Seneca Cayuga ARC - Redacted Bates HWM

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//T|/...0-%20YELLOW/Applications%20with%20NO%2012600%20Response%20[YELLOW]/Seneca%20Cayuga%20ARC/Waiver.txt[08/12/2011 3:51

rom: Donna VanAllan [[email protected]]ent: Wednesday, November 24, 2010 1:18 PMo: HHS HealthInsurance (HHS)

Cc: [email protected]: Waiver

Attachments: waiver app.pdf

ee attached Waiver Application and required documents (within one attachment).

lease contact Bill Kaminski, Director of Human Resources, at 315-539-5067 if you have any questions, or requiredditional information.

Donna VanAllan

------Donna VanAllan

xecutive Assistanteneca Cayuga ARC15-539-5067, ext. 117

Seneca ARC:000001

Document obtained by CompleteColorado.com


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Seneca ARC:000002



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Pages 3 through 17 redacted for the following reasons:- - - - - - - - - - - - - - - - - - - - - - - - - - - -Exemption 4

Seneca ARC:000003



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//T|/...%20with%20NO%2012600%20Response%20[YELLOW]/Seneca%20Cayuga%20ARC/Request%20for%20info%2012.9.10.htm[08/12/2011 3:51

rom: Kottenmeier, Erika (HHS/OCIIO)ent: Thursday, December 09, 2010 12:25 PM

To: '[email protected]'Cc: Habit, Sandra (HHS/OCIIO)ubject: Annual Limits Waiver Applicationear Mr. Kaminski,

hank you for your application on behalf of Seneca Cayuga ARCs Standalone HRA. Before we can complete processing your

pplication, we need several items of information from you. Specifically, please provide the following:

The number of enrollees in the plan (including dependents)

The amount the employer contributes to each employee

A signed attestation as it is stated in the September 3, 2010 OCIIO Sub -Regulatory guidance. The attestation must inclu

statement that 1) the HRA was in existence prior to September 23, 2010, and 2) that the plan will experience a significa

increase in premium or significant decrease in access to benefits if it complies with the restricted annual limits of the AC

The language may be found in item five at the following URL: http://www.hhs.gov/ociio/regulations/patient/ociio_2010-

1_20100903_508.pdf

lease scan your signed attestation and attach it to an email to this address. If you cannot scan the attestation, please fax it to

301) 492-4217. If you will be faxing the attestation, please notify me first. In order to complete your application, please provide

formation by 5:00 pm, December 10, 2010. Once this information is received and the application is complete, it will be proce

y the Department of Health and Human Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHSsue a decision within 30 days of receiving a complete application. You will receive an e-mail from HHS notifying you of the

aiver decision.

ind Regards,

rika M. Kottenmeier

ivision of Enforcement

ffice of Oversight

HS/OCIIO

[email protected]

INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:

This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be

disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the

extent of the law.

Seneca ARC:000004

http://www.hhs.gov/ociio/regulations/patient/ociio_2010-1_20100903_508.pdfhttp://www.hhs.gov/ociio/regulations/patient/ociio_2010-1_20100903_508.pdfmailto:[email protected]:[email protected]://www.hhs.gov/ociio/regulations/patient/ociio_2010-1_20100903_508.pdfhttp://www.hhs.gov/ociio/regulations/patient/ociio_2010-1_20100903_508.pdf


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//T|/...2012600%20Response%20[YELLOW]/Seneca%20Cayuga%20ARC/Follow%20up%20to%20previous%20email%2012.9.10.htm[08/12/2011 3:5

rom: Kottenmeier, Erika (HHS/OCIIO)ent: Thursday, December 09, 2010 12:47 PM

To: '[email protected]'Cc: Habit, Sandra (HHS/OCIIO)ubject: Follow up to previous emailear Mr. Kaminski,

n addition to the information requested in the previous email, your application is also missing a statement of how the applicatio

he annual limits will result in a decrease in benefits to the HRA. The application must provide some evidence of how the annu

mits will result in a significant increase in premiums (generally demonstrated by a percent increase), or a decrease in access enefits. Without a statement of either we cannot grant the waiver. We are aware that HRAs are not typical health plans with

remiums paid, so you will most likely have to make a showing of decrease in benefits. Please provide this information as well

ind Regards,

rika M. Kottenmeier

ivision of Enforcement

ffice of Oversight

HS/OCIIO

301) 492-4170

[email protected]


This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be

disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the

extent of the law.

