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[Webinar] Healthcare Reform: Not Everything Has Been Delayed

2013-10-08 14:00:00

In this webinar ADP covers healthcare reform—the provisions, deadlines, and direct impact on employers. Based on the feedback and questions that have been posed in our prior events, we look forward to taking an opportunity to further address common compliance and cost control questions tied to this robust, game-changing legislation.

This Webcast delivered professional insights into the impact on employers of the ACA. We will discuss:

  • Requirements applicable to 2014 under the ACA and associated deadlines
  • Requirements that have been postponed until 2015
  • New requirements that are also anticipated to take effect in 2015
  • The impact of the Supreme Court’s decision on DOMA and what this means for employer-sponsored benefit plans
  • Thoughts on the future of healthcare benefits for employers of all sizes

Who Should Participate:
Executive management, finance managers and CFOs, benefits/HR leadership and business owners, as well as all HR professionals.

haslingerJohn A. Haslinger
Vice President, Benefits Outsourcing Consulting Services, Strategic Advisory Services 
John is Vice President of ADP Benefits Outsourcing Consulting, responsible for Compliance and Health Care. He has 35 years of experience in the areas of employee benefits, spanning strategic design, compliance and administration for both retirement and H&W benefit plans. In particular, his experience has focused on operations, outsourcing and shared service environments. Prior to joining ADP, John was a Director in Deloitte Consulting’s Human Capital Practice where he consulted with both plan sponsors and providers in these areas – addressing strategic, operational, and funding issues.

ADP SmartCompliance Health Care Module

Learn more ACA Compliance: Stabilize Your Approach To The Affordable Care Act.

Joe McCafferty:
Compliance Week

October 8, 2013
2:00 PM ET

Joe McCafferty: Good afternoon and welcome to today’s Compliance Week webcast. I’m Joe McCafferty, Executive Editor, Compliance Week, and I’ll be hosting this afternoon’s session. Today we’re going to be talking about health care reform and the accompanying provisions, deadlines, and direct impact on employers.

As many of you know, some of the major provisions of the Affordable Care Act have been delayed until January of 2015, but many of them have not and even with the delays, companies will have a difficult time meeting those deadlines. Before we hear from our guest who is here to talk about some of that, let me quickly go over the agenda for this afternoon.

We’re scheduled to go for one hour. I’ll give a brief introduction and then will jump into the presentation, brought to you today along with ADP. Presentation will be followed by a question and answer session. Your questions will be kept confidential, so don’t be shy. You can ask them at any time by using the “Ask Question” function on the left-hand side of your screen. I’ll pose them to our guest at the end of the presentation. I urge you to ask your questions as they occur to you. We’ll be much more likely to get to them the sooner that you ask them. Another note, this webcast will also offer CPE credit. To obtain your CPE credit, wait until the webcast is over and I sign off. At that point, the final exam will be presented automatically in a separate window.

Please be sure to disable any pop-up blockers you have. Those can disrupt us serving you the test. If you have any trouble viewing the CPE test are receiving the CPE certificate, just send an email to info, I-N-F-O@complianceweek.com, to request a copy. Also, at any time during the presentation, you can download the slides from the drop-down menu on the left-hand side of your screen. You can also hit the view slide full screen button, that’s at the bottom of your screen, if you wish to increase the size of the slides. Lastly, a help button is located in the upper right-hand corner of your screen for assistance.

Today’s webcast is part of a series that Compliance Week launched a few years ago. We hold these webcasts just about every week and our guests have been chief compliance and governance officers at leading public companies and experts on various compliance, regulatory, governance, and risk topics. For an upcoming schedule of our future webcasts, please visit www.complianceweek.com for details on those or to register.

So let’s begin our program. Today we’re very pleased to have with us John Haslinger. He is Vice President of ADP’s Strategic Advisory Services. John has 35 years of experience in the area of employee benefits, spanning strategic design, compliance, and administration for both retirement and health and welfare benefit plans. His experience is focused on operations, outsourcing, and shared service environments. John also spent 10 years on the Board of Directors on the New York Business Group on Health, and he has taught graduate level classes on benefits and compliance at Framingham State University.

