Policies may be subject to limitations and exclusions. Select Benefi ts is not a replacement for major medical insurance or other comprehensive coverage. Symetra® and the Symetra Financial logo are registered service marks of Symetra Life Insurance Company. Reach for great things SM is a service mark of Symetra Life Insurance Company.

H E A L T H C A R E S O L U T I O N S

T H E S Y M E T R A W A Y:

It’s tough out there. Medical plan expenses are going up, mini-meds are in transition and you need

solutions now. Symetra can help. As more employers move towards self funding, our stop loss product

can cap their risk and provide the fl exibility needed to meet new healthcare regulations. And for

employers looking to replace mini-meds, Symetra’s fi xed indemnity group insurance policy, Select

Benefi ts, may be a good alternative. As a pioneer in stop loss with over 30 years of risk management

expertise, we are qualifi ed to help you through these challenging times. Call us at 800-975-3665.

LMC 5585 8/2010

Trying to solve today’s healthcare challenges on your own?

Why?

Symetra Stop Loss, fi led as a group Excess Loss policy, and Select Benefi ts group insurance policies are insured by Symetra Life Insurance Company, 777 108th Ave. NE Ste. 1200 Bellevue, WA 98004 and are not available in all states or any U.S. territories. Policies may be subject to limitations and exclusions. Select Benefi ts is not a replacement for major medical insurance or other comprehensive coverage. Symetra® and the Symetra Financial logo are registered service marks of Symetra Life Insurance Company. Reach for great things SM is a service mark of Symetra Life Insurance Company.

H E A L T H C A R E S O L U T I O N S

T H E S Y M E T R A W A Y:

It’s tough out there. Medical plan expenses are going up, mini-meds are in transition and you need

solutions now. Symetra can help. As more employers move towards self funding, our stop loss product

can cap their risk and provide the fl exibility needed to meet new healthcare regulations. And for

employers looking to replace mini-meds, Symetra’s fi xed indemnity group insurance policy, Select

Benefi ts, may be a good alternative. As a pioneer in stop loss with over 30 years of risk management

expertise, we are qualifi ed to help you through these challenging times. Call us at 800-975-3665.

LMC 5585 8/2010


There is a phrase - I will leave it to your imagination - that many have heard and, several males have experienced;

once. There are just some things that do not work well when facing the wind. For instance, trying to fly a kite in front of you while facing into the wind, holding the underside of an umbrella facing into the wind, and my favorite walking into the wind on Rush Street in Chicago in February without holding on to a rope. There are, however, some things that work well into the wind, like taking off in an airplane. What does this have to do with “Minimum Loss Ratio Requirements?” This seemingly vital piece of the new healthcare reform package may offer immediate relief from public opinion but it will make a mess and embarrass the ones who suggested it.

What is the intent of this section

of the legislation? First, it is a lethal suggestion that all insurance companies are spending less than 85% of the money they take in on paying claims and second, suggests that the federal government is spending at least 85%, or more, of the money they take in on “pure” claims. I would debate this here except for one small detail. The whole argument is stupid. What if you just go ahead and say spend 99% of everything you take in on claims? Does that lower healthcare costs? No. It is what is not being said that should make you mad.

Nowhere in this section of the monolithic, so-called reform bill, or for that matter any section of this bill does the legislation simply suggest that what the 85%, 90%, 99%, or 65% of money being spent on claims, is actually paying for claims that should have been created, or more importantly, that the claims that are being paid are priced correctly to begin with. I worked hard to write that last sentence in the style of the new legislation. In short, setting an arbitrary cap on what any company or government must pay for claims does nothing to lower the cost of healthcare! This has been my argument from day one, whenever that was, that the problem is not financing healthcare alone, but the delivery of, and the control of healthcare utilization. A minimum loss ratio will not create more dollars to spend on claims, it will create rationing.

Here are the facts. A 2008 report by Price, Waterhouse, Coopers, commissioned by America’s Health Plans, found that 87% of all premium dollars collected are being spent on care. The other 13% is not pure profit. This report states that in 2007, three-quarters of the increase in healthcare costs were driven by provider cost increases. Administrative costs - claims processing, consumer and provider support,

& Other Things Not to Do Into the Wind& Other Things Not to Do Into the Wind

MInIMuM loSS ratIo requIreMentS

By Bob Shupe

the Self-Insurer | September 2010 5

and taxes and profits accounted for one tenth of the total increase. This report shows the average profit to be 3%. Fortune Magazine reported last year that insurance company profits averaged 6.2% of revenue, far below other industries. There are numerous items that have to be paid out of that 13% including, in most states, setting aside a required 25% of paid claims as a reserve, in case the client leaves and the company has to pay the run-out of claims incurred before the group left. It includes the administrative cost of disease management programs, staffing, processing, electronic medical

record maintenance, case management, AND a mountain of compliance with GOVERNMENT regulations and taxes. Setting a minimum loss ratio has nothing to do with cutting down on utilization of services, poor life styles,

eating choices, smoking, obesity, misuse of imaging for profit, preventive tests to protect the physician (which they do make money on), and a warehouse full of other cost producing items.

The purpose of this section of the now over 3,000 plus pages of the bill

has but one agenda, cast shame of the insurance industry and push our country toward national healthcare. It is about controlling almost 20% of our GDP. The sad part is that those pushing this current agenda are so

convinced that the American public won’t question their motives that they can get by with it, and get re-elected. I really, really hope they are very wrong. If not, then they can continue doing it into the wind while the country does it up a rope. n

Here are the facts. A 2008 report by price, Waterhouse, Coopers, commissioned by America’s Health plans, found that 87% of all premium dollars collected are

being spent on care. The other 13% is not pure profit.


INSURANCE MEDIA COVER

SIIA’s RRG Initiatives


One of SIIA’s top government relations priorities for 2010 has been to improve

life for risk retention groups – self-insured groups of like businesses or professionals organized under the federal Liability Risk Retention Act (LRRA) to insure against liability claims.

SIIA’s efforts to support RRGs resulted in the successful introduction in the House last March of “The Risk Retention Modernization Act” (HR 4802) that would allow RRGs to write commercial property coverage in addition to liability insurance, and also would establish federal enforcement of the LRRA’s preemption of non-domiciliary state interference with the operation of RRGs.

The latter effort was further strengthened by the directive of Rep. Dennis Moore (D-KS), a sponsor of HR 4802, that the Government Accountability Office shall investigate abuses of RRGs by some state insurance regulators.

SIIA issued a press release on July 23 in support of Rep. Moore’s directive that the GAO study instances where non-domiciliary states attempt to improperly regulate the operation of RRGs through such tactics as “cease and desist” orders, onerous filing requirements, imposition of fees, waiting periods, information requests or other means.

The SIIA release offered comments by Kevin Doherty, chairman of SIIA’s Alternative Risk Transfer Committee. It was widely published in insurance trade publications and websites, and several significant publications interviewed Kevin further in coverage digested as follows:

National Underwriter Online News Services, July 23:

“GAO to Probe State Regulation of

RRGs,” by Caroline McDonald included

these points:

“Hopefully, we’ll start identifying

specific situations to get people to

understand the difficulty RRGs face in

this climate,” Kevin Doherty, who chairs

the Self-Insurance Institute of America’s

Alternative Risk Transfer Committee,

told NU Online News Service.

Mr. Doherty said the RRGs are

fine with complying with “reasonable

regulations.” The problem, however,

is “prohibition against doing what

they were authorized to do by their

domiciliary state.” He said the study

should serve as the basis for a federal

dispute resolution process to prevent

further unlawful abuses by states of

these self-insured groups.

