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rom: Jim Flynn-HR [[email protected]]
ent: Friday, December 03, 2010 5:34 PM
o: HHS HealthInsurance (HHS)
c: Horrell, James; Ginni Goldsberry-HR
ubject: Waiver
ttachments: Sitel Corp Cornerstone Plan Waiver Request- Dec 2010.pdf
ear Mr. Mayhew:
ttached please find an annual limit waiver request for the Sitel Corporation (EIN 16-1364816), Cornerstone Medical Plan
lease let me know if you have any questions.
ind Regards,
im Flynn. Director, Global Benefits 615.301.7118 office
615.301.7297 [email protected]
itelwo American Center02 West End Avenue, Suite 1000
ashville, TN 37203 USA 877.93LOGIC
ww.sitel.com
*CONFIDENTIAL NOTICE**his e-mail and any files transmitted with it may contain PRIVILEGED or CONFIDENTIAL information and may
ead or used only by the intended recipient. If you are not the intended recipient of the e-mail or any of itsttachments, please be advised that you have received this e-mail in error and that any use, dissemination, distributorwarding, printing, or copying of this e-mail or any attached files is strictly prohibited. If you have received this
mail in error, please immediately purge it and all attachments and notify the sender by reply e-mail.
Sitel:000001
Document obtained by CompleteColorado.com
mailto:[email protected]://www.clientlogic.com/http://www.clientlogic.com/mailto:[email protected]7/27/2019 Sitel Corporation - Redacted Bates HW
2/30
~SfrEL _._
December 3,2010
Department ofHealth and Human ServicesOffice ofConsumer Information and Insurance OversightOffice ofOversightRoom 737-F-04200 Independence Ave. SW, Washington, DC 20201Attention: James MayhewRe: WaiverVia e-mail: [email protected] compliance with the guidance issued on September 3, 2010, from the Health andHuman Services Office ofOversight, we are applying for a waiver of the annual limitrequirement for the Sitel Corporation (BIN 16-1364816), Cornerstone Plan.
1. The Cornerstone plan is offered to our new employees, who are generallylower-paid, in order to provide an affordable benefit for their ftrst two years ofemployment.The plan is affordable primarily because the plan limits total annual benefitsto $The plan is funded through a combination of employee contributions and thegeneral assets of Sitel. The plan is not insured through an insurance companybut instead is self-insured.
2. As of September, 2010, the Cornerstone plan covers approximatelyemployees and members (employees and dependents combined).3. T ent annual limit for health benefits (medical and prescription drug) is$ The total cost of the plan for the current plan year is estimated to be
$ or approximately $ per employee per month. The ratesapplicable to the Cornerstone Plan for the period July I, 2010 through June30,2011, are shown below:Single Employee: $ per mEmployee plus one dependent: $ per monthEmployee plus two or more dependents: $ per month
Sitel:000002
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6jSiTEL 4, Compliance with the interim final regulations would require increasing thecurrent $ annual benefit limit per person to at least $750,000, Ouractuary has estimated that the increase of the annual limit would increase costsby between % and %. Cu l costs for the Cornerstone plan areexpected to be approximately $ The projected increase in costsnoted above would increase annual expenses by $ to $Site)'s current budgetary restrictions would require that we pass most of thisadditional cost to our employees, which we believe would seriously affectwhether the Cornerstone Plan would be affordable.
Our ac tuary's letter is enclosed with this application.5. The Cornerstone Plan was in force prior to September 23,2010 and theincrease in the annual benefit limit to $750,000 will result in a significantdecrease in access to these benefits or a significant increase in the premiumspaid by the individuals covered by the Cornerstone Plan.
I, Jim Flynn, Senior Direct ofGlobal Benefits and Plan Administrator, attest that theCornerstone Plan was in place prior to September 23, 2010, and that that the application ofthe PPACA required limits to the Cornerstone Plan would result in a significant decrease inaccess to benefits for those currently covered by such plans or policies, or a significantincrease in premiums paid by those covered by such plans or policies.
. I J I ~ !:PI'Signed by:
Two American Center, 3102 West End Avenue, Suite 1000 Nashville, Tennessee 37203+1 615.301.7100T I +1615.301.7150F I www.siteLcolTl
Sitel:000003
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Page 4 redacted for the following reason:- - - - - - - - - - - - - - - - - - - - -Exemption 4
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rom: Moultrie, Cam (HHS/OCIIO)ent: Friday, December 17, 2010 10:57 AM
To: [email protected]: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application for Sitel Corp Cornerstone Plan
Dear Mr. Flynn,
hank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act
PHS Act) Section 2711. In order to expedite your application, please provide the following information:
I. Please complete the entire annual limits spreadsheet, [attached to the email available at:http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed spreadsheto this email address as an attachment. We will only be able to process spreadsheets that are fully comp(i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain tyour plan, please write None, and/or provide an explanation regarding why you are unable to completethat particular cell in a separate document.