John, were very pleased to have you here with us. Do you want to get us started?

John Haslinger: Joe, thank you very much, and I want to thank everyone else for joining us today on today’s session. We’re going to be looking at what has been delayed and what hasn’t been delayed in terms of health care reform and there’s, I think, some confusion around both those issues. Before I get going, I think it’s important for me to point out that ADP is not a law firm and I’m not an attorney and we’re not giving legal advice. So we do encourage everyone on the call to make sure that they take the information they get from these and other types of sessions and review them with their own legal counsel.

It’s not the final word on health care reform. Regulations are going to continue to pour forth. We’ve had regulations as recently as only a few weeks ago. I’ll talk about some of the ones that came out early in September regarding reporting requirements that have been kind of put forth as proposed, but even the political situation we are in right now with the debt situation, the debt crisis, has the potential to change some elements or postpone some elements of health care reform. So this is a living thing. It will continue to change and evolve, certainly at least until 2018, and in all likelihood, beyond.

And we do try to avoid providing any sort of political point of view as we talk about these, as ADP’s position is really it is the law. We want to make sure that our clients and organizations that we’re providing assistance to understand the law, understand the requirements and can- are able to comply with it in the most efficient manner possible.

With that said, let’s jump right into the presentation. Since you all have copies of the deck (ph), I will not be reading every single word on each slide, but I’ll really go to the salient points. And the first thing as the delays. We’re all very familiar with right before the July 4 holiday the White House issued a statement indicating that some elements of the employer mandate were going to be delayed, at least until 2015, and the day after, I think it was July 5 or 6, the Treasury issued something approaching 600 pages of regulations around the delay.

Now, one of the misconceptions has been that the employer mandate, in fact, has been delayed and it has not been delayed. All that’s been delayed is the reporting requirements associated with the employer mandate and then the penalties that could occur should an employer fail to comply with the employer mandate. Having said that, all of the other requirements are technically in force as of January 1, 2014, so employers should, in fact, be enrolling or making plans available to people who meet the ACA full-time requirements. And I will continually use ACA full-time and rather than saying full-time status, because employers can, in fact, make a distinction between what they might consider full-time employees and ACA full-time employees. From the ACA point of view, such ACA full-time employees must be eligible for health care if they work at least 30 hours a week, on average, per month during the measurement period.

Having said that, they don’t have to be treated as full-time for any other HR programs. So if an employer has a different definition of full-time for something like vacation accrual or for stock distribution or eligibility, those definitions can in fact stay in place. But the key thing here is the reporting has been put off until ’15; the penalties have been put off until ’15; but the requirements have not changed. And in fact, as we go through this, we’ll see that Treasury’s intent was in part to avoid errors and to look for ways they might be able to simplify, but very critically, as they stated in the regulations, the preamble to the regulations, was to provide employers with an opportunity to actually test their processes and procedures.

That’s a critical consideration in that when 2015 rolls around, we don’t anticipate any – or certainly not significant – transition relief. We think the requirements will be expected to be workable and achievable by employers at that point in time, so the transition relief that had been offered for 2014 is not likely to occur in the future. Now, one other thing, one other area has been delayed, and this focuses on annual out-of-pocket limits. The annual out-of-pocket limits were intentionally going to be restricted for both prescription drugs and health care plans, and you could see the maximums, there, but basically a little over $6,000 for individual coverage; and just under $13,000 for family coverage, with some per deductible limitations within those limits.

The decision was made that for plans that have separate PBM situations, separate from their health care. So if your prescription drugs are provided separate from your health care benefits, that combined limit does not have to apply in 2014. It will have to apply in 2015 and you should certainly be reaching out to your prescription drug and health care providers to ensure that they will be able to transmit and transfer data between them to ensure that that limit is met and not exceeded. Now, frankly, for many large employers, this is not a big issue in that many of the plans that we see with employers with at least 1,000 or more employees already have limits there at this level or lower. But be aware, at least for 2014, you can maintain separate limits equal to these amounts that you see on the screen for your prescription drug program and your health care program if they are provided separately. If they are combined in provided by a single provider, then the combined limits would still go into effect in 2014.