“With enforcement through a dispute resolution process,

risk retention groups can be

confident of their rights under federal

law,” he said in a statement. SIIA said it is hopeful that this independent GAO

study will bolster the case for the need of some sort of dispute

resolution. Business Insurance, August 2:

“Lawmakers seek probe of states’

efforts to regulate RRGs” by Mark A.

Hofmann included these points:

Kevin Doherty, chairman of the

Self-Insurance Institute of America’s

alternative risk committee and a

partner in the Nashville, Tenn., office

of Burr & Forman, stressed that the

(LRRA) law has no enforcement

provisions. The only legal remedy when

an RRG believes a nondomiciliary state

has overstepped its bounds is a federal

lawsuit, which is very expensive, said Mr.

Doherty.

“Most risk retention groups don’t

have the capability to file a federal

lawsuit to enforce their rights,” he said.

Best’s Review, August 2010 issue;

The issue’s cover feature was

headlined: “Rethinking the Regulations

– Proposed federal legislation would

increase the lines of business that

risk retention groups could write.”

This broader article included the

current legislative intent of HR 4802

and included these quotes from the

author’s interview of Kevin Doherty:

“It is very difficult to do liability

(insurance) and not do property

(insurance) because most people who

buy the liability coverage would like

to have the property as well. So what

happens is that people have to cut and

paste different programs around the

RRG to make it work.

“So effectively what happens (in

the case of state interference) is that

RRGs are restricted in their operations

because there is no dispute resolution.”

Alternatives to traditional insurance,

including RRGs, now probably

constitute about half of the business

insurance marketplace, Doherty said.

“When you consider that, you’ve got

to figure people are more and more

familiar with captives and RRGs, and

they are a more-accepted way of doing

business. So I would presume all of that

would lead to grand flexibility for RRGs

and ultimately passage of the proposed

law.” n


To understand and then

explain is much of what

lawyers do. To be effective,

an advocate must first get

it, and then teach it—to a judge, a jury,

a mediator, an arbitrator, and even to

opposing counsel. Indeed, the latter

may be the most important audience a

litigator has. After all, it is the opposing

lawyer who has the ear—and the

trust-- of the decision-maker on the

other side of the dispute. Unless the

case goes all the way through trial and

final appeal, what the opposing lawyer

thinks about her case—as informed

by the efficiently communicated

strengths of yours-- may well dictate

the outcome.

An effective counselor, therefore,

must also be willing to be taught by his

Mediation of Stop Loss Cases: Doughnuts as Teachable Moments

Bench Benchfrom the

By thomas a. croft, esq.

opponent about their case and its merits as she perceives them. When both sides

competently present to one another the best picture of their respective views

of the case, a rational and informed resolution is most often not only possible,

but probable. This yields efficiency and minimization of cost, which, of course, is

beneficial to both sides of the dispute at hand, as well as the court system, and

thus to society at large.

In mediation, these dynamics exist with the interposition of a neutral party. The

teaching and learning that occurs in this context is facilitated by the fact of the

mediator’s independence, and his singular agenda to reach a mutually acceptable

settlement of the case in the time at hand. The often-encountered unwillingness

of a party or its counsel to learn a thing about the weaknesses of their own case,

sometimes resisted with swashbuckling intransigence and bravado, is minimized by

the presence of a mediator, who can “cut-to the chase” in private caucus with each

side. The ability of the mediator to “tell it like it is” to a lawyer’s myopic client is the

great advantage that mediation provides.

Having said all this, I turn to what I really wanted to write about this month,

which is doughnuts.

In the stop loss arena, doughnuts provide, in the current vernacular, “teachable

moments.” This is why it is always a good idea to serve them at mediations of stop

loss cases. Let me wax frivolous, and explain.


Bench

500 Craig Road | Second Floor | Manalapan, New Jersey, 07726Tel: (732) 863-5523

www.maple-tech.com


Like most humans, mediators are not born with an understanding of stop loss. Nor have they likely encountered it previously in their law or mediation practices. At least I’ve never run across one who did at the start of a mediation, although there are probably some out there. It is therefore necessary and desirable to bring things into focus for them using a simple visual aid. Enter the common doughnut:

Stop loss spec claims, like doughnuts (excepting the cream-filled or jelly variety), have holes: These holes represent the amount of the medical claim that must ultimately be borne by the Plan. The size of the hole is the size of the Specific Deductible set forth on the Schedule of the stop loss policy. The doughnuts themselves can be thought of as the stop loss claims to be reimbursed under the policy, i.e., eaten by the carrier and not the Plan. Some doughnuts are small—barely larger than the hole. Others can be quite large. However, no doughnut can be larger than the maximum reimbursement available under the stop loss contract. The part of the doughnut larger than that must be eaten by the Plan. I do not deal here with lifetime maximums, as they are, as a practical matter, destined to go the way of the Dodo because of PPACA (“Pee-Pee Ahh-Cah” to some).

The function of the TPA is to bake the doughnuts and serve them up to the stop loss carrier : The circular symmetry of the doughnuts can be spoiled by certain exclusions and/or limitations in the stop loss contract limiting the reimbursement available beyond the specific deductible (doughnut hole).

The bites out of the doughnuts are taken by claims personnel, enforcing these limitations in the stop loss policy. They are then spit out and returned to the TPA submitting them. A common bite is the one resulting from enforcement of the U&C limitation in the stop loss policy (as opposed to the one, if it exists, in the Plan). Sometimes the bite takes away the whole doughnut, as where the claim is wholly excluded by a policy exclusion. These can get especially messy when expectorated by an MGU or carrier.

Lasers can be explained in terms of special “large reimbursement holes” for claims relating to certain specified individuals identified during underwriting with especially problematic diagnoses.

Then there is the matter of the rotten doughnuts. These are doughnuts sent to the stop loss carrier for which there was no disclosure during underwriting, though

there should have been. Stop loss

carriers won’t eat these, and routinely

send them back to their source after

their unpleasant odor is detected.

Explaining the aggregate feature of

a stop loss contract is an easy matter

once we’ve gone down the doughnut

road. In somewhat oversimplified

terms, an agg. feature is a promise by

the stop loss carrier to eat the excess

amount of doughnut holes left for

the Plan if the bag that holds them

exceeds a certain size (typically 125%

of expected volume), as determined

by the aggregate corridor during

underwriting. Note that the size of

the holes in the agg. bag can vary

from miniscule up to the size of the

Spec. Stop loss carriers do not like to

eat the holes as a general matter, and

therefore they almost never plan on

doing so. They tend to get a bad cases

of indigestion of they do. If there is an

agg. claim, most underwriters and claim

personnel will tell you that something

is amiss, i.e., there is a rotten agg.

somewhere, perhaps in Denmark.

Litigation over stop loss claims is

essentially an ongoing dispute over

who must eat the doughnut served up

by the TPA that the MGU/Carrier has

spit out, or refused to eat because it

was allegedly spoiled—as in the case

of non-disclosure. Nobody wants

to eat the doughnut, but ultimately

somebody must. At mediation, the

spoiled or partially chewed doughnut

is placed on a plate in the middle of

the table between the parties, who

look at it most of the day with disgust

while the lawyers urge the opposite

party to chow down. The mediator’s

role is to explain to both sides why the

doughnut really won’t taste as bad as

they fear. By the end of the day, both

sides usually agree on a division, eat

their share, and then go on with their

lives.