II. In addition, please provide the following information:
Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?
Confirm whether your plan provides any lifetime limits.
Confirm whether the plan was created pursuant to the Taft-Hartley Act and, if applicable, the effective and
expiration dates of the collective bargaining agreement.
n order to complete your application, please provide this information by 5:00 pm, December 21, 2010. Once thisnformation is received and the application is complete, it will be processed by the Department of Health and Humervices (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 3ays of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decisi
hank you.
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
his information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribut
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
Sitel:000005
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rom: Moultrie, Cam (HHS/OCIIO)ent: Monday, December 20, 2010 5:30 PM
To: Moultrie, Cam (HHS/OCIIO); [email protected]: Habit, Sandra (HHS/OCIIO); [email protected]: RE: Waiver Application for Sitel Corp Cornerstone Plan
reminder that I will need this information by tomorrow, Tuesday December 21 st at 5:00 pm, in order to process your
pplication before the holidays.
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
his information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribut
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
rom: Moultrie, Cam (HHS/OCIIO)ent: Friday, December 17, 2010 10:57 AMo: '[email protected]'c: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application for Sitel Corp Cornerstone Plan
Dear Mr. Flynn,
hank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service ActPHS Act) Section 2711. In order to expedite your application, please provide the following information:
I. Please complete the entire annual limits spreadsheet, [attached to the email available at:http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed spreadsheto this email address as an attachment. We will only be able to process spreadsheets that are fully comp(i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain tyour plan, please write None, and/or provide an explanation regarding why you are unable to completethat particular cell in a separate document.
II. In addition, please provide the following information:
Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?
Confirm whether your plan provides any lifetime limits.
Confirm whether the plan was created pursuant to the Taft-Hartley Act and, if applicable, the effective and
expiration dates of the collective bargaining agreement.
n order to complete your application, please provide this information by 5:00 pm, December 21, 2010. Once this
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nformation is received and the application is complete, it will be processed by the Department of Health and Humervices (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 3ays of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decisi
hank you.
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
his information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribut
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
Sitel:000007
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rom: Jim Flynn-HR [[email protected]]ent: Tuesday, December 21, 2010 5:49 PM
To: Moultrie, Cam (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Sitel Corp Cornerstone Plan
Attachments: Copy of Copy of waiver_application_form sitel.xlsi Cam, per your request, attached please find the completed annual limits spreadsheet to accompany our waiver applicat
s a point of clarification the plan in question does have coinsurance rate of % company/ % employee. I mention thiecause it was not immediately clear which side of the equation was represented on the file.
n addition, please find below the answers to your other questions:
The plan was in existence prior to 3/23/10, but is NOT grandfathered (the OV copay increase on 7/1/10 exceeded the
limit).
The plan DOES have a lifetime limit of $ , but the annual limit is $ and employees can enroll in the pla
only years. As a practical matter, the limit is $ per year.
The plan was NOT created pursuant to the Taft-Hartley Act.
lease let me know if you have any further questions.
egards,
im Flynn. Director, Global Benefits 615.301.7118 office 615.301.7297 fax
itelwo American Center02 West End Avenue, Suite 1000
ashville, TN 37203 USA 877.93LOGIC
ww.sitel.com
rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Friday, December 17, 2010 9:57 AMo: Jim Flynn-HRc: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application for Sitel Corp Cornerstone Plan
Dear Mr. Flynn,
hank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service ActPHS Act) Section 2711. In order to expedite your application, please provide the following information:
I. Please complete the entire annual limits spreadsheet, [attached to the email available at:http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed spreadsheto this email address as an attachment. We will only be able to process spreadsheets that are fully comp(i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain tyour plan, please write None, and/or provide an explanation regarding why you are unable to complete
Sitel:000008
Document obtained by CompleteColorado.com
mailto:[email protected]://www.clientlogic.com/http://www.clientlogic.com/mailto:[email protected]7/27/2019 Sitel Corporation - Redacted Bates HW
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//T|/...ith%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Reqeust%20for%20info%20response%2012.21.10.htm[08/11/2011 3:39
that particular cell in a separate document.