With those delays, it’s important to think about what has not been delayed. And some things that have not been delayed – not sure why the screen is not showing up – so what has not been delayed that’s really critical are going to be four critical areas. One of them is the fees that employers have to pay. Employers are looking at a number of fees. The PCORI fees are probably the most critical ones that you may be aware of. They’ve already been paid or they should have been at this point – July of this year.

The next ones that’ll be popping out that are going to be important are going to be the transitional reinsurance program fees. Now the transitional reinsurance program fees are going to be triggered next November, 2014. They are much more substantial than the fees associated with the PCORI fees. The PCORI fees, as you’re all aware, were $1 per covered life this past July. The transitional reinsurance fees, on the other hand, will be $63 per covered life and that is leading to some employers thinking about, “How do I, while complying with the law, minimize the people that might be covered under my plan to avoid having to pay fees on people that perhaps shouldn’t be covered?” And we’re seeing a variety of strategies.

One good example – and it’s not driven entirely by this, but it’s an element – is what UPS had announced in terms of not making their plans available to spouses who are eligible for coverage where they work. So I think that trend is likely to continue. The second thing that has not been delayed is going to be, and this is, again, you’ve already hopefully addressed this because we’re now past October 1, is the distribution of notice of coverage to employees or the exchange notifications. By law, they should have been in the hands of employees no later than October 1, 2013, and for employees hired on and after that date, you’ve got to make sure you get it into their hands within 14 days of the date of hire.

Some other elements that have not been delayed – the plan design changes. And I won’t go through them and super detail, given the timing of today’s session, but things like the elimination of the annual and lifetime dollar limits on essential health benefits. That is a critical change. Your plans must comply with that as of January 1, 2014 or if the plan year that commences later and you meet other specific requirements which most plans will, you can put some of these off until your plan year commences.

Waiting periods have been eliminated or reduced. You can no longer have a waiting period that goes beyond 90 days for a full-time employee who is newly hired. And that’s important to keep in mind. It’s 90 days from the date of hire. It’s not 90 days from the first of the month following the date of hire. And presumably, you’ve already begun to make changes to your policies and procedures to reflect that, but that’s a critical one.

New wellness program rules have gone into effect. The most critical element of that has been the ability to have a deeper discount. Instead of 20%, you can go to 30% for employees who in fact meet or participate in certain specific wellness opportunities. Most employers have already built that into their plans, if they’re going to build it into their plans, for 2014.

And then finally, coverage for specific recommended and preventive services without any cost sharing for non-grandfathered plans. This has been another critical area that has to be in place on January 1, 2014.

Perhaps the most critical one, though, is the fourth element. And this is the look back period. Many employers who have not prepared and were not ready to determine eligibility on January 1, 2014, using the look back approach, have kind of been lulled into a sense of, in some cases, of false security. They’re thinking, “Well, I don’t have to worry about this until January of ’15, and therefore, I’ve got a lot of time. I can wait until, get my systems up and running.” The risk element that employers run here is that if they don’t start doing this now, they will, in fact, run out of time. In fact, and hopefully this next slide will show us this – it’s not moving forward. Give me one second here. Having a little – a problem. Okay.

This next slide shows the issue of when you’re going to have to start tracking hours of service in order to be in compliance with the look back period. Now, what this is indicating – it’s based on a few assumptions. One is that you have a calendar one plan year, January 1. So the plan year commences on January ’14 and then again on January ’15. As of January ’15, you will have to be reporting to the federal government and you will be subject to potential penalties under the employer mandate. If you want to avoid those penalties and you want to make sure you’re in full compliance, one of the critical issues is going to be making sure that you determined who is an ACA full-time employee using the appropriate look back period. Now, we are recommending as a best practice that our clients use a 12 month look back period. We’re finding that that is the least expensive, both from a benefit costs point of view, as well as from an administration point of view, both internally and if it’s outsourced to folks like us, the external costs.