Bon appetit. n

Our Offices

The Taft Companies, LLC901 Dulaney Valley Rd · Suite 610 · Towson, MD 21204

P (877) 587-1763 · F (877) 224-0876

W. A. Taft & Company, (DC) LLC

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W. A. Taft & Company Ltd. (Bermuda)W. A. Taft Insurance Brokers Ltd.

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The Taft Companies provide Alternative Risk Transfer (ART) solutions and captive management services within Bermuda and U.S. captive insurance company

domiciles. It also provides access to the Bermuda market as a licensed Bermuda broker. Its services include captive feasibility studies; formation and management

services through its subsidiary companies, as well as structuring reinsurance designs and placement.

W. A. Taft Insurance Brokers Ltd. is a Bermuda-based licensed broker. As an independent non-aligned entity, Taft provides brokers and captives access to the

most innovative and entrepreneurial insurance market in the world.

Practicing the ART of Imagination®

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www.taftcos.com · 877.587.1763





Our Offices

The Taft Companies, LLC901 Dulaney Valley Rd · Suite 610 · Towson, MD 21204

P (877) 587-1763 · F (877) 224-0876

W. A. Taft & Company, (DC) LLC

W. A. Taft & Company, (MT) LLC

W. A. Taft & Company, (SC) Ltd., LLC

W. A. Taft & Company Ltd. (Bermuda)W. A. Taft Insurance Brokers Ltd.

P (441) 295-8495 · F (441) 292-1196

The Taft Companies provide Alternative Risk Transfer (ART) solutions and captive management services within Bermuda and U.S. captive insurance company

domiciles. It also provides access to the Bermuda market as a licensed Bermuda broker. Its services include captive feasibility studies; formation and management

services through its subsidiary companies, as well as structuring reinsurance designs and placement.

W. A. Taft Insurance Brokers Ltd. is a Bermuda-based licensed broker. As an independent non-aligned entity, Taft provides brokers and captives access to the

most innovative and entrepreneurial insurance market in the world.

Practicing the ART of Imagination®







When talking with prospective captive insurance owners, it’s important to have a list of benefits to mention.

Here are some of the primary reasons people should consider forming a captive insurance company.

Case law provides one of the most common reasons: a company is forced into creating its own captive

because the insurance market no longer provides adequate coverage, or the private market only provides

coverage at prohibitive prices. The plaintiff in Consumer’s Oil owned property in a flood plain but could not find insurance.

The plaintiffs in U.S. v. Weber faced the exact same problem. The plaintiff in Ocean Drilling was an offshore oil company that

could not find adequate insurance for its offshore activities. The plaintiff in Humana was a large nationally known hospital chain

that almost went without insurance because of the cost. In all of the preceding cases, the private market did not provide the

plaintiffs with the coverage they needed; hence, all the companies were forced to create their own captives.

A Case forCAptiVeS

A second reason for creating a

captive is to obtain more control over

the insurance policy. Case law provides

a classic example: in Beech Aircraft the

plaintiff wanted an insurance policy

where the company had more control

over the attorneys during litigation.

The company lost a large tort claim,

which the company felt was caused by

its attorneys, who were appointed by

its insurer. The company went so far as

to try to have its insurance company-

appointed counsel removed during

trial. Beech needed an insurance policy

that gave it far more control over the

attorneys appointed in case of a claim.

This leads to two reasons for forming a

captive insurance company.

A third reason for forming a captive

is cost reduction. For example, in the

second quarter of 2009, the Traveler’s

Insurance Company had selling, general

and administrative expenses of $839

billion. Over the same period, Aetna

had selling, general and administrative

expenses of $1.4 billion. To a certain

extent, each company’s premiums

reflect these costs. Compare that to

a captive that has little selling and

marketing expense because it is dealing

with a limited number of insureds. This

lowers the cost of insurance issued by

the captive.

Fourth, the insured can use its

own loss experience in determining

insurance rates. While underwriters

used to consider each insured’s unique

loss experience, that situation rarely

exists now. If the parent has a good

By F. Hale Stewart


loss profile, the captive can use this in

determining premiums. As a result, the

captive will allow the insured to tailor

the insurance policy to the insured’s

unique loss experience.

Fifth, captives can be used as wealth

transfer vehicles. Here is the general

plan. A company owned by a high net

worth individual establishes a captive.

The captive has written premiums

higher than $350,000 and lower than

$1.2 million. As a result, the captive

is taxed on its taxable investment

income, which is usually lower than

net premiums received. At the same

time, the estate’s beneficiaries are

shareholders of the captive. It is best if

they own the captive through a trust

to protect the shares from future

creditor’s claims. The children receive

the benefit of increased share prices

caused by an increase in the captive’s

overall net worth. However, the captive

is subject to a lower level of taxation

because of the 831(b) exception.

Because of certain tax attributes

of insurance companies (such as

the ability to deduct contributions

to reserves from its gross income),

the captive can act as a wealth

accumulation vehicle.

Sixth, owning a captive gives

the owner direct access to the

reinsurance market. Reinsurers usually

have lower costs of operation and

regulatory barriers, along with lower

administration expenses. This spares

the captive the cost of insurance

mark-ups. However, most reinsurers

are only interested in large premiums,

thereby preventing the smaller captive

from meaningfully participating in the

reinsurance market.

Seventh, a captive can provide

the insureds with a negotiation tool

when dealing with other insurers. The

reasoning is simple: when the insured

has a captive, he is not in dire need

of insurance. Instead, he may be able

take or leave the policy provided by an

independent third party insurer. This

changes the dynamic of a negotiation,

giving the insured more leverage when

dealing with an insurer.

Eighth, a captive can provide stable

pricing. If the insured already has a

good loss history – or if the insured

develops and successfully implements

a comprehensive loss program in

conjunction with forming the captive

– the loss experience can be reflected

in the captive’s premiums. In contrast,

insurance provided by a third party

insurer places the insured at the whims

of similar insureds covered by the

insurer. n

F. Hale Stewart, JD, LLM, CTEP, CAM,

CWM is a tax attorney in Houston,

Texas and who also authored the book

A Practitioner’s Guide to U.S. Captive

Insurance Law, which is available from

IBLS.com. His website is http://www.

captiveinsuranceinfo.com/

WE SAY,

YOU SAY,

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By Rick Scarfino, CPA, CITP, CISA and Josh Ayers, CPA, CITP, CISA

SaS 70 no More: SSAe 16

Brings Convergence &Change

Third-party administrators (TPAs), managing general underwriters (MGUs), electronic claims clearinghouses, and other organizations that provide services directly to the self-insurance industry

have to contend with the ever changing landscape of health care reform and additional regulation like the Health Insurance Portability and Accountability (HIPAA) Act and the Health Information Technology for Economic and Clinical Health (HITECH) Act. Now those organizations must also contend with a significant change in accounting and auditing standards. The American Institute of Certified Public Accountants (AICPA) Auditing Standards Board (ASB) recently released Statement on Standards for Attestation Engagements no. 16, Reporting on Controls at a Service Organization (SSAE 16). SSAE 16 will supersede the requirements and guidance for service auditors that was previously included in Statement on Auditing Standards No. 70, Service Organizations (SAS 70).

SSAE 16 brings U.S.

auditing and attestation standards more in line

with international auditing and attestation standards

but retains much of the guidance that was already

included in SAS 70. There will be a few practical changes to

service auditor procedures, but there are some important changes

service organizations should know when SSAE 16 becomes effective.

Below are a series of frequently asked questions and answers that will help service organizations implement the relevant changes necessary to transition

to SSAE 16.


1. If we have a SAS 70 Type I or II Report, when will we have to transition to the new standard and what happens if we do not?