II. In addition, please provide the following information:
Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?
Confirm whether your plan provides any lifetime limits.
Confirm whether the plan was created pursuant to the Taft-Hartley Act and, if applicable, the effective and
expiration dates of the collective bargaining agreement.
n order to complete your application, please provide this information by 5:00 pm, December 21, 2010. Once thisnformation is received and the application is complete, it will be processed by the Department of Health and Humervices (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 3ays of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decisi
hank you.
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
his information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribu
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
*CONFIDENTIAL NOTICE**his e-mail and any files transmitted with it may contain PRIVILEGED or CONFIDENTIAL information and may
ead or used only by the intended recipient. If you are not the intended recipient of the e-mail or any of itsttachments, please be advised that you have received this e-mail in error and that any use, dissemination, distributorwarding, printing, or copying of this e-mail or any attached files is strictly prohibited. If you have received this
mail in error, please immediately purge it and all attachments and notify the sender by reply e-mail.
Sitel:000009
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rom: Jim Flynn-HR [[email protected]]ent: Tuesday, December 21, 2010 9:09 AM
To: Moultrie, Cam (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO); [email protected]: RE: Waiver Application for Sitel Corp Cornerstone Planhank you very much. Im reviewing our responses right now and will have them to you by tomorrow afternoon.
ind Regards,
im Flynn. Director, Global Benefits 615.301.7118 office 615.301.7297 fax
itelwo American Center02 West End Avenue, Suite 1000
ashville, TN 37203 USA 877.93LOGIC
ww.sitel.com
rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Monday, December 20, 2010 4:30 PMo: Moultrie, Cam (HHS/OCIIO); Jim Flynn-HRc: Habit, Sandra (HHS/OCIIO); [email protected]: RE: Waiver Application for Sitel Corp Cornerstone Plan
reminder that I will need this information by tomorrow, Tuesday December 21 st at 5:00 pm, in order to process your
pplication before the holidays.
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
his information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distributcopied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
rom: Moultrie, Cam (HHS/OCIIO)ent: Friday, December 17, 2010 10:57 AMo: '[email protected]'c: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application for Sitel Corp Cornerstone Plan
Dear Mr. Flynn,
hank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service ActSitel:000010
Document obtained by CompleteColorado.com
mailto:[email protected]://www.clientlogic.com/http://www.clientlogic.com/mailto:[email protected]7/27/2019 Sitel Corporation - Redacted Bates HW
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//T|/.../Applications%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Correspondence%2012.21.10.htm[08/11/2011 3:39:
PHS Act) Section 2711. In order to expedite your application, please provide the following information:
I. Please complete the entire annual limits spreadsheet, [attached to the email available at:http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed spreadsheto this email address as an attachment. We will only be able to process spreadsheets that are fully comp(i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain tyour plan, please write None, and/or provide an explanation regarding why you are unable to completethat particular cell in a separate document.
II. In addition, please provide the following information:
Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?
Confirm whether your plan provides any lifetime limits.
Confirm whether the plan was created pursuant to the Taft-Hartley Act and, if applicable, the effective and
expiration dates of the collective bargaining agreement.
n order to complete your application, please provide this information by 5:00 pm, December 21, 2010. Once thisnformation is received and the application is complete, it will be processed by the Department of Health and Humervices (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 3ays of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decisi
hank you.
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
his information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribut
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
*CONFIDENTIAL NOTICE**his e-mail and any files transmitted with it may contain PRIVILEGED or CONFIDENTIAL information and may
ead or used only by the intended recipient. If you are not the intended recipient of the e-mail or any of itsttachments, please be advised that you have received this e-mail in error and that any use, dissemination, distributorwarding, printing, or copying of this e-mail or any attached files is strictly prohibited. If you have received this
mail in error, please immediately purge it and all attachments and notify the sender by reply e-mail.
Sitel:000011
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rom: Moultrie, Cam (HHS/OCIIO)ent: Wednesday, December 22, 2010 10:47 AM
To: Jim Flynn-HRCc: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Sitel Corp Cornerstone Planhank you for the information.
n your application, your plan(s) or policy(ies) provide a lifetime limit. Pursuant to Section 2711 of the PHS Act, y
may not have any lifetime limit on your plan as of September 23, 2010, except in the case of non-essential benefitshat are permitted under Federal or State law. Plans that previously had a lifetime limit may add an annual limit noess than the lifetime limit without affecting the grandfather status of the plan. Please confirm whether this lifetimemit will be eliminated from your plan.