Clients can obviously do shorter ones but we’re finding, as we go through the math with clients, most companies are, in fact, migrating towards a 12 month look back. With that as an assumption, and a January 1, ’15 plan year as an assumption, the chart at the bottom of the page shows you when you actually have to start tracking hours of service to be fully compliant for January 1, ’15. And if you are going to need a 90 day administrative. In order to make the determination on who is or who is not a full-time employee under ACA, you will actually have to start tracking hours of service beginning in October, the first pay cycle in October 2013. And I – you’ll notice I’m using the term “hours of service.” Some employers have kind of begun locking in on hours worked or hours paid; and that’s not adequate. Hours worked and paid is clearly one of the major components of hours of service. It’s probably the vast majority, but there’s also hours that are paid that are not worked and again, both of those elements are generally easily available through payroll systems, but then there’s the third element that many employers have just not focused on. And this is unpaid leave. Unpaid leave associated with family medical leave, USERRA, or jury duty must be taken into account when determining hours of service. And if it is not taken into account – and we’ll come to this when I get into more detail on the shared responsibility requirements – if it’s not taken into account, an employer could trigger a significant penalty, especially if the failure to take into account results in the employer offering coverage to less than 95% of the people who should be considered ACA full-time employees.

Now as you can see at the bottom of the chart, if you can do the administration at the end of the year and less than 90 days, you can postpone having to worry about tracking hours of service a bit area but in every instance, if you have a calendar one plan year, you must begin tracking hours of service in 2013, in order to be fully compliant when we hit 2015. And I think a lot of employers were not aware of this.

Going to the next chart, we can see some additional issues that employers are going to have to make sure that they are ready to deal with and essentially, we are looking at a number of considerations here. One is the emergence of nondiscrimination rules for fully insured plans and potentially changes in the nondiscrimination rules for self-insured plans. Now, many of your who have self-insured plans may not have even been aware that you had non-discrimination rules in place, but they’ve been there for well over 25 years. It’s – the Internal Revenue Service Code, Section 105(h), and we anticipate that, at a minimum, those rules will be enforced by treasury beginning in ’14 or ’15, but there’s a possibility those rules could be modified and the reason I say that is under ACA, the IRS is required to promulgate regulations around nondiscrimination testing for fully insured plans. One of the easiest things they could have done was just adopt the 105(h) requirements.

Having failed to do so, it suggests to some observers that they may be looking for a more mathematically, numerically-based approach without any facts and circumstances considerations. Should they go that route then it would not be unlikely that they would apply that same testing requirement to the self-insured market. So I think you want to be aware of the 105(h) requirements, ensure that your plans currently comply with them, and to the extent that new requirements emerge over calendar ’14, be ready to make modifications, if necessary, in your plan designs.

One other item that’s going to be emerging in ’15, which will further complicate administration as we go forward, is going to be open enrollments. We don’t have any regulations around this and it’s already late, in terms of being implemented. Anticipate that as of January 1, ‘ 15, employers will, in fact, have to automatically enroll all ACA full-time employees in their plans. Now, ACA does not exist in a vacuum, and by that, I mean that it interacts with and intersects with other regulations and laws impacting employee benefits and human resources.

One of the critical ones here is Internal Revenue Code Section 125, the cafeteria regulations. Employees who are automatically enrolled in a plan of coverage will not be able to change their elections once the plan year has commenced under current regulations. Now there is some hope that Treasury will provide some sort of transition relief, perhaps allowing people to make an election change for 30 or 60 days following the commencement of the plan year, should they be automatically enrolled and really not want to be. But at present, that does not exist. And that’s an important consideration for employers that they could potentially be faced with employees enrolled for coverage that they cannot turn off the contributions for who did not want or need on the legally or otherwise, that coverage. One alternative to that, should we not get transition relief, would be to default auto enrollments into a post-tax contribution structure, which would allow flexibility in refunding the contributions and turning them off, should an employee come and be concerned about that.