Answer: The new standard must

be applied to all reports that cover

periods ending on or after June 15,

2011 with early adoption permitted.

If a service organization does not

transition to the new standard, its

clients and its clients’ auditors will

be unable to rely on the report. This

could result in the service organization

incurring unnecessary costs related

to the time and resources needed to

accommodate additional on-site audits

and requests for information by its

clients or its clients’ auditors.

It should be noted that by the time

you read this article your first period

under SSAE 16 may have already

started.

2. Are all of the control objectives and specified controls we have in place for SAS 70 still relevant under SSAE 16?

Answer: Yes. At this point, no

significant changes to control objectives

and specified controls are considered

to be necessary. As a result, the

majority of the testing your auditor

performed prior to SSAE 16 will be

applicable once the new standard is in

place.

3. What are the significant changes we will have to consider in preparing for our transition to SSAE 16?

Answer: Three significant changes

will need to be considered by service

organizations:

• Management’s Assertion

The service organization will

be required to provide the

service auditor with a written

assertion about the fairness of the presentation of the description of controls, the suitability of its design and, in a Type II engagement,

its operating effectiveness. The assertion must either accompany the service auditor’s report or be included in the service organization’s description of controls. Depending on its service auditor, the service organization may be required to have a responsible individual sign the management assertion.

SSAE 16 provides an example management assertion that your service auditor can help you tailor to your service organization.

• Suitability of Criteria

The service organization will be required to use suitable criteria to measure, present and evaluate the management assertion. The new SSAE 16 standard includes the suitable criteria to be used in a Type I or Type II engagement. The service organization should discuss these criteria with its current service auditor.

• Risk Assessment

The service organization will be required to perform a formal or informal risk assessment that

identifies the risks that threaten the achievement of the control objectives and specified controls already established and, if applicable, identifies additional control objectives and specified controls needed to meet the users’ needs. The risk assessment should include the consideration of changes to the description of controls and how the service organization monitors the effectiveness of its control environment.

4. Will there be changes in my service auditor’s procedures under SSAE 16?

Answer: Yes. The service auditor will have to consider additional acceptance and continuance procedures to ensure the service organization has the ability to provide a reasonable basis for its assertion and the service organization has implemented a risk assessment methodology. The service auditor’s application of materiality


in SSAE 16 engagements will now

consider both qualitative (the nature of

observed deviations) and quantitative

(the tolerable rate compared to

the observed rate of deviations)

components. The service auditor’s use

of a service organization’s internal audit

department will also be required to be

disclosed with respect to the reliance

on the specific tests performed

5. My organization outsources certain processes to a sub-service organization. What impact will this relationship have on my report under SSAE 16?

Answer: Under SSAE 16, service

organizations will still have to consider

whether to include (inclusive method)

or exclude (carve-out method)

relevant sub-service organization

control objectives and related controls

in their report. However, choosing the

inclusive method will have a greater

impact on the service organizations

under SSAE 16. When the inclusive

method is used, the requirements of

SSAE 16 that apply to the service

organization will also apply to the

sub-service organization. This means

the sub-service organization will also

have to provide a written assertion

regarding its description of controls

relevant to the service organization and

provide evidence of its effectiveness.

In order to provide the appropriate

evidence of its effectiveness the sub-

service organization would need to

supply its SSAE 16 report or be subject

to additional procedures performed by

the service auditor. As a result, service

organizations will have to consider

whether they will be able to coordinate

and obtain the necessary information

to use the inclusive method.

6. What changes can I expect to see in the service auditors’ opinion letter?

Answer: Many of the changes to

the service auditors’ opinion letter will

relate to the topics covered above.

For example, there will be references

to management’s assertion, there

will be an indication as to whether

the carve-out or inclusive method is

being used with respect to sub-service

organizations, there will be specific

reference to the complementary

user control considerations, and, in

Type II engagements, the opinion will

now express whether the internal

controls were properly designed and

implemented for the entire period,

not just as of the period end date as

previously reported.

7. Are there any plans to publish additional guidance with respect to SSAE 16?

Answer: Yes. Keep in mind that the

AICPA will issue an audit guide that

provides additional guidance and clarity

sometime in late 2010 and possibly

early 2011. As a result, both service

auditors and service organizations will

still have some questions regarding

the implementation and impact of the

changes until this guidance is released

to the public.

8. I am a service organization that feels SAS 70 is not relevant to my organization because the services I provide do not affect a user’s financial statements, yet my clients continue to request one. Is there any relevant guidance for service organizations like data centers, software as a service providers, or electronic claims clearinghouses?

Answer: As mentioned above, the

AICPA is scheduled to release audit

guidance in late 2010 and possibly early

2011, which will address this concern

as well. The expectation is they will

allow service auditors to provide three

different types of Systems of Controls

(SOC) reports. SSAE 16 reports will

be considered SOC 1 reports and

AICPA Trust Services (WebTrust and

SysTrust) reports will be issued as

SOC 3 reports. SOC 2 reports will be

available to service organizations that

do not process transactions that affect

their client’s financial statements but are

concerned with the security, availability,

and/or confidentiality of their client’s

data (e.g. data centers).


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9. Will the new standard provide us with any additional advantages?

Answer: Yes. The new standard

converges U.S. and International auditing

and attestation standards. Depending

on the needs of the users and/or their

auditors, those service organizations

that have been required to provide a

separate report under the International

Standards on Attestation Engagements

(ISAE) 3402 in addition to their SAS

70, may now be able to meet their

reporting obligations with a single SSAE

16 report.

10. The new SSAE 16 standard mentions early adoption as an option for service organizations. Are there benefits to early adopting?

Answer: Those that choose to early

adopt will have more time to assess

and evaluate whether the service

organization has implemented the processes necessary to comply with SSAE 16. There are certainly challenges to be faced in organizations transitioning from SAS 70 to SSAE 16 however, service organizations that choose to early adopt could be perceived as market leaders and their users may consider their control environment to be stronger than their competitors.

You may be thinking about the most important question, what do I do now? The answer is to take charge of the transition process. Ask your service auditor to educate you on the new standard and help you start planning your course of action. Start discussing whether early adoption is appropriate, who in the organization is responsible for the management assertion, and if there are any additional compliance and risk assessment processes that need to be implemented to comply with the new standard. Developing a communication plan for sub-service

organizations, clients, and users will allow

key individuals within those organizations

to know what to expect when your

SSAE 16 report is issued. Gaining an

early understanding of SSAE 16 and

taking charge of the transition process

will help your organization avoid the

stress and disruption of costly mistakes

and missed opportunities associated

with delaying the transition to the new

compliance requirements. n

Rick Scarfino, CPA, CITP, CISA is a Senior

Manager with Stone Carlie & Company,

LLC. Rick can be reach at rscarfino@

stonecarlie.com. Josh Ayers, CPA, CITP, CISA

is a Manger with Stone Carlie & Company,

LLC. Josh can be reached at jayers@

stonecarlie.com. Stone Carlie & Company,

LLC (www.stonecarlie.com) is a full service

accounting firm that specializes in SAS70

engagements for TPAs and other entities

within the insurance industry.


The Departments of Health and Human Services (HHS), Treasury and Labor (collectively the “Agencies”) issued interim final regulations (“Regulations”) on July 14, 2010 regarding the new preventive care coverage requirements set forth in new Public Health Service Act (PHSA) Section 2713, as added by the Patient Protection and Affordable Care Act (PPACA). This rule is effective for plan years beginning on or after

September 23, 2010 and it affects all

plans that are not grandfathered health

plans. The following is an overview of

the Regulations.