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
his information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribu
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
rom: Jim Flynn-HR [mailto:[email protected]]ent: Tuesday, December 21, 2010 5:49 PM
o: Moultrie, Cam (HHS/OCIIO)c: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Sitel Corp Cornerstone Plan
i Cam, per your request, attached please find the completed annual limits spreadsheet to accompany our waiver applicat
s a point of clarification the plan in question does have coinsurance rate of % company/ % employee. I mention thi
ecause it was not immediately clear which side of the equation was represented on the file.
n addition, please find below the answers to your other questions:
The plan was in existence prior to 3/23/10, but is NOT grandfathered (the OV copay increase on 7/1/10 exceeded the
limit). The plan DOES have a lifetime limit of $ , but the annual limit is $ and employees can enroll in the pla
only years. As a practical matter, the limit is $ per year.
The plan was NOT created pursuant to the Taft-Hartley Act.
lease let me know if you have any further questions.
egards,
im Flynn. Director, Global Benefits
Sitel:000012
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615.301.7118 office 615.301.7297 fax
itelwo American Center02 West End Avenue, Suite 1000
ashville, TN 37203 USA 877.93LOGIC
ww.sitel.com
rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Friday, December 17, 2010 9:57 AMo: Jim Flynn-HRc: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application for Sitel Corp Cornerstone Plan
Dear Mr. Flynn,
hank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act
PHS Act) Section 2711. In order to expedite your application, please provide the following information:
I. Please complete the entire annual limits spreadsheet, [attached to the email available at:http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed spreadsheto this email address as an attachment. We will only be able to process spreadsheets that are fully comp(i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain tyour plan, please write None, and/or provide an explanation regarding why you are unable to completethat particular cell in a separate document.
II. In addition, please provide the following information:
Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?
Confirm whether your plan provides any lifetime limits.
Confirm whether the plan was created pursuant to the Taft-Hartley Act and, if applicable, the effective and
expiration dates of the collective bargaining agreement.
n order to complete your application, please provide this information by 5:00 pm, December 21, 2010. Once thisnformation is received and the application is complete, it will be processed by the Department of Health and Hum
ervices (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 3ays of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decisi
hank you.
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
Sitel:000013
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mailto:[email protected]://www.clientlogic.com/http://www.clientlogic.com/mailto:[email protected]7/27/2019 Sitel Corporation - Redacted Bates HW
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INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
his information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribu
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
*CONFIDENTIAL NOTICE**his e-mail and any files transmitted with it may contain PRIVILEGED or CONFIDENTIAL information and may
ead or used only by the intended recipient. If you are not the intended recipient of the e-mail or any of itsttachments, please be advised that you have received this e-mail in error and that any use, dissemination, distributorwarding, printing, or copying of this e-mail or any attached files is strictly prohibited. If you have received this
mail in error, please immediately purge it and all attachments and notify the sender by reply e-mail.
Sitel:000014
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7/27/2019 Sitel Corporation - Redacted Bates HW
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rom: Jim Flynn-HR [[email protected]]ent: Wednesday, December 22, 2010 11:00 AM
To: Moultrie, Cam (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Sitel Corp Cornerstone Plani Cam, our plan year is from July 1 through June 30. The lifetime limit will be removed as of July 1, which is the beginning
he first plan year following September 23, 2010.
ind Regards,m
rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Wednesday, December 22, 2010 9:47 AMo: Jim Flynn-HRc: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Sitel Corp Cornerstone Plan
hank you for the information.
n your application, your plan(s) or policy(ies) provide a lifetime limit. Pursuant to Section 2711 of the PHS Act, ymay not have any lifetime limit on your plan as of September 23, 2010, except in the case of non-essential benefitshat are permitted under Federal or State law. Plans that previously had a lifetime limit may add an annual limit noess than the lifetime limit without affecting the grandfather status of the plan. Please confirm whether this lifetimemit will be eliminated from your plan.
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) [email protected]
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
his information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribu
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
rom: Jim Flynn-HR [mailto:[email protected]]ent: Tuesday, December 21, 2010 5:49 PMo: Moultrie, Cam (HHS/OCIIO)c: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Sitel Corp Cornerstone Plan
i Cam, per your request, attached please find the completed annual limits spreadsheet to accompany our waiver applicat
s a point of clarification the plan in question does have coinsurance rate of % company/ % employee. I mention thi
ecause it was not immediately clear which side of the equation was represented on the file.
n addition, please find below the answers to your other questions:
Sitel:000015
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The plan was in existence prior to 3/23/10, but is NOT grandfathered (the OV copay increase on 7/1/10 exceeded the
limit).