Having said that, let’s take a look at the reporting requirements. On September 9, Treasury issued a detailed proposed reporting requirements. These reporting requirements will take effect on January 1, 2015, and they primarily kick in at the end of 2015, so there is some time for employers to fully comply with these. One of the key things to keep in mind as we walk through these reporting requirements quickly, is the multiple systems that will have to be talking to one another and interacting with one another. For example, four key systems are going to be required to interface with one another if an employer both wants to actively manage their compliance and be fully in compliant for reporting purposes, at the end of the year. And when I say active management, I mean measuring, tracking, and potentially adjusting what they’re doing during the year.

The time scheduling system will be critical to that, especially if you have variable hour, part-time employees who the intent is to keep below some threshold to avoid having to make them full time for ACA purposes. Payroll is going to be a critical component of this for things like determining affordability, as well as hours worked and hours paid. The benefits systems are going to be critical. Again, they will have an impact in terms of affordability. There will also be systems records for enrollment and eligibility determinations; and then leave administration, as I mentioned earlier – unpaid leaves for FMLA, USERAA, and jury duty must be included in determining who is an ACA full-time employee.

The issue that I raised with a lot of our clients is that few employers have systems in these areas that actually talk to each other well, and in some cases, they’re still working manually, in particularly, around leave administration. It’s not uncommon, even for very large companies, to not have a true system in place for tracking things like jury duty or USERRA. So this is an important consideration, to make sure that your systems are up and running, are tracking accurately, and can, in fact, provide data either among and across each other, or to a centralized tool that brings it together, can use it for calculations, and will actually store the results for future reconciliation.

Now, the basic results are pretty straightforward. An employer, or an applicable large employer – and I’m assuming everyone on the call today is at least more than 50 full-time equivalents – so an applicable large employer will have two reporting requirements. One is going to be an employer transmittal to the government. The other is going to be the issuance of employee statements. Those will occur at the end of the calendar year. So the employee statements will be issued in conjunction with the W-2s that occur in January of ’16. The employer transmittals can occur between February and March, depending on how the employer chooses to file those.

What we’ve done here is we’ve laid out some of the key requirements. There are two forms that are going to be required for employers to comply with: one is the forms 1094C and we’ve outlined the requirements that must be provided by the employer here. You can see that the employer will have to provide a lot of information around who it is, who the employers person is, should the federal government or any of the agencies have any questions and they need to get in touch with somebody, how many individual employee statements were in fact issued by the employer. They’ll have to document that the coverage that they provided or offered to the employees met the minimum value and the minimum essential coverage requirements. They’ll have to certify as to whether they, as a applicable large employer, they offered coverage to at least 95% of their employees and in 2015, to the dependents of their employees.

Now another critical thing to keep in mind here is that the term dependents is defined in the Internal Revenue Code under Section 152. It is not the same definition that ACA uses. ACA Points to Section 152, but for some reason, has decided that spouses do not have to be included as dependents for purposes of the Affordable Care Act. So only dependent children, as defined under Section 152, must be offered coverage.

The employer will have to show the number of full-time employees each month, and again, this is ACA full-time employees, months during which the employer was conducting business and, you know, other information that you can see here. Now in terms of what they’ve got to provide to the employee, it’s very extensive. Again, much of it is repetitive to what we went through on the employer transmittal, but now for each individual employee, they’re going to have to show them which months were they eligible to participate in coverage, the monthly premium for the lowest-cost plan that had at least a 60% actuarial value, that was offered to the ACA full-time employee. More employer information, and then things like, was minimum essential coverage offered to the employee only, to their dependents, to their spouse. Was coverage offered during an employee, while they were in a waiting period who were not full-time employees? Did employees elect coverage? If they elected it, what were the effective dates of that coverage?

