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  • 7/30/2019 Assurant Redacted HW

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    Assurant Health markets products underwritten by Time Insurance Company, Union Security Insurance

    September29,

    2010

    JamesMayhew

    HealthandHumanServices

    OfficeofConsumerInformationandInsurance

    OfficeofOversight

    Room737F04

    200IndependenceAve.SW

    WashingtonD.C. 20201

    Re:Waiver

    of

    Application

    of

    Time

    Insurance

    Company

    and

    John

    Alden

    Life

    Insurance

    CompanysKeyMedandAssurantAffordableHealthAccessA,BandCProductsDearMr.Mayhew,

    501WestMichigan

    P.O.Box3050

    Milwaukee,WI 532013050

    T800.800.1212

    www.assurant.com

    Beginningin2008,webegansellingthelimitedbenefitplanstitledAssurantAffordableHealth

    Access. In2007,webegansellingKeyMed. Theseplansprovidebenefitsforeverydaymedical

    expensessuchasofficevisitsandprescriptiondrugs. Theseplansincludesomeoutpatientand

    hospitalizationcoverage. Weseekawaiveroftheapplicationoftheimpositionoftherestricted

    annuallimitsportionofPPACA. Therequestsaresetforthbelow:

    HealthAccess

    A

    1. BenefitsunderHealthAccessA,whichisissuedwithnomedicalunderwriting 4officevisitsperyearatamaximumof visitforatotalofmaximumof

    peryearforofficevisits

    maximumperyearforprescriptiondrugs peryearforoutpatientxrayandlaboratoryservices peryearforsurgicalservices

    2. Therearecurrently planswitheffectivedatesafter3/23/2010,whosenextplanyearbegins1/1/2011. WestoppedsellingthisplanonJune15,2010.

    3. Theannuallimitsweseektomaintainarelistedabove. Thepremiumratesforthisproductvarybyage milycomposition. Aratechartisattached. Forexample,

    a

    single

    person

    aged

    would

    pay

    in

    the

    monthly

    premium.

    For

    a

    husband

    (age andwife children,themonthlypremiumis4. Compliancewiththeremovaloftheannualmaximumswouldresultinasignificant

    increaseinpremiumspaidbyourinsureds. Theinc inpremiumnecessarytoaccountforremovalofjusttheannualmaximumsis Theadditio hewellnessbenefitsf productwillresultinapremiumincreaseof foranoverallincreaseof

    Company and John Alden Life Insurance Company.

    ASSURANT:000001

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    Page 2

    5. AttestationofChiefExecutiveOfficerisattached.HealthAccessB

    1. BenefitsunderHealthAccessB officevisitsperyearatamaximumof$ /visitforatotalofmaximumof$

    peryearforofficevisits

    peryearforprescriptiondrugs peryearforoutpatientservices

    2

    emergency

    room

    visits

    per

    year

    at

    a

    maximum

    of

    /year

    for

    a

    total

    annual

    maximumof ground, airambulancefor2tripsperyearforatotalannual

    maximumof ground, air Upto dayforsickness, /dayforinjuryduetoinpatienthospitalization,

    toamaximumof peryear

    Surgicalservicespaidperaschedule, limitedto peryear2. Therearecurrently planswitheffectivedatesafter3/23/2010,whosenext

    planyearbegins1/1/2011. WestoppedsellingthisplanSeptember15,2010.

    3. Theannuallimitsweseektomaintainarelistedabove. Thepremiumratesforthisproductvarybyageandfamilycomposition. Aratechartisattached. For

    example,asinglepe aged ,wouldpay inthemonthlypremium.usband

    (age

    )and

    wife

    with children,themonthlypremiumis

    .

    4. Compliancewiththeremovaloftheannualmaximumswouldresultinasignificantincreaseinpremiumspaidbyourinsureds. Theincreaseinpremium

    necessarytoaccountforremovalofjusttheannualmaximumsis The

    additionof ellnessbenefitsforthisproductwillresultinapremiumincreaseof ,foranoverallincreaseof .

    5. AttestationofChiefExecutiveOfficerisattached.HealthAccessC

    1. BenefitsunderHealthAccessC

    4officevisitsperyearatamaximumof /visitforatotalofmaximumofperyearforofficevisits

    peryearforprescriptiondrugs peryearforoutpatientservices emergencyroomvisitsperyearatamaximumof /yearforatotalannual

    maximumof

    ASSURANT:000002

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    Page 3

    ground, /airambulancefor tripsperyearforatotalannualmaximumof ground, air

    Upto /dayforsickness, /dayforinjuryduetoinpatienthospitalization,toamaximumof peryear

    Surgicalservicespaidperaschedule, limitedto peryear2. Therearecurrently planswitheffectivedatesafter3/23/2010,whosenextplan

    yearbegins1/1/2011. WestoppedsellingthisplanSeptember15,2010.