The plan DOES have a lifetime limit of $ , but the annual limit is $ and employees can enroll in the pla
only years. As a practical matter, the limit is $ per year.
The plan was NOT created pursuant to the Taft-Hartley Act.
lease let me know if you have any further questions.
egards,
im Flynn. Director, Global Benefits 615.301.7118 office 615.301.7297 fax
itelwo American Center02 West End Avenue, Suite 1000
ashville, TN 37203 USA 877.93LOGIC
ww.sitel.com
rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Friday, December 17, 2010 9:57 AMo: Jim Flynn-HRc: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application for Sitel Corp Cornerstone Plan
Dear Mr. Flynn,
hank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service ActPHS Act) Section 2711. In order to expedite your application, please provide the following information:
I. Please complete the entire annual limits spreadsheet, [attached to the email available at:http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed spreadsheto this email address as an attachment. We will only be able to process spreadsheets that are fully comp(i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain tyour plan, please write None, and/or provide an explanation regarding why you are unable to completethat particular cell in a separate document.
II. In addition, please provide the following information:
Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?
Confirm whether your plan provides any lifetime limits.
Confirm whether the plan was created pursuant to the Taft-Hartley Act and, if applicable, the effective and
expiration dates of the collective bargaining agreement.
Sitel:000016
Document obtained by CompleteColorado.com
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//T|/...ith%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Request%20for%20info%20response%2012.22.10.htm[08/11/2011 3:39
n order to complete your application, please provide this information by 5:00 pm, December 21, 2010. Once thisnformation is received and the application is complete, it will be processed by the Department of Health and Humervices (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 3ays of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decisi
hank you.
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
his information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribu
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
*CONFIDENTIAL NOTICE**his e-mail and any files transmitted with it may contain PRIVILEGED or CONFIDENTIAL information and may
ead or used only by the intended recipient. If you are not the intended recipient of the e-mail or any of itsttachments, please be advised that you have received this e-mail in error and that any use, dissemination, distributorwarding, printing, or copying of this e-mail or any attached files is strictly prohibited. If you have received this
mail in error, please immediately purge it and all attachments and notify the sender by reply e-mail.*CONFIDENTIAL NOTICE**his e-mail and any files transmitted with it may contain PRIVILEGED or CONFIDENTIAL information and may
ead or used only by the intended recipient. If you are not the intended recipient of the e-mail or any of its
ttachments, please be advised that you have received this e-mail in error and that any use, dissemination, distributorwarding, printing, or copying of this e-mail or any attached files is strictly prohibited. If you have received this
mail in error, please immediately purge it and all attachments and notify the sender by reply e-mail.
Sitel:000017
Document obtained by CompleteColorado.com
7/27/2019 Sitel Corporation - Redacted Bates HW
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ANNUAL LIMIT WAIVER APPLICATION
Ann ual
Limit Waiver
Request
App licant
Name
Policy Name
(use a new
row for each
policy
application)
App licant
(Plan/ Policy
Situs) City
App licant
(Plan/
Policy
Situs)
State
Plan/ Policy
Effective Date
(mm/dd/yyyy)
Contact
Name
Street
Address City State Zip Code
Phone
Number
(including
area code)
Address
C
(e.
Be
Rx o
Applicant
ABC Plan 1 Washington DC 01/01/2011 J ane Doe
100 ABC
Drive Washington DC 20201
1-800-ABC-
1234
abc@abchea
lthplan.com Lim
Applicant
ABC Plan 1 Washington DC 01/01/2011 J ane Doe
100 ABC
Drive Washington DC 20202
1-800-ABC-
1234
abc@abchea
lthplan.com Lim
Sitel, Inc. ornerstone Pla Nashville TN 07/01/2010 J im Flynn West End Av Nashville TN 37203 -615-301-711 [email protected]
Sitel, Inc. ornerstone Pla Nashville TN 07/01/2010 J im Flynn West End Av Nashville TN 37203 -615-301-711 [email protected]
Sitel Inc ornerstone Pla Nashville TN 07 01 2010 imFl nn West End Av Nashville TN 37203 -615-301-711 fl nn sitelc, . - - - . .