So this is a lot of information. We do not have specific surroundings, like record layouts, yet. We don’t even have specifics yet around some of what will be required to support these statements. So it’s highly unlikely, for example, that an employer will merely be able to report to the federal government that coverage was affordable. The likelihood is that they’ll have to be able to document that, and we don’t know what elements of payroll or benefits the government will look to to see if you can demonstrate that something was affordable. Even if it’s not required, as part of the initial reporting that you document these, even if attestations were accepted, during audits, when employers are reconciling with or disputing penalty assessments, they need to go back to this. Raw data will be critical and you need to keep in mind that this raw data is part of the employees’ permanent tax file. So it needs to be maintained for at least seven years and it is subject to audit by the federal government.

Another piece that not been outlined, yet has been the exchange reporting requirements. There will be reporting requirements, real-time, ‘during 15, to exchanges. And when I say real-time, the exchange will reach out to employers to the extent they needed to show information and as we understand the very vague, very limited rules that have been put forth thus far, employers will have up to 90 days to provide responses to that information. We expect that that reporting requirement will get tightened up and that it will become much more rigorous. In particular, an example that seems to have been totally ignored is when an employee who is eligible to receive a subsidy in the exchange suddenly, because of their tenure or job change, now becomes eligible for coverage by the employer. At the moment, there’s no reporting requirement for the employer to notify the exchange. We do anticipate that there will be one. The federal government and the state exchanges do not want to continue to provide subsidies to people who are no longer eligible for those subsidies. So there’s a number of things that are likely to happen on the exchange reporting side of this.

Now in terms of strategic considerations, I think it’s important for us to be thinking about two key areas – and we’ll try to get to both of them in today’s call. One is shared responsibility. It’s here. We are already in the process of open enrollment. Employers, if they are complying with the law as the requirements are, even though penalties don’t apply, have already begun identifying ACA full-time employees and notifying them of their benefit eligibility. Employers may have also started making other changes in their employment practices in response to the law. And I’ll talk about some of them in a minute.

The other key one is going to be the excise tax in 2018. Now this is one that we’ll spend a little time on at the very end but many employers, because it’s 2018, have kind of put on the back burner and we are strongly suggesting that if you have not done an analysis and a projection of the cost of your benefit plans – and all the elements need to be included in that cost calculation – then you need to do it now and project that at least through 2018, and probably a little bit later than that, to see whether or not you are likely to incur an excise tax penalty under the excise tax. Our data, and other consulting firms and administrators, have very similar results. Our data suggests that as many as two thirds of all employers will incur an excise tax liability in either 2018 or ’19, unless they make changes to their plans. So we think it’s important that employers be aware of the potential for hitting this liability – and the liability’s substantial. I’ll go through it and a lot more detail, but basically, if you exceed specified dollar limits that the federal government has indicated, every dollar above those limits is subject to a 40% non-deductible excise tax. So hold that in mind and will come back to it.

One of the key things that I kind of point out to a lot of employers is that health care reform is not a benefits piece of legislation. It obviously impacts employee benefits, but it’s far more massive. In fact, it can be argued that it is the most significant piece of social legislation in the history of the United States in terms of its scope and in terms of the cost and the impact on the economy. It impacts every single person who’s living legally in the United States. It impacts every employer who’s operating in the United States. Every health care provider, every insurance company, every PBM, every medical device manufacturer – in fact, it impacts approximately 20% of the entire United States economy. So this is a massive piece of social legislation and it will transform how we approach health care and insurance as we go forward over the next decade.

As a result, we are strongly suggesting that employers stop looking at this as a benefits event and begin looking at it in much more strategic consideration. The kind of traditional benefits is at the bottom. The foundational elements. You know you need to make sure that your systems are in place; that you understand the basic compliance requirements; that you signed off with your legal counsel that you are in fact doing those things and you have processes and procedures and systems in place to document that; that you’re able to track the appropriate hours of service on behalf of employees; and get the required forms out. All that’s basic nuts and bolts and that’s something, and that’s something that benefit professionals have dealt with throughout.