Recommended preventive Services

Generally, group health plans that

are not “grandfathered health plans”

must cover, by the applicable effective

date (see “Applicable Effective Date”

below for more detail) and waive all

cost-sharing requirements (See “Cost

Sharing Requirements” below for more

details) for the following “recommended

preventive services”:

• Evidence-based items or services

with an “A” or “B” rating from the

U.S. Preventive Services Task Force

(USPSTF);

PPACA, HIPAA AND FEDERAL HEALTH BENEFIT MANDATES:

practical q aq a&The Patent Protection and Affordable Care Act (PPACA), the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and other federal health benefit mandates (e.g., the Mental Health Parity Act, the Newborns and Mothers Health Protection Act, and the Women’s Health and Cancer Rights Act) dramatically impact the administration of self-insured health plans. This monthly column provides practical answers to administration questions and current guidance on PPACA, HIPAA and other federal benefit mandates.

Attorneys John R. Hickman, Ashley Gillihan and Johann Lee provide the answers in this column. Mr. Hickman is partner in charge of the Health Benefits Practice with Alston & Bird, LLP, an Atlanta, New York, Los Angeles, Charlotte and Washington, D.C. law firm. Mr. Gillihan and Mr. Lee are members of the Health Benefits Practice. Answers are provided as general guidance on the subjects covered in the question and are not provided as legal advice to the questioner’s situation. Any legal issues should be reviewed by your legal counsel to apply the law to the particular facts of your situation. Readers are encouraged to send questions by email to Mr. Hickman at [email protected].

Departments issue Mandatory preventive Care Regulations


• Immunizations for routine use in children, adolescents and adults with a recommendation in effect from the Advisory Committee on Immunization Practices of the Centers for Disease Control and Prevention;

• Evidence-informed preventive care screenings for infants, children and adolescents provided in guidelines supported by the Health Resources and Services Administration (HRSA); and

• Evidence-informed preventive care and screening for women provided in guidelines supported by HRSA and not otherwise addressed by the USPSTF. The Regulations note that HHS is developing these guidelines and expects to issue them no later than August 1, 2011. Recommendations of the USPSTF regarding breast cancer screening, mammography, and prevention issued in or around November 2009 are not considered to be current under the regulations.

The complete list of recommendations and guidelines that must be covered by plans is located at http://www.HealthCare.gov/center/regulations/prevention.html (the “List”) and will be continually updated to reflect both new recommendations and guidelines and revised or removed guidelines. You will find the current list in Appendix A attached to this overview.

Plans are not required to provide coverage (or waive cost-sharing) for any item or service that ceases to be a recommended preventive service, such as if the USPSTF downgrades a recommended preventive service from a rating of “B” to a rating of “C” or “D”. Likewise, plans may provide coverage for items and services in addition to those included in the recommendations and guidelines (and such services may be subject to cost sharing).

nOTE: The Regulations provide that a plan or issuer may use reasonable medical management techniques to determine the frequency, method, treatment, or setting for preventive services, to the extent such specifications are not specifically included in the relevant recommendations or guidelines.

Applicable Effective DateNon-grandfathered plans must

cover the recommended preventive

services beginning with plan years

beginning on or after September 23,

2010. However, for recommendations

or guidelines that went/go into effect

after September 23, 2009, specified

services must be covered for plan

years that begin on or after the date

that is one year after the date the

recommendation or guideline was/is

issued. While the majority of services

currently identified in the List must

be covered within the first plan year

beginning on or after September 23,

2010, several current recommendations

and guidelines went into effect after

September 23, 2009, and therefore,

the coverage requirement is delayed

until one year after the issue date with

respect to those services.

Cost Sharing Requirements Generally, cost sharing for

network providers with respect to

“recommended preventive services” is

prohibited. “Cost sharing” for purposes

of these rules includes deductibles,

co-payments, and coinsurance.

Cost sharing is permitted for any

item or service that ceases to be a

recommended preventive service or

for services or treatments in addition

to those included in the specified

recommendations. In addition, the

Regulations indicate that a plan may

impose cost-sharing requirements for a

treatment not included in the specified

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recommendations even if the treatment

results from a recommended preventive

service. Finally, the regulations clarify

that nothing prevents a plan or

issuer from using reasonable medical

management techniques to determine

the frequency, method, treatment, or

setting for a required preventive care

item or service to the extent not

specified in the recommendation or

guideline

Example: Child A visits an

in-network pediatrician for a

preventive care screening. As

a result of the preventive care

screening, the pediatrician

recommends that Child A

undergo surgery for a heart

disorder. Because the preventive

care screening is a recommended

preventive service, the plan cannot

impose a cost sharing requirement.

However, the plan may impose a

cost sharing requirement for Child

A’s heart surgery, which resulted

from the preventive care screening.

Furthermore, the Regulations clarify

the cost-sharing requirements when

a recommended preventive service is

provided during an office visit:

• Cost sharing with respect to the

office visit is prohibited if...

− the primary purpose of the office

visit is the recommended preventive

service and the recommended

preventive services is NOT billed

separately (or tracked separately as

individual encounter data).

Example: Child B covered

by a group health plan visits an

in-network pediatrician to receive

an annual physical exam that

is a recommended preventive

service. During the office visit,

the child receives additional

items and services that are not

recommended preventive services.

The provider bills the plan for the

office visit. Because the primary

purpose for the office visit was to

provide recommended preventive

services, and the plan was not billed

separately, the plan may not impose

a cost-sharing requirement with

respect to the office visit.

• Cost sharing with respect to the

office visit is permitted if...

− the recommended preventive

service is billed separately from the

office visit (or is tracked separately as

individual encounter data). Although

cost sharing with respect to the

office visit is permitted, cost sharing

with respect to the separately billed/

tracked recommended preventive

service is not permitted.

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Example: Joe, who is covered by a group health plan, visits an in-network health care provider. While visiting the provider, Joe is screened for cholesterol abnormalities with a rating of A or B (i.e. recommended preventive services). The provider bills the plan separately for the office visit and for the laboratory work of the cholesterol screening test. The plan may not impose any cost-sharing requirements with respect to the separately-billed laboratory work of the cholesterol screening test. However, the plan may impose cost-sharing requirements for the office visit since it was billed separately from the recommended preventive service.

− the preventive service is not billed separately (or is not tracked as individual encounter data separately) from an office visit but the primary purpose of the office

visit is not the delivery of such an item or service.

Example: Bob visits his network provider for abdominal pain. During the visit, he has a blood pressure screening that is a recommended preventive service. The provider bills the plan for the office visit (i.e. there is not a separate bill for the blood pressure screening). The plan may impose cost sharing on the office visit because the primary purpose of the office visit was not the delivery of a recommended preventive service.