    3. Theannuallimitsweseektomaintainarelistedabove. Thepremiumratesforthisproduct

    vary

    by

    age

    and

    family

    composition.

    A

    rate

    chart

    is

    attached.

    For

    example,

    asinglepersonaged wouldpay inthemonthlypremium. Fora

    husband(age andwifewith children,themonthlypremiumis .4. Compliancewiththeremovaloftheannualmaximumswouldresultinasignificant

    increaseinpremiumspaidbyourinsureds. Theincreaseinpremiumnecessaryto

    accountforremovalofjusttheannualmaximumsis . Theaddit fthewellnessbenefitsforthisproductwillresultinapremiumincreaseof ,foran

    overallincreaseof .

    5. AttestationofChiefExecutiveOfficerisattached.KeyMed

    1. BenefitsunderKeyMedThose

    with

    annual

    maximums:

    officevisitsperyearatamaximumof peryearforofficevisits peryearforprescriptiondrugs peryearforoutpatientservices emergencyroomvisitsperyearatamaximumof$ /yearforatotalannual

    maximumof

    ground, /airambulancefor tripsperyearforatotalannualmaximumof ground, air

    Thosewithnoannualmaximums:

    Surgicalservicespai dule,witha perconditionmaximum sickness, injuryperinpatienthospitalizationday,uptoa

    maximumper

    condition

    2. Therearecurrently planswitheffectivedatesafter3/23/2010,whosenextplanyearbegins1/1/2011. WestoppedsellingthisplanJune15,2010.

    3. Theannuallimitsweseektomaintainarelistedabove. Thepremiumratesforthisproductvarybyageandfamilycomposition. Aratechartisattached. Forexample,

    asinglemaleaged whopurchasedthemostpopularplanwouldpay in

    ASSURANT:000003

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    themonthlypremium. Forahusband(age )andwifewith children,the

    monthlypremiumforthatplanis

    4. Compliancewiththeremovaloftheannualmaximumswouldresultinasignificantincreaseinpremiumspaidbyourinsureds. Theinc npremiumnecessarytoaccountforremovalofjusttheannualmaximumsis Theadditionofthewellnessbenefitsf productwillresultinapremiumincreaseof foranoverallincreaseof

    5. AttestationofChiefExecutiveOfficerisattached.Werespectfullyrequestthatawaiverbegrantedassetforthabove. Pleasecontactmeifyou

    havequestionsorrequireadditionalinformation. Thankyouforyourconsideration.

    Sincerely,

    JuliaM.Hix

    VicePresident,RegulatoryCompliance

    AssurantHealthComplianceOfficer

    [email protected]

    (T)(414)2997830

    (F)(414)2996168

    ASSURANT:000004

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    ASSURANT:000005

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    Pages 6 through 7 redacted for the following reasons:- - - - - - - - - - - - - - - - - - - - - - - - - - - -Exemtion (b)(6)

    ASSURANT:000006

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    ///co-adshare/...20Force/CCIIO%20Waivers%20-%20Torres/DFOI%20Processing%20Team/Desiree/Assurant%20Health/Waiver.htm[11/02/2011 10:35

    rom: [email protected]: Wednesday, September 29, 2010 4:45 PM

    To: HHS HealthInsurance (HHS)Cc: [email protected]; [email protected]; [email protected]: Waiver

    Attachments: Waiver Application - Time Insurance Company and John Alden Life Insurance Company.pdflease find the attached letter for waiver of application of the restricted annual limit requirements which includes exhibit

    ttachments, including the required attestation.

    hank you,

    licia Blake

    enior Contract Compliance Analyst

    ssurant Health

    egal Department

    414.299.8713

    414.299.6168 This e-mail message and all attachments transmitted with it may contain legally privileged and/oronfidential information intended solely for the use of the addressee(s). If the reader of this message is not thentended recipient, you are hereby notified that any reading, dissemination, distribution, copying, forwarding or othse of this message or its attachments is strictly prohibited. If you have received this message in error, please notifyhe sender immediately and delete this message and all copies and backups thereof. Thank you.