But then you start getting into more strategic considerations. So for example, do you offer coverage or not? Does it make sense to pay a penalty or does it make more sense to offer coverage to your employees? Do you change your business model or do you continue it? Do you make more employees full-time or more employees part-time? What impact does that ultimately have on your ability to service your clients? Do you make changes because of the upcoming excise tax to your benefit plans now and begin phasing them in, or do you wait until you’re faced with the need to make potentially massive cutbacks? And then, again, to the workforce strategy, as you think about these changes, what impact do they have on your ability to attract, retain, and engage your employees and what is the balance, potentially – and it’s likely to change – what is the appropriate balance between benefits and other forms of direct compensation? In the past, employers did not have these limitations, did not have these requirements, and they may have, for example, said, “Well, I want to be at the 70th or 80th percentile in my benefits when I do comparative market scans, but I only want to be at the 50th or 60th percent indirect pay.” While that balance may change somewhat. Some employers may decide they want to be higher or lower when they look at their competitors and benefits, and that may directly impact how they choose to structure and provide other forms of compensation.

So we really think you need to start thinking about this very, very strategically. This is not a piece of legislation that looks anything like the prior benefit legislation. In the past, benefit legislation involved things like systems, IT, and legal, which this does, but you did not have flexibility. You did what the law required. You sent out your HIPAA notices or your COBRA notices; you calculated the rates the way the law suggested. This, because of the scope and scale, really does provide a lot of flexibility to employers and will have different impacts on different employers in different industries, based on the decisions they make.

So let’s quickly run through shared responsibility. There are five key considerations. One is determining ACA full-time status and there are special rules that apply to things like breaks in service and, as I mentioned earlier, nonpaid leaves for FMLA, USERRA, and jury duty, as well as if you have educational employees, teachers, college professors, adjunct professors, making sure that you take into account appropriately periods of time when they are, while will continue to be employees of yours, are not being paid; summer vacation is a, you know, the classic example.

And then you also have the issue around rehires. When you bring back somebody within 26 weeks of their date of termination. Essentially, in that instance, you’ll have to, what I’ll call bridge the service. We’ll take a look at the hours of service they had before they left that are in the measurement, the appropriate measurement. You will, while they were gone, if they come back within less than 26 weeks, they will have a period of time where they have zero hours of service and then they will have new hours of service as of their date of rehire. So these are all considerations in terms of tracking who’s going to be an ACA full-time eligible employee.

You may want to be thinking about management of hours worked. And again, managing it allows you to better control the outcome. And a good example is you may decide that, “We’re going to continue to provide some of our work through part-time employees and were going to now limit those part-time employees to let’s say 24, 27 or 30 hours per week.” The reality is some employees will probably still work more than 30 hours a week because of things like, you know, illness. People call in sick, people quit, people change jobs, sports and activity, and we are recommending strongly that employers look at this, if not every week, certainly on a pay cycle or a monthly basis to ensure that if they have classified people as part-time, they are, in fact, overall keeping them at the appropriate hour level. Now, we won’t have time to get into it in detail today, but failure to do that could trigger an issue under ERISA, Section 510, which basically says it is not acceptable to reduce someone’s hours to deprive them of benefits to which they’d otherwise be eligible, qualified benefits.

Not again, it’s a complex issue. We can certainly, if we have time at the Q&A at the end, I can go into some more detail, but we do think is to avoid those and other issues that employers want to be able to track and keep an eye on part-time hours. Make sure they really are part-time and make sure that overall, there consistently part-time. The coverage availability requirement is probably the most critical consideration that employers have to deal with. The law says you must offer minimum essential coverage to at least 95% of your ACA full-time employees. Failure to do that will almost absolutely guarantee certainty that you will incur the penalty of $2,000, per ACA full-time employee. And that includes people who are enrolled in coverage, so the ability to identify accurately your ACA full-time population and to administratively ensure that you offer coverage to at least 95% of that accurately identified population is going to be critical.

Now, where that can fall down is if you’re not tracking hours of service related to things like unpaid leave. If he unpaid leave results in people being excluded from who you think should be ACA full-time people because you’re not tracking it, and the result is those people should have been counted and you end up offering coverage to less than 95% of the people that should have been counted – if any one of those folks goes to an exchange and gets a subsidy, they trigger the $2,000 penalty on all on all of your ACA full-time employees, minus the first 30. That is a catastrophic occurrence for many employers. Excuse me.