Seneca ARC:000005

mailto:[email protected]:[email protected]


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//T|/...NO%2012600%20Response%20[YELLOW]/Seneca%20Cayuga%20ARC/Request%20for%20info%20response%2012.13.10.txt[08/12/2011 3:51

rom: Kottenmeier, Erika (HHS/OCIIO)ent: Monday, December 13, 2010 11:27 AMo: Habit, Sandra (HHS/OCIIO)ubject: FW: Annual Limits Waiver Application

----Original Message-----

rom: Kottenmeier, Erika (HHS/OCIIO)ent: Monday, December 13, 2010 11:25 AMo: 'Bill Kaminski'ubject: RE: Annual Limits Waiver Application

Dear Mr. Kaminski,

hank you for your reply. Your cover letter was somehow separated from your plan documents, so I appreciate youe-sending it. However, we are still missing the employer contribution information, as it is not included in the Plan

Document (it says $XXX.XX in place of a dollar amount). When we have that information your application will beomplete.

Kind Regards,rika Kottenmeier

----Original Message-----rom: Bill Kaminski [mailto:[email protected]]ent: Friday, December 10, 2010 2:49 PMo: Kottenmeier, Erika (HHS/OCIIO)ubject: Re: Annual Limits Waiver Application

Dear Erika, The lettered we mailed on 11/24/10 (signed copy attached) has the number of participants and dependenovered, etc...? I believe the letter and plan document answers the questions below? We sent this as an email and w

mailed a hard-copy. Please review and let me know what else is required. Thanks. Bill Kaminski

On 9 Dec 2010 at 12:24, Kottenmeier, Erika (HHS/OCIIO) wrote:

Dear Mr. Kaminski,

Thank you for your application on behalf of Seneca Cayuga ARCsStandalone HRA. Before we can complete processing your application, we need several items of information fro

ou.Specifically, please provide the following:

* The number of enrollees in the plan (including dependents)* The amount the employer contributes to each employee* A signed attestation as it is stated in the September 3, 2010 OCIIO Sub-Regulatory

guidance. The attestation must include a statement that 1) the HRA was in existence priorto September 23, 2010, and 2) that the plan will experience a significant increase inpremium or significant decrease in access to benefits if it complies with the restricted annuallimits of the ACA. The language may be found in item five at the following URL:

http://www.hhs.gov/ociio/regulations/patient/ociio_2010-1_20100903_508.pdf

Seneca ARC:000006



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//T|/...NO%2012600%20Response%20[YELLOW]/Seneca%20Cayuga%20ARC/Request%20for%20info%20response%2012.13.10.txt[08/12/2011 3:51

Please scan your signed attestation and attach it to an email to thisaddress. If you cannot scan the attestation, please fax it to (301)492-4217. If you will be faxing the attestation, please notify mefirst. In order to complete your application, please provide thisinformation by 5:00 pm, December 10, 2010. Once this information isreceived and the application is complete, it will be processed by theDepartment of Health and Human Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidanc

HHS will issue a decision within 30 days of receiving a complete application. You will receive an e-mail from HH

otifying you of the waiver decision.

Kind Regards,

Erika M. KottenmeierDivision of EnforcementOffice of OversightHHS/[email protected]


This information has not been publicly disclosed and may be privilegedand confidential. It is for internal government use only and must not be disseminated, distributed, or copied to

ersons not authorized to receive the information.Unauthorized disclosure may result in prosecution to the full extent of the law.

Seneca ARC:000007



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//T|/...lications%20with%20NO%2012600%20Response%20[YELLOW]/Seneca%20Cayuga%20ARC/Correspondence%2012.13.10.txt[08/12/2011 3:51

rom: Kottenmeier, Erika (HHS/OCIIO)ent: Monday, December 13, 2010 3:53 PMo: 'Bill Kaminski'

Cc: Habit, Sandra (HHS/OCIIO)ubject: RE: Annual Limits Waiver Application

Mr. Kaminski;

No problem at all. Now I have all the information I need. I will make a recommendation to HHS leadership at the nossible opportunity. Thank you for your assistance.

est,rika Kottenmeier

----Original Message-----rom: Bill Kaminski [mailto:[email protected]]ent: Monday, December 13, 2010 3:35 PMo: Kottenmeier, Erika (HHS/OCIIO)ubject: RE: Annual Limits Waiver Application

Krika - sorry about the XXX.XX I missed that. The normal annual contribution has been $ per year. thanks. Bil


rom: "Kottenmeier, Erika (HHS/OCIIO)"[email protected]>o: 'Bill Kaminski'

Date sent: Mon, 13 Dec 2010 11:24:43 -0500ubject: RE: Annual Limits Waiver Application

Dear Mr. Kaminski,

Thank you for your reply. Your cover letter was somehow separated from your plan documents, so I appreciate ye-sending it. However, we are still missing the employer contribution information, as it is not included in the Plan

Document (it says $XXX.XX in place of a dollar amount). When we have that information your application will beomplete.