PRA Disclosure Statement
According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless itdisplays a valid OMB control number. The information collection is 0938-1105. The time required to complete this information collection is estimated to average ( 8 hours) or ( 240 minutes) per response, includinsearch existing data resources, gather the data needed, and complete and review the information collection. If you have comments concerning the accuracy of the time improving this form, please write to: CMS, 7500 Security Boulevard, Attn: PRA Reports Clearance Officer, Mail Stop C4-26-05, Baltimore, Maryland 21244-1850.
Document obtained by CompleteColorado.
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ANNUAL LIMIT WAIVER APPLICATION
Ambul ator y Emerg ency Hosp italizatio n Laboratory Pediat ri c
Maternity/
Newborn
Mental Health/
Substance
Abuse
Rehabilitative/
Devices
Preventive/
Wellness
None None None None None None None None None
None None None None None None None None None
None None None None None None None None None
None None None None None None None None None
None None None None None None None None None
Current Essential Benefits Annual Limits (Annual Limit f or Each Essential Benefit)
Document obtained by CompleteColorado.
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ANNUAL LIMIT WAIVER APPLICATION
ndividual/ Employee
Tier*
Employee
contribution
(if applicable)
Employer
contribution
(if applicable) Total
Employee
contribution
(if applicable)
Employer
contribution
(if applicable) Total
Employee
contribution
(if applicable)
Employer
contribution
(if applicable) Total
Employee $100.00 $600.00 $700.00 $110.00 $650.00 $760.00 $125.00 $800.00 $925.00
Employee +Family
Employee
Employee +1
Em lo ee+2
Projected Rate Increase that would result
from c ompliance with $750,000 Annual Limit
Restriction (in dollars) (Average Premium
by Individual)*
Current Monthly Premium Rates or
Premium Equivalent Rates (in dollars)*:
Renewal Monthly Premium Rates or
Premium Equivalent Rates if Waiver Granted
(in dollars)*
* When completing the columns requesting premium rate information, please express the premium rates as a composite rate (ifpremiums are a range based on years of service or age) and by tier (Employee, Employee +Spouse, Employee +Child, Family,etc.) as applicable. If you are an issuer, please provide the premium amount in the column titled, "Total" (Column AN, AQ and AT).
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//T|/...LOW/Applications%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Completion%2012.28.10.htm[08/11/2011 3:39
rom: Moultrie, Cam (HHS/OCIIO)ent: Tuesday, December 28, 2010 10:25 AM
To: Habit, Sandra (HHS/OCIIO)ubject: FW: Waiver Application for Sitel Corp Cornerstone Plan
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services301) 492-4174
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
his information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribu
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
rom: Moultrie, Cam (HHS/OCIIO)ent: Tuesday, December 28, 2010 10:25 AMo: 'Jim Flynn-HR'ubject: RE: Waiver Application for Sitel Corp Cornerstone Plan
hank you for your information. Your application is now complete and you will receive a determination of yourpplication within 30 days.
hank you.
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
his information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribu
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
rom: Jim Flynn-HR [mailto:[email protected]]ent: Wednesday, December 22, 2010 11:00 AMo: Moultrie, Cam (HHS/OCIIO)c: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Sitel Corp Cornerstone Plan
i Cam, our plan year is from July 1 through June 30. The lifetime limit will be removed as of July 1, which is the beginning
Sitel:000021
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//T|/...LOW/Applications%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Completion%2012.28.10.htm[08/11/2011 3:39
he first plan year following September 23, 2010.
ind Regards,
m
rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Wednesday, December 22, 2010 9:47 AM
o: Jim Flynn-HRc: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Sitel Corp Cornerstone Plan
hank you for the information.
n your application, your plan(s) or policy(ies) provide a lifetime limit. Pursuant to Section 2711 of the PHS Act, ymay not have any lifetime limit on your plan as of September 23, 2010, except in the case of non-essential benefitshat are permitted under Federal or State law. Plans that previously had a lifetime limit may add an annual limit noess than the lifetime limit without affecting the grandfather status of the plan. Please confirm whether this lifetimemit will be eliminated from your plan.
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
his information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribu
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
rom: Jim Flynn-HR [mailto:[email protected]]ent: Tuesday, December 21, 2010 5:49 PMo: Moultrie, Cam (HHS/OCIIO)c: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application for Sitel Corp Cornerstone Plan
i Cam, per your request, attached please find the completed annual limits spreadsheet to accompany our waiver applicat
s a point of clarification the plan in question does have coinsurance rate of % company/ % employee. I mention thiecause it was not immediately clear which side of the equation was represented on the file.
n addition, please find below the answers to your other questions:
The plan was in existence prior to 3/23/10, but is NOT grandfathered (the OV copay increase on 7/1/10 exceeded the
limit).