    ASSURANT:000007

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    ///co-adshare/...ers%20-%20Torres/DFOI%20Processing%20Team/Desiree/Assurant%20Health/Additional%20Info%2010.19.10.htm[11/02/2011 10:35

    rom: Andrews, Jane (HHS/OCIIO)ent: Tuesday, October 19, 2010 11:25 AM

    To: '[email protected]'Cc: Habit, Sandra (HHS/OCIIO)

    ubject: Regarding Assurant's application for annual limit waiversMs. Hix: I am currently reviewing your application for annual limit waivers for your four products. I have several questions:

    looks as if these are fully insured products for groups, is that correct? If this is not correct, please let me know what market

    hese policies are for, e.g. individual market.

    lso, it looks as if the effective dates for all products is 1/1/11. Is that correct?inally, woul u to give us the premiums that underlie the percent increases? For example, you have notedercents like etc, but can you tell us what current premium that is based on and future premium amount if

    ad to compl annual limit? Is that an average premium across all age and genders?hanks and feel free to contact me with questions.

    ane W. Andrews

    CIIO

    501 Wisconsin Ave

    ethesda, MD 20814

    01-492-4122 (desk)

    02-536-6779 (Blackberry)

    INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:

    This information has not been publicly disclosed and may be privileged and confidential. It is for internal governmuse only and must not be disseminated, distributed, or copied to persons not authorized to receive the informatio

    Unauthorized disclosure may result in prosecution to the full extent of the law.

    ASSURANT:000008

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    ///co-adshare/...20Torres/DFOI%20Processing%20Team/Desiree/Assurant%20Health/Additional%20Info%20Resp%2010.19.10.htm[11/02/2011 10:35:4

    rom: [email protected]: Tuesday, October 19, 2010 12:34 PM

    To: Andrews, Jane (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO)

    ubject: Re: Regarding Assurant's application for annual limit waiversane and Sandra,

    will have a response back to you shortly. Julie

    ulia Hix-Royer

    ice President Assurant Regulatory Compliance

    nd Assurant Health Compliance Officer

    01 West Michigan

    Milwaukee, WI 53201-3050

    4142997830

    4142996168

    f you want to be really good at something, its going to involve relentlessly pushing past your comfort zone, along with frustrati

    truggle, setbacks and failures."-Tony Schwartz -

    om: "Andrews, Jane (HHS/OCIIO)" o: "'[email protected]'" c: "Habit, Sandra (HHS/OCIIO)" ate: 10/19/2010 10:25 AMubject: Regarding Assurant's application for annual limit waivers

    Ms. Hix: I am currently reviewing your application for annual limit waivers for your four products. I have several questions:

    looks as if these are fully insured products for groups, is that correct? If this is not correct, please let me know what market

    hese policies are for, e.g. individual market.lso, it looks as if the effective dates for all products is 1/1/11. Is that correct? inally, woul u to give us the premiums that underlie the percent increases? For example, you have noteercents like

    etc, but can you tell us what current premium that is based on and future premium amount if

    ad to compl annual limit? Is that an average premium across all age and genders?hanks and feel free to contact me with questions.

    ane W. AndrewsCIIO501 Wisconsin Aveethesda, MD 2081401-492-4122 (desk)02-536-6779 (Blackberry)

    ASSURANT:000009

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    ///co-adshare/...20Torres/DFOI%20Processing%20Team/Desiree/Assurant%20Health/Additional%20Info%20Resp%2010.19.10.htm[11/02/2011 10:35:4

    INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:This information has not been publicly disclosed and may be privileged and confidential. It is for internal governm

    use only and must not be disseminated, distributed, or copied to persons not authorized to receive the informatioUnauthorized disclosure may result in prosecution to the full extent of the law.

    his e-mail message and all attachments transmitted with it may contain legally privileged and/or confidentialnformation intended solely for the use of the addressee(s). If the reader of this message is not the intended recipienou are hereby notified that any reading, dissemination, distribution, copying, forwarding or other use of this messar its attachments is strictly prohibited. If you have received this message in error, please notify the sendermmediately and delete this message and all copies and backups thereof. Thank you.