Impact on network plansThe Regulations clarify that a

network based plan is not required to provide coverage for recommended preventive services delivered by an out-of-network provider and may impose cost-sharing requirements for any such out-of-network services that are offered. n

AppEnDIX ACurrent as of July 16, 2010

Grade A and B Recommendations of the united States preventive Services Task Force: • Screening for abdominal

aortic aneurysm

• Counseling to reduce

alcohol misuse

• Screening for anemia

• Aspirin to prevent CVD: men

• Aspirin to prevent CVD: women

• Screening for bacteriuria

• Screening for blood pressure

• Counseling for BRCA screening

• Screening for breast cancer (mammography)

• Chemoprevention of breast cancer

• Counseling for breast feeding

• Screening for cervical cancer

• Screening for chlamydial infection: non-pregnant women

• Screening for chlamydial infection: pregnant women

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• Screening for cholesterol abnormalities: men 35 and older

• Screening for cholesterol abnormalities: men younger 35

• Screening for cholesterol abnormalities: women 45 and older

• Screening for cholesterol abnormalities: women

younger than 45• Screening for

colorectal cancer• Chemoprevention

of dental caries• Screening for

depression: adults• Screening for depression:

adolescents• Screening for diabetes• Counseling for diet• Supplementation with

folic acid• Screening for gonorrhea:

women• Prophylactic medication

for gonorrhea: newborns• Screening for hearing loss• Screening for

hemoglobinopathies• Screening for hepatitis B• Screening for HIV• Screening for congenital

hypothyrodism• Iron supplementation

in children• Screening and counseling

for obesity: adults• Screening and counseling

for obesity: children• Screening for osteoporosis• Screening for PKU• Screening for Rh

incompatibility: first pregnancy visit

• Screening for Rh incompatibility: 24-28 weeks gestation

• Counseling for STIs• Counseling for tobacco

use: adults• Counseling for tobacco

use: pregnant women• Screening for syphilis: non-pregnant persons• Screening for syphilis: pregnant women• Screening for visual

acuity in children

Recommended Immunizations (compilation of vaccines on all required schedules):• Hepatitis B• Rotavirus• Diphtheria, Tetanus,

Pertussis• Haemophilus influenzae

type b• Pneumococcal• Inactivated Poliovirus• Influenza• Measles, Mumps, Rubella• Varicella• Hepatitis A• Meningococcal• Tetanus, Diphtheria,

Pertussis• Human Papillomavirus• Zoster

Recommendations for preventive pediatric Health Care:• History (Initial/Interval)

• Measurements (Length/Height and Weight; Head Circumference; Weight for Length; Body Mass Index; Blood Pressure)

• Sensory Screening (Vision/Hearing)

• Developmental/ Behavioral Assessment (Developmental Screening; Autism Screening; Developmental Surveillance; Psychosocial/Behavioral Assessment; Alcohol and Drug Use Assessment)

• Physician Examination

• Procedures (Newborn Metabolic/Hemoglobin Screening; Immunization; Hematocrit or Hemoglobin; Lead Screening; Tuberculin Test; Dyslipidemia Screening; STI Screening; Cervical Dysplasia Screening)

• Oral Health

• Anticipatory Guidance

SACHDnC Recommended uniform Screening panel CORE COnDITIOnS:• Propionic academia• Methylmalonic acidemia

(methylmalonyl-CoA mutase)

• Methylmalonic acidemia (cobalamin disorders)

• Isovaleric acidemia• 3-Methylcrotonyl-CoA

carboxylase deficiency• 3-Hydroxy-3-methyglutaric

aciduria• Holocarboxylase synthase

deficiency• ß-Ketothiolase deficiency• Glutaric acidemia type I• Carnitine uptake defect/

carnitine transport defect• Medium-chain acyl-CoA

dehydrogenase deficiency• Very long-chain acyl-CoA

dehydrogenase deficiency• Long-chain L-3 hydroxyacyl-

CoA dehydrogenase deficiency

• Trifunctional protein deficiency

• Argininosuccinic aciduria• Citrullinemia, type I• Maple syrup urine disease• Homocystinuria• Classic phenylketonuria• Tyrosinemia, type I• Primary congenital

hypothyroidism• Congenital adrenal

hyperplasia• S,S disease (Sickle cell anemia)• S, βeta-thalassemia• S,C disease• Biotinidase deficiency• Classic galactosemia• Severe Combined

Immunodeficiences• Cystic fibrosis

• Hearing loss

SACHDnC Recommended uniform Screening panel SECOnDARY COnDITIOnS:• Methylmalonic acidemia

with homocystinuria• Malonic acidemia• Isobutyrylglycinuria• 2-Methylbutyrylglycinuria• 3-Methylglutaconic aciduria• 2-Methyl-3-hydroxybutyric

aciduria• Short-chain acyl-CoA

dehydrogenase deficiency• Medium/short-chain

L-3-hydroxyacl-CoA dehydrogenase deficiency

• Glutaric acidemia type II• Medium-chain ketoacyl-

CoA thiolase deficiency• 2,4 Dienoyl-CoA reductase

deficiency• Carnitine

palmitoyltransferase type I deficiency

• Carnitine palmitoyltransferase type II deficiency

• Carnitine acylcarnitine translocase deficiency

• Argininemia• Citrullinemia, type II• Hypermethioninemia• Benign

hyperphenylalaninemia• Biopterin defect in cofactor

biosynthesis• Biopterin defect in

cofactor regeneration• Tyrosinemia, type II• Tyrosinemia, type III• Various other

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It was a hot summer day in South Carolina. We were flying the Cessna 170 over the football field at Furman University. The plane was operating

perfectly. The pilot was not. My instructor, Joe Kaminski , kept saying “left stab Tom, left stab.” He was trying to teach me how to fly in circles without losing altitude, a very important maneuver to be sure. We were using the football stadium as the circle that we were following around at about 3500 feet in altitude. Eventually I got it right and much to his satisfaction we made a smooth, safe landing at the Greenville/Spartanburg Airport.

Joe was my flight instructor and a darned good one. Many years before, Joe had been licensed as the youngest private pilot in the United States at the age of 15, unheard of in those days. I eventually got my VFR license but never went on beyond that. I truly loved learning to fly. All these years later, with over 2 million commercial air miles accumulated, I still love to fly.

Joe and I became friends as a result of our meeting as fellow employees with the TPA firm of Hewitt Coleman & Associates. He’s gone now, but not forgotten. Dick Hewitt, a great innovator of approaches to self-insurance had started the company primarily to serve one of the most dangerous industries in the country at that time. Logging and lumbering led the list. Dick felt that self-insuring these businesses in the group workers compensation venue could help reduce the costs to the employers while at the same time, with proper safety engineering practices, reduce the terrible losses that had been occurring for decades. The reality was that most writers in the primary market had essentially bailed out of the logging

industry and self-funding the workers compensation coverage in group programs was literally the last option for most firms.

The end result of this was that in the following several years, numerous groups in Georgia, North and South Carolina, Florida, Alabama, Michigan and many other States were formed, most of which remain today either in the Self-Insured Group format or as Captive arrangements. Little did we know at the time that the movement we were starting would grow to the extent that it has across the country.

Dick Hewitt is long gone from this earth today but certainly not forgotten. When I first met him I was in a very comfortable position with the Zurich American Insurance Company as the safety engineering manager for the Mid-West Division. I had no desire to move anywhere. Dick flew into town with Joe Kaminski as his pilot. It took him one expensive dinner and about two hours to talk me into joining his firm, a move that I never regretted. Nearly thirty years later I retired from the business, having

traveled through the back woods and lumber mills across the country with both Hewitt Coleman and eventually with CoreSource and AON. As time went by we moved into similar programs in the foundry business, government agencies such as road commissions, rural electric supply cooperatives, construction companies and a host of other entities.

Self-Insured Workers Compensation groups have been an insurance savior for many industries in this country over the years. They have also resulted in much improved working environments for thousands of workers and a means

for businesses to succeed without the appalling losses previously suffered in these occupations.

Surely it is not over. This market will continue to expand as it has since the beginning. SIIA has always been an integral part of it as the meeting place for participants in such programs and will continue to be into the foreseeable future. I have fond memories of its development and progress. And it gave me the opportunity to do a lot of flying, even if not in the pilot’s seat. n

MatHer’S GraPevIne


26 www.siia.org | July 2010

By dick Goff

Obamacare’s apparent threat of providing unlimited lifetime health benefits to members of employee health plans has become the monster in the closet – you’re afraid to open the door and you’re afraid not to open the door. Stop-loss insurance costs are expected to zoom to the stratosphere, or else

employers will chuck the whole thing and just write a check for the new tax.