The plan DOES have a lifetime limit of $ the annual limit is $ and employees can enroll in the pla
only years. As a practical matter, the limit is $ per year.
The plan was NOT created pursuant to the Taft-Hartley Act.
Sitel:000022
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lease let me know if you have any further questions.
egards,
im Flynn. Director, Global Benefits 615.301.7118 office 615.301.7297 fax
itelwo American Center02 West End Avenue, Suite 1000
ashville, TN 37203 USA 877.93LOGIC
ww.sitel.com
rom: Moultrie, Cam (HHS/OCIIO) [mailto:[email protected]]ent: Friday, December 17, 2010 9:57 AMo: Jim Flynn-HRc: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application for Sitel Corp Cornerstone Plan
Dear Mr. Flynn,
hank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service ActPHS Act) Section 2711. In order to expedite your application, please provide the following information:
I. Please complete the entire annual limits spreadsheet, [attached to the email available at:http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed spreadshe
to this email address as an attachment. We will only be able to process spreadsheets that are fully comp(i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain tyour plan, please write None, and/or provide an explanation regarding why you are unable to completethat particular cell in a separate document.
II. In addition, please provide the following information:
Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?
Confirm whether your plan provides any lifetime limits.
Confirm whether the plan was created pursuant to the Taft-Hartley Act and, if applicable, the effective and
expiration dates of the collective bargaining agreement.
n order to complete your application, please provide this information by 5:00 pm, December 21, 2010. Once thisnformation is received and the application is complete, it will be processed by the Department of Health and Humervices (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 3ays of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decisi
hank you.
Sitel:000023
Document obtained by CompleteColorado.com
mailto:[email protected]://www.clientlogic.com/http://www.clientlogic.com/mailto:[email protected]7/27/2019 Sitel Corporation - Redacted Bates HW
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//T|/...LOW/Applications%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Completion%2012.28.10.htm[08/11/2011 3:39
am Lynne Moultrie
ffice of Consumer Information and Insurance Oversight
.S. Department of Health and Human Services
301) 492-4174
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
his information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribu
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
*CONFIDENTIAL NOTICE**his e-mail and any files transmitted with it may contain PRIVILEGED or CONFIDENTIAL information and may
ead or used only by the intended recipient. If you are not the intended recipient of the e-mail or any of itsttachments, please be advised that you have received this e-mail in error and that any use, dissemination, distributorwarding, printing, or copying of this e-mail or any attached files is strictly prohibited. If you have received this
mail in error, please immediately purge it and all attachments and notify the sender by reply e-mail.*CONFIDENTIAL NOTICE**his e-mail and any files transmitted with it may contain PRIVILEGED or CONFIDENTIAL information and may
ead or used only by the intended recipient. If you are not the intended recipient of the e-mail or any of itsttachments, please be advised that you have received this e-mail in error and that any use, dissemination, distributorwarding, printing, or copying of this e-mail or any attached files is strictly prohibited. If you have received this
mail in error, please immediately purge it and all attachments and notify the sender by reply e-mail.
Sitel:000024
Document obtained by CompleteColorado.com
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rom: Habit, Sandra (HHS/OCIIO)ent: Thursday, December 30, 2010 3:50 PM
To: '[email protected]'ubject: Sitel, Inc. Approval Letter for a Waiver of the Annual Limits Requirements 12-30-2010
mportance: High
Attachments: Updated Jan 1 Approval Letter .pdf
ood Afternoon,
hank you for submitting an application for a Waiver of the Annual Limits Requirements of the PHS Act
ection 2711 for Sitel, Inc. HHS has reviewed your application and made its determination. Please see the
ttached letter.
lease confirm receipt of this letter by replying to this e-mail.
lease let me know if I can be of further assistance.
incerely
andy Habit
epartment of Health and Human Services
ffice of Consumer Information and Insurance Oversight
01-492-4175
NFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW: This information has not been publiclysclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribu
r copied to persons not authorized to receive the information. Unauthorized disclosures may result in prosecution to the full e
f the law.