    ASSURANT:000010

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    ///co-adshare/...rs%20-%20Torres/DFOI%20Processing%20Team/Desiree/Assurant%20Health/Approval%20Sent%2010-26-2010.htm[11/02/2011 10:35

    rom: Botwinick, Alexandra (HHS/OCIIO)ent: Tuesday, October 26, 2010 3:06 PM

    To: '[email protected]'

    mportance: High

    Attachments: Updated Jan 1 Approval Letter .pdf

    Ms. Blake,

    hank you for submitting an application for a Waiver of the Annual Limits Requirements of the PHS Act

    ection for Assurant Health. 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 address with a copy to [email protected]

    lease let me know if I can be of further assistance.

    incerely,

    Alexandra Botwinick

    ffice of Oversight

    HHS/OCIIO

    [email protected]

    ASSURANT:000011

    mailto:[email protected]:[email protected]
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    ///co-adshare/...20Processing%20Team/Desiree/Assurant%20Health/Correspondence%20to%20waiver%20questions%2010.21.10.htm[11/02/2011 10:35

    rom: Andrews, Jane (HHS/OCIIO)ent: Thursday, October 21, 2010 12:30 PM

    To: '[email protected]'Cc: '[email protected]'; Habit, Sandra (HHS/OCIIO)

    ubject: RE: Assurant Health - Response to Waiver Questionsreceived your information. Thank you. I see you have expressed these in an annual premium; however, we could take these

    nnual premiums and divide by 12 to get the monthly premium, so I think this is all we need. Thanks again.

    ane W. Andrews

    CIIO501 Wisconsin Ave

    ethesda, MD 20814

    01-492-4122 (desk)

    02-536-6779 (Blackberry)

    INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:

    This information has not been publicly disclosed and may be privileged and confidential. It is for internal governmuse only and must not be disseminated, distributed, or copied to persons not authorized to receive the informatio

    Unauthorized disclosure may result in prosecution to the full extent of the law.

    rom: [email protected] [mailto:[email protected]]ent: Thursday, October 21, 2010 11:58 AMo: Andrews, Jane (HHS/OCIIO)c: [email protected]; Habit, Sandra (HHS/OCIIO)ubject: Assurant Health - Response to Waiver Questions

    Ms. Andrews:

    n follow up to our call this morning and to your October 19, 2010 email, please see the additional information below in respons

    our questions regarding our waiver requests.

    Product Type - The waiver requests are for plans sold in the individual market.

    . Effective Dates - All of these plans were issued prior to September 23, 2010. The next plan year will begin on January 1, 20

    hich would be the effective date of the waiver.

    Premiums - The premiums underlying the percent increases are detailed below. These are average premiums for all plans

    hich would receive the waiver.

    Current % Futureroduct Premium Increase Premiumealth Access A

    ealth Access B

    ealth Access C

    eyMed

    hank you for taking time to discuss our request. Please contact me with any additional questions.

    incerely,

    osh Dauenior Counsel

    ssurant Health

    414) 299-8790

    ASSURANT:000012

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    ///co-adshare/...20Processing%20Team/Desiree/Assurant%20Health/Correspondence%20to%20waiver%20questions%2010.21.10.htm[11/02/2011 10:35

    his e-mail is intended solely for the person or entity to which it is addressed and may contain confidential and/or privileged

    formation. Any review, dissemination, copying, printing or other use of this e-mail by persons or entities other than the

    ddressees is prohibited. If you have received this e-mail in error, please contact the sender immediately and delete the mate

    om any computer. This e-mail message and all attachments transmitted with it may contain legally privileged and/oronfidential information intended solely for the use of the addressee(s). If the reader of this message is not thentended recipient, you are hereby notified that any reading, dissemination, distribution, copying, forwarding or othse of this message or its attachments is strictly prohibited. If you have received this message in error, please notifyhe sender immediately and delete this message and all copies and backups thereof. Thank you.

    ASSURANT:000013

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    ///co-adshare/...OI%20Processing%20Team/Desiree/Assurant%20Health/Response%20to%20Waiver%20Questions%2010.21.10.htm[11/02/2011 10:35:

    rom: [email protected]: Thursday, October 21, 2010 11:58 AM

    To: Andrews, Jane (HHS/OCIIO)Cc: [email protected]; Habit, Sandra (HHS/OCIIO)ubject: Assurant Health - Response to Waiver Questions

    Ms. Andrews:

    n follow up to our call this morning and to your October 19, 2010 email, please see the additional information below in respons

    our questions regarding our waiver requests.

    Product Type - The waiver requests are for plans sold in the individual market.

    . Effective Dates - All of these plans were issued prior to September 23, 2010. The next plan year will begin on January 1, 20

    hich would be the effective date of the waiver.

    Premiums - The premiums underlying the percent increases are detailed below. These are average premiums for all plans

    hich would receive the waiver.