The monster wins in either of those scenarios. But Roosevelt was right (maybe about this one thing): There is nothing to fear but fear itself.

Here’s another scenario: Transfer the risks of very large health claims into a captive where catastrophic losses may be expected, and dealt with as they come, from a pool large enough to return some underwriting profit. You can be afraid of the monster or you can tame it to dance a jig at circus sideshows and keep all the quarters it collects as your profit rewarding your intelligence and verve.

Scared of Obamacare? Here’s one Cure

Would that be ART coming to the rescue of employers?

It will take a few words of explanation

to wrap your mind around this concept.

Heck, it’s taken me a couple of years just to

try writing it down.

Let’s start at the beginning with first

principles of self-insurance for an ERISA

employee health plan. Traditionally the plan

sponsor self-insures losses up to a self-

elected retention level, and buys traditional

stop-loss insurance to cover specific and

aggregate losses in excess of the retention.

Self-insurance 101, right?

Now, moving into less familiar territory,

let’s say several self-insured benefit plans

(or 1,000) become members of a pool for

the purposes of their stop-loss coverage.

If a captive insurance company were

to be formed for that purpose, it could

insure each plan’s excess losses over their

retention levels.

All it takes is for someone like an

insurance company, a big MGU or TPA

to start the captive. A few of these

excess coverage captives already exist on

a modest level and you can learn more

about them at SIIA’s national conference in

October. Check sessions in the ART track.

The strength of this kind of ART

structure is that it’s got the law of large

numbers working for it. That law has

nothing to do with tickets for three-digit speeds in a western state where enforcement was supposed to be lax but that’s another kind of large number story. For today’s purpose, the law simply and irrefutably states that the more risk-takers there are in a pool, the less any given risk will cost its members.

Or the captive could be structured in individual incorporated cells to keep everyone’s risks in separate silos up to an actuarially predetermined assumption level prior to buying stop-loss coverage for all but specific named risks that potentially could become catastrophic losses. This would benefit plan sponsors that could actuarially forecast their most expensive risks. And the captive can be counted on for underwriting profit, investment profit and possibly tax advantages for the owner-insureds.

A point to be considered is that by using a captive to insure excess losses, and then buying reinsurance through the captive on a pooled basis to cover catastrophic losses, insureds are pushing traditional commercial involvement in their risk management farther out – or farther up the financial ladder, whichever image you prefer.

This could be called stair-stepping risk attachment levels for specified risks. I predict stair-stepping will replace cherry-picking in the benefits lexicon. Of course

the metaphors are already related as some

harvesters climb ladders to pick cherries.

In this kind of risk attachment level

stair-stepping, a health plan could determine

various attachment points, moving higher

as the risks become increasingly expensive.

Conditions such as certain cancer treatments,

premature babies or organ transplantation

come to mind.

While each cell within the large group

captive could attach its excess loss coverage

at varied levels to cover specific and aggregate

health risks, all cells would participate in a pool

to cover those few truly catastrophic claims.

As an aside, the million dollar claims that

everyone fears are not that common in reality.

I asked an executive of a leading stop-loss

carrier how many he had seen in his career

and he estimated that number would be five.

An ART structure like this would certainly

surmount Obamacare’s scary requirement

of unlimited lifetime benefits for members of

employer benefits plans. The question is: Why

doesn’t everyone do it?

One response resides within that law

of thermodynamics stating that an object

in motion tends to continue in motion. My

corollaries are: A buyer of stop-loss insurance

tends to continue to buy the same product,

and a seller of stop-loss insurance tends to

continue to sell the same product.

But the joker in that deck is the difficulty

of pricing unlimited stop-loss insurance

without creating a captive-reinsurance

structure that can deal with the catastrophic

anomalies.

As I noted earlier, it will take a visionary

service provider with access to a large

number of self-insured benefit plans to make

this work. Do we have any volunteers?

Dick Goff is managing member of The

Taft Companies LLC, a captive insurance

management firm and Bermuda broker at

[email protected]. n

ART Gallery


InSIDER InForMatIon SiiA New MembersREGULAR MEMBERS

Company name/Voting Representative

Josh Holzer, President, American Healthcare Recoveries,

New York, NY

Craig Irvine, Vice President of Sales, BCS Financial Corporation,

Oakbrook Terrace, IL

Reney Clifford, Director Strategic Accounts, Capital District Physicians Health Plan,

Albany, NY

Angelo Nardi, Executive Vice President, Gallagher Benefit Services, Inc.,

Itasca, IL

Daniel Kloiber, National Director of Sales,

MedVantx Pharmacy Services, Sioux Falls, SD

David Angelone, Partner, One Hundred Years,

New York, NY

Peggy Collins, Vice President Group & Claim Svcs., Pekin Life Insurance Co.

Pekin, IL

EMPLOYER MEMBERSCompany name/Voting Representative

Paul Pinckney, CEO, Healthcare Industry Self-Ins

Program of CA, Irvine, CA

Cora Beth Hartfield, Administrator, MS Truck, Food & Fuel SIF,

Jackson, MS

Rebecca Millar, The Mahoney Group,

Casa Grande, AZ

AUL named a Voluntary Sales Growth Leader Indianapolis (Aug. 3, 2010) –The Employee Benefits Division at American United Life Insurance Company® (AUL), a OneAmerica company, has been named a Voluntary Sales Growth Leader by Eastbridge Consulting Group, Inc.

“This year, we congratulate AUL,” said Gil Lowerre, president of Eastbridge Consulting Group. “AUL has experienced double-digit sales growth in the group voluntary insurance market for each of the last three years, and the company’s 2009 growth rate for these products was in excess of 50 percent.”

As group voluntary insurance sales continue to grow industry-wide, AUL’s Employee Benefits division has exceeded the average rate of growth for these products over three consecutive years, according to Eastbridge’s U.S. Worksite Sales Report.

“We’re honored to be recognized for sales growth on the group voluntary insurance side,” said Len Cavallaro vice president of AUL’s Employee Benefits division. “It shows that we’re a stable company and further confirms our position as a leader in the group voluntary insurance market.”

The AUL Employee Benefits Division works with Eastbridge Consulting Group throughout the year by providing information related to practices, processes and marketing. Eastbridge uses the information to create industry-wide surveys that allow AUL to track trends and see where they’re headed in the marketplace.

iNetiCO is excited to announce the addition of Jennifer Gilkison to our Account Services division. Jennifer’s role as Account Services Coordinator will serve as a liaison between the departments of INETICO / INETICARE and our clients, delivering enhanced reporting and valuable resources to help them achieve their goals.

Jennifer comes to INETICO with a Bachelor of Arts degree in English and American Literature from the University of South Florida, 13 years of account management experience with Beech Street, preceded by 7 years experience in group health as Sales Coordinator for Mutual of Omaha and Proposal Writer for Guardian Life.

“We understand the importance of the role that Jennifer will play within the INETICO / INETICARE family, and know that she will bring a highly valued service to our clients. The entire INETICO family is dedicated to building relationships and providing exceptional service and results for our clients and partners.

Jennifer’s role is another example of our commitment to set the standards within the industry for client satisfaction and loyalty.”