Kind Regards,Erika Kottenmeier

-----Original Message-----

From: Bill Kaminski [mailto:[email protected]]Sent: Friday, December 10, 2010 2:49 PMTo: Kottenmeier, Erika (HHS/OCIIO)Subject: Re: Annual Limits Waiver Application

Dear Erika, The lettered we mailed on 11/24/10 (signed copy attached) has the number ofparticipants and dependents covered, etc...? I believe the letter and plan document answersthe questions below? We sent this as an email and we mailed a hard-copy. Please reviewand let me know what else is required. Thanks. Bill Kaminski


Seneca ARC:000008



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//T|/...lications%20with%20NO%2012600%20Response%20[YELLOW]/Seneca%20Cayuga%20ARC/Correspondence%2012.13.10.txt[08/12/2011 3:51

>> Dear Mr. Kaminski,>> Thank you for your application on behalf of Seneca Cayuga ARCs Standalone HRA. Before we> can complete processing your application, we need several items of information from you.> Specifically, please provide the following:>> * The number of enrollees in the plan (including dependents)

> * The amount the employer contributes to each employee> * A signed attestation as it is stated in the September 3, 2010 OCIIO Sub-Regulatory> guidance. The attestation must include a statement that 1) the HRA was in existence prior> to September 23, 2010, and 2) that the plan will experience a significant increase in> premium or significant decrease in access to benefits if it complies with the restricted annual> limits of the ACA. The language may be found in item five at the following URL:> http://www.hhs.gov/ociio/regulations/patient/ociio_2010-1_20100903_508.pdf>> Please scan your signed attestation and attach it to an email to this address. If you cannot scan> the attestation, please fax it to (301) 492-4217. If you will be faxing the attestation, please notify> me first. In order to complete your application, please provide this information by 5:00 pm,

> December 10, 2010. Once this information is received and the application is complete, it will be> processed by the Department of Health and Human Services (HHS). As stated in our September> 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30 days of receiving a> complete application. You will receive an e-mail from HHS notifying you of the waiver decision.>> Kind Regards,>> Erika M. Kottenmeier> Division of Enforcement> Office of Oversight> HHS/OCIIO> [email protected]>>> 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

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

Seneca ARC:000009



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//T|/...RC%20Approval%20Letter%20for%20a%20Waiver%20of%20the%20Annual%20Limits%20Requirements%2012-30-2010.htm[08/12/2011 3:51

rom: Habit, Sandra (HHS/OCIIO)ent: Thursday, December 30, 2010 5:39 PM

To: '[email protected]'ubject: Seneca Cayuga ARC 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 Seneca Cayuga ARC. HHS has reviewed your application and made its determination. Plea

ee the attached 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

[email protected]

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.

Seneca ARC:000010

mailto:[email protected]:[email protected]


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Seneca ARC:000011



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Seneca ARC:000012



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rom: Bill Kaminski [[email protected]]ent: Monday, January 03, 2011 2:59 PMo: Habit, Sandra (HHS/OCIIO)ubject: Re: Seneca Cayuga ARC Approval Letter for a Waiver of the

Annual Limits Requirements 12-30-2010

Received your approval - thank you! Bill Kaminski, Seneca Cayuga ARC

On 30 Dec 2010 at 17:38, Habit, Sandra (HHS/OCIIO) wrote:

Good Afternoon,

Thank you for submitting an application for a Waiver of the AnnualLimits Requirements of the PHS Act Section 2711 for Seneca Cayuga ARC.HHS has reviewed your application and made its determination. Pleasesee the attached letter.

Please confirm receipt of this letter by replying to this e-mail.

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

Sincerely,

Sandy HabitDepartment of Health and Human Services Office of Consumer Informationand Insurance [email protected]

INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:This information has not been publicly disclosed and may be privilegedand confidential. It is for internal government use only and must notbe disseminated, distributed, or copied to persons not authorized toreceive the information. Unauthorized disclosures may result in prosecution to the full extent of the law.

Seneca ARC:000013


Seneca Cayuga ARC - Redacted Bates HWM

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