    Current % Futureroduct Premium Increase Premiumealth Access A

    ealth Access B

    ealth Access C

    eyMed

    hank you for taking time to discuss our request. Please contact me with any additional questions.

    incerely,

    osh Dauenior Counsel

    ssurant Health

    414) 299-8790

    his e-mail is intended solely for the person or entity to which it is addressed and may contain confidential and/or privileged

    formation. Any review, dissemination, copying, printing or other use of this e-mail by persons or entities other than the

    ddressees is prohibited. If you have received this e-mail in error, please contact the sender immediately and delete the mate

    om any computer. This e-mail message and all attachments transmitted with it may contain legally privileged and/oronfidential information intended solely for the use of the addressee(s). If the reader of this message is not thentended recipient, you are hereby notified that any reading, dissemination, distribution, copying, forwarding or othse of this message or its attachments is strictly prohibited. If you have received this message in error, please notifyhe sender immediately and delete this message and all copies and backups thereof. Thank you.

    ASSURANT:000014

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    ///co-adshare/...onal%20Oct%208th%20app%20confirming%20approval%20for%20oct%2029th%20app%20only%2010-27-2010.htm[11/02/2011 10:35

    rom: [email protected]: Wednesday, October 27, 2010 9:14 AM

    To: Botwinick, Alexandra (HHS/OCIIO)Cc: OCIIO Oversight

    ubject: Re:

    ollow Up Flag: Follow uplag Status: Red

    Attachments: 9.29.2010 Waiver Application - Time Insurance Company and John Alden Life InsuranceCompany.pdf; 10.8.2010 Waiver Application - RightStart and SaveRight.pdfMs. Botwinick,

    received the approval letter for the Waiver of the Annual Limits Requirements you sent yesterday afternoon.

    We submitted separate applications for different products. One application was submitted September 29th and additional

    formation, as requested, was submitted to Jane Andrews on October 21st. The second application was submitted October 8t

    opies of both initial applications are attached below for your reference. Can you please indicate which application was approve

    hank you,

    licia Blake

    enior Contract Compliance Analyst

    ssurant Health

    egal Department

    414.299.8713

    414.299.6168

    om: "Botwinick, Alexandra (HHS/OCIIO)" o: "'[email protected]'" ate: 10/26/2010 02:06 PMubject:

    Ms. Blake,

    hank you for submitting an application for a Waiver of the Annual Limits Requirements of the PHS Actection for Assurant Health. 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 address with a copy to [email protected]

    lease let me know if I can be of further assistance.

    incerely,

    ASSURANT:000015

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    ///co-adshare/...onal%20Oct%208th%20app%20confirming%20approval%20for%20oct%2029th%20app%20only%2010-27-2010.htm[11/02/2011 10:35

    Alexandra Botwinick

    ffice of Oversight

    HHS/OCIIO

    [email protected]

    attachment "Updated Jan 1 Approval Letter .pdf" deleted by Alicia Blake/HEALTH/ASSURANT/US]his e-mail message and all attachments transmitted with it may contain legally privileged and/or confidential

    nformation intended solely for the use of the addressee(s). If the reader of this message is not the intended recipienou are hereby notified that any reading, dissemination, distribution, copying, forwarding or other use of this messar its attachments is strictly prohibited. If you have received this message in error, please notify the sendermmediately and delete this message and all copies and backups thereof. Thank you.

    ASSURANT:000016

    mailto:[email protected]:[email protected]
  • 7/30/2019 Assurant Redacted HW

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    ///co-adshare/...aivers%20-%20Torres/DFOI%20Processing%20Team/Desiree/Assurant%20Health/Corresponsdence%2010.27.10.htm[11/02/2011 10:35

    rom: Andrews, Jane (HHS/OCIIO)ent: Wednesday, October 27, 2010 11:15 AM

    To: '[email protected]'Cc: Habit, Sandra (HHS/OCIIO); Botwinick, Alexandra (HHS/OCIIO)

    ubject: Your other, October 8th waiver application

    We dont seem to have a record of your October 8th waiver application, but we will get it in the queue now.

    ane W. Andrews

    CIIO

    501 Wisconsin Ave

    ethesda, MD 20814

    01-492-4122 (desk)

    02-536-6779 (Blackberry)

    INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:

    This information has not been publicly disclosed and may be privileged and confidential. It is for internal governmuse only and must not be disseminated, distributed, or copied to persons not authorized to receive the informatio

    Unauthorized disclosure may result in prosecution to the full extent of the law.

    ASSURANT:000017

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    ASSURANT:000018

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