INETICO is also proud to have been selected as a finalist for the Tampa Chamber of Commerce 2010 Small Business of the Year Award

We are honored to be recognized along side the other great local companies who have been nominated for this award. Each of these organizations strived to not only create a unique business model and become the employer of choice within the Tampa Bay area, but also to make a positive impact within their industries and communities. Rockport Healthcare Adds 25,000 OptumHealthSM physical Medicine Specialists Network expansion enhances access to workers’ comp medical care providers for Rockport customers

HOUSTON, TX (July 27, 2010) – Rockport Healthcare Group announced it is adding more than 25,000 OptumHealth physical medicine specialists to its workers’ compensation Preferred Provider Organization (PPO) network. The PPO program launched May 1, 2010.

Adding OptumHealth’s nationwide network of care providers to Rockport’s workers’ compensation PPO gives workers enhanced access to best-in-class treatment for their musculoskeletal conditions.

A commitment to understanding local jurisdictions is the hallmark of Rockport’s approach and has helped the company steadily expand in a competitive marketplace. The company’s network currently includes more than 525,000 care providers, making it one of the largest national networks dedicated to workers’ compensation care.

“Our goal is to ensure that we offer our clients access to the best possible array of workers’ compensation providers,” said Mark Neer, Senior Vice President of Network Development at Rockport. “We are continually striving to grow the specialty areas most frequently utilized in workers’ compensation. OptumHealth offers a complete range of specialists along with integrated, personally relevant health guidance and services designed to assist people in their recoveries.”For more information:Company Contact: Media Contact:Doug Markham Brenna Harrington615-221-2625 [email protected] [email protected]


armando Baez

BRCH011 - SIIA Full Page Ad

Self-Insured Employer

456 American Way

Anytown, USA

September 15, 2010

Dear HR Director,

We heard that you implemented a consumer-driven healthcare plan.

How are your employees reacting? Thought so...

We’ve got something you need! At change:healthcare we make consumer-driven

healthcare work for employers and employees.

Our cost transparency solution teaches employees how to get the best price for care.

It works and we have the ROI to prove it.

Look for us at booth 419 at the SIIA National Educational Conference & Expo

October 12-15. Stop by and learn how you make that consumer-driven healthcare

plan a success at your company!

Sincerely,

change:healthcare

www.changehealthcare.com 800.655.0732 ext 4 [email protected]

this October, SIIA’s annual educational conference, themed “Sharing the Success of Self-Insurance” will be held in Chicago. This is the right place for SIIA members to come together on this pivotal year. Chicago is, by population density, airline distances and fares, the center of the U.S. We expect a terrific turnout for our 30th Annual National Educational Conference and Expo.

Your Association continues to take a bold and optimistic stance despite continued government meddling in our healthcare system bordering on repression. The center of the nation is an appropriate place to meet and determine how best to fight this menace.

I remember last year’s conference in Orlando with pride! We were all very anxious as Obama’s healthcare “reform” proposal coupled with an overwhelmingly democrat controlled congress seemed poised to end the best healthcare system in the world.

Some thought then that this threat signaled the death knell of our industry. But I now look back with pride that, through our Association’s work in Washington in coalition with many, many others, we saved – I’m not overstating the result of our combined lobbying efforts – repeat, we saved the employer-based self-insured health care system. The private health care system survives to fight for survival another day.

Sharing 30 years of Success in Chicago

Now we will gather in Chicago and celebrate the continued success of self-insurance and alternative risk transfer. As your Board Chairman for 2010, I invite all our members to join us.

To showcase the real advantages of self-insurance, our conference committee has developed many sessions that highlight successful company self-insured plans into a unique educational effort – kind of live, three-day Harvard Business Review-type of case studies.

This year our conference features more than 100 speakers covering everything about self-insurance and ART from the global to the local. Many of our speakers are true pioneers of our industry and developed self-insured plans covering employee health benefits, workers’ compensation, business or professional liabilities and international risk exposures.

We’ll feature corporations who have come to rely on self-insurance to better manage their risks. Participating are: Intel, Lowe’s, Marriott International, Mayo Clinic, McDonalds, Mohawk Industries and many others.

This year’s conference will also include many of the biggest names in insurance and reinsurance, who will demonstrate how they can be instrumental partners to corporations in managing self-insurance risks: This group includes Chubb, HCC Life, HM Insurance Group, Marsh, Munich Re, Zurich, GBG and others.

We have keynoters scheduled to help us make sense of our self-insurance world: Joe Plumeri, Chairman and CEO of Willis Group Holdings, Inc. will present “The

Changing Nature of Risk,” and Stephen Hayes, highly regarded journalist of The Weekly Standard and Fox News will share his “Election Day Preview.”

We will receive a briefing on the federal Patient Protection and Affordability Act to learn how the current version of healthcare reform will affect self-insured group health plans and how all our organizations must be prepared for a new and very intrusive regulatory environment.

And we will discover how self-insurance and alternative risk transfer leaders are already responding to healthcare reform with innovative financing and administrative structures. Watch for sessions like these:

• The National System Contractors Association leader Chuck Wilson will describe a self-insured ERISA plan now operating in 50 states.

• How 15 school districts in Ohio have banded together in the self-insured Butler Health Plan that provides 20,000 individuals with negotiated prices at hospitals throughout the covered region.

• How TPA Employee Benefits Management Services (EBMS) formed a captive to provide a layer of stop-loss coverage to self-insured clients that cuts costs and returns profits to insured members.

These are but a few highlights to show the depth and scope of our scheduled sessions – our session tracks this year will provide the most intense and valuable educational experiences ever at a SIIA conference.

Our hope is that this vast and varied celebration of self-insurance will inspire

many of our members to greater levels of personal involvement in our business and political issues. We have seen some increase in that regard over the last year or two and we are so grateful to our members who worked so hard last year to defeat the worst elements of ObamaCare. But the fight is not yet over!

My own wish is that individual members will join the Self-Insurance PAC in greater numbers and that company members will raise their SIIA membership category one level up – both examples of taking responsibility for the improved opportunities their companies will enjoy through greater participation in the political process.

Finally, I hope our meeting this year will give our members support in our grassroots efforts to pressure federal and state representatives to improve the political climate for our issues, and to participate in the campaigns of those representatives who will serve our interests. If I’m describing a perfect but elusive world, forgive me. But that world can become possible and the starting point will be in Chicago.

I will be traveling to Chicago from Shanghai where I have been working to help Chinese Companies develop insured and self-insured solutions to an inadequate government health care system.

So, I will be in Chicago in October.

Please join me. Our future is at stake! n

Saludos!

cHaIrMan’S rePort

BRCH011 - SIIA Full Page Ad

Self-Insured Employer

456 American Way

Anytown, USA

September 15, 2010

Dear HR Director,

We heard that you implemented a consumer-driven healthcare plan.

How are your employees reacting? Thought so...

We’ve got something you need! At change:healthcare we make consumer-driven

healthcare work for employers and employees.

Our cost transparency solution teaches employees how to get the best price for care.

It works and we have the ROI to prove it.

Look for us at booth 419 at the SIIA National Educational Conference & Expo

October 12-15. Stop by and learn how you make that consumer-driven healthcare

plan a success at your company!

Sincerely,

change:healthcare

www.changehealthcare.com 800.655.0732 ext 4 [email protected]

Global Excel Management Inc.Toll Free: 877-298-3623 | Tel.: 819-566-1130

www.globalexcelusa.com | [email protected]

COST CONTAINMENT DONE RIGHT

50 01 ADV EUS 0910 SIM

The Great One once said that the key to his success was skating to where the puck was going to be and not to where it’s been.

Global Excel. Maybe it’s time to work with someone focused on the future.

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