Sitel:000025
Document obtained by CompleteColorado.com
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Sitel:000026
Document obtained by CompleteColorado.com
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Sitel:000027
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rom: Jim Flynn-HR [[email protected]]ent: Monday, January 03, 2011 10:13 AM
To: Habit, Sandra (HHS/OCIIO)ubject: RE: Sitel, Inc. Approval Letter for a Waiver of the Annual Limits Requirements 12-30-2010
Ms Habit:
hank you for your approval. I noticed in the approval letter the effective date of this waiver is January 1, 2011 to January
012. Our actual policy year is July 1, 2011 to July 1, 2012. My understanding is the annual limits requirement is effective
he first policy year beginning on or after September 23, 2010. Will this waiver apply to our entire policy year beginning ouly 1, 2011?
ind Regards,
im Flynn. Director, Global Benefits 615.301.7118 office 615.301.7297 fax
itelwo American Center02 West End Avenue, Suite 1000
ashville, TN 37203 USA 877.93LOGIC
ww.sitel.com
rom: Habit, Sandra (HHS/OCIIO) [mailto:[email protected]]ent: Thursday, December 30, 2010 2:50 PMo: Jim Flynn-HRubject: Sitel, Inc. Approval Letter for a Waiver of the Annual Limits Requirements 12-30-2010
mportance: High
ood Afternoon,
hank you for submitting an application for a Waiver of the Annual Limits Requirements of the PHS Act
ection 2711 for Sitel, Inc. HHS has reviewed your application and made its determination. Please see the
ttached letter.
lease confirm receipt of this letter by replying to this e-mail.
lease let me know if I can be of further assistance.
incerely
andy Habit
epartment of Health and Human Services
ffice of Consumer Information and Insurance Oversight
01-492-4175
Sitel:000028
Document obtained by CompleteColorado.com
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rom: Habit, Sandra (HHS/OCIIO)ent: Monday, January 03, 2011 4:03 PM
To: 'Jim Flynn-HR'ubject: RE: Sitel, Inc. Approval Letter for a Waiver of the Annual Limits Requirements 12-30-2010
Attachments: July 1 .pdfMr. Flynn,
My apologies. I have attached the July 1, 2011 approval letter. Please let me know if I can be of any further assistance.
hank you,
andy
rom: Jim Flynn-HR [mailto:[email protected]]ent: Monday, January 03, 2011 10:13 AMo: Habit, Sandra (HHS/OCIIO)ubject: RE: Sitel, Inc. Approval Letter for a Waiver of the Annual Limits Requirements 12-30-2010
Ms Habit:
hank you for your approval. I noticed in the approval letter the effective date of this waiver is January 1, 2011 to January012. Our actual policy year is July 1, 2011 to July 1, 2012. My understanding is the annual limits requirement is effective
he first policy year beginning on or after September 23, 2010. Will this waiver apply to our entire policy year beginning o
uly 1, 2011?
ind Regards,
im Flynn. Director, Global Benefits 615.301.7118 office 615.301.7297 fax
itelwo American Center02 West End Avenue, Suite 1000
ashville, TN 37203 USA 877.93LOGIC
ww.sitel.com
rom: Habit, Sandra (HHS/OCIIO) [mailto:[email protected]]ent: Thursday, December 30, 2010 2:50 PM
o: Jim Flynn-HRubject: Sitel, Inc. Approval Letter for a Waiver of the Annual Limits Requirements 12-30-2010mportance: High
ood Afternoon,
hank you for submitting an application for a Waiver of the Annual Limits Requirements of the PHS Act
ection 2711 for Sitel, Inc. HHS has reviewed your application and made its determination. Please see the
ttached letter.
Sitel:000029
Document obtained by CompleteColorado.com
mailto:[email protected]://www.clientlogic.com/http://www.clientlogic.com/mailto:[email protected]7/27/2019 Sitel Corporation - Redacted Bates HW
30/30
lease confirm receipt of this letter by replying to this e-mail.
lease let me know if I can be of further assistance.
incerely
andy Habit
epartment of Health and Human Services
ffice of Consumer Information and Insurance Oversight
01-492-4175
NFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW: This information has not been publicly
sclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distribu
r copied to persons not authorized to receive the information. Unauthorized disclosures may result in prosecution to the full e
f the law.
*CONFIDENTIAL NOTICE**his e-mail and any files transmitted with it may contain PRIVILEGED or CONFIDENTIAL information and may
ead or used only by the intended recipient. If you are not the intended recipient of the e-mail or any of itsttachments, please be advised that you have received this e-mail in error and that any use, dissemination, distributorwarding, printing, or copying of this e-mail or any attached files is strictly prohibited. If you have received this
mail in error, please immediately purge it and all attachments and notify the sender by reply e-mail.
Document obtained by CompleteColorado.com
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