So this is what I’m going to come back to on the next page as well. This is a critical issue. The affordability determination is another one. We’ll talk briefly about that, but essentially the employer cannot charge an employee for individual single coverage more than 9.5% of their W-2 earnings. But keep in mind, that individual single coverage is geared toward the least-expensive plan the employer offers that has at least a 60% actuarial value. Now HHS has a website out there where you can value your plans or your broker or consultant can do that on your behalf. You put the plan provisions in. The tool will in fact kick out a value, and actuarial value, because it’s not as simple as saying my plan pays 60% of expenses.

But having said that, many employers, especially multistate employers, do not have a uniform low cost plan. Some people might have – you know, in California they might be using Kaiser and that potentially could be their low cost plan from an actuarial value point of view. Some people might be in Massachusetts using Harvard Pilgrim. We are recommending, as a best practice that employers put in place a, what we’re calling, a compliance plan. A plan that has a 60% actuarial value and that crosses all states now, the most common version of that is probably going to be a consumer driven plan with an HRA, but that compliance plan will make administration easier. All of your affordability calculations for all of your employees will be triggered by that plan. Your offering calculations will be triggered by that plan. So we really do think it makes sense for employers to be thinking about that.

And then finally, reporting and reconciliation. And we talked briefly about the reporting requirements. I think the reconciliation requirements are also critical. Employers will get penalty assessments, and in many cases, they will not be liable for those penalties. The most easy example for us to illustrate is an example where the employer will determine affordability based on W-2 earnings. And that is one of the safe harbors and that’s the correct way to do it. The exchange is going to determine affordability on the basis of adjusted gross family income. You can easily imagine a situation where an employer determines an employee has affordable coverage, based on their W-2 and is not aware that they are paying deductible alimony and child support and when that employee goes to an exchange, he or she will in fact potentially be eligible for a subsidy, which is likely to trigger a penalty assessment, which will require the employer to go through a reconciliation process after the fact so that they do not have to pay the penalty.

Now, the timing on this is going to be long-term. The exchange enrollment that we described for that particular example will occur in ’15. The employer will generate government reports and employee reports in ’16, and the penalty assessment is not going to come back for calendar ’15 until the summer or fall of calendar ’17. So this is going to be a complex, long-term issue that employers are going to have to deal with.

Now, some changes are some things that employers are doing. In terms of compliance, many employers are making no change at this point to their plans. Some are moving more employees to full-time status, and for employers who have very few part-time employees, this makes sense. It can reduce the administrative costs of tracking hours of service because when you classify people as full-time, you don’t need to track their hours of service. A lot of employers, especially those where there are very significant numbers of part-time employees already, are moving the same or even increased numbers of their employees to part-time status being under 30 hours per week on average, and a very small segment of employers – but it’s there – are terminating coverage. There’s no one right answer here as you think about this. It really comes down to the impact on the business, impact to recruit and attract and retain and engage people, and the ability to actually provide services, and then the cost. The cost of non-deductible penalties versus the cost of providing coverage.

Some of the changes that we’re seeing in plans are things – there’s a clear interest in moving to a defined contribution model. That has been hurt a little bit by Treasury, a think about 10 days ago now, has reiterated their position on the ability to use an HRA to act as a funding vehicle and a defined contribution format and essentially, they said you can’t. They said HRAs have to be provided if they’re going to be pretext and qualified, you have to be provided in conjunction with a structured health care plan. That doesn’t mean you can’t get closer to a defined contribution model, it just means the tool that some consultants were hoping would be there has not been approved. There is more of a move to consumer-driven health care, the idea being if we can lower demand, we will obviously lower utilization. And that is also reflected in the move to more wellness activities tied to lowering demand by not only making people better informed consumers, but by being healthier. And then finally, were seeing a real move towards restricting access. The expanded use of things like dependent audits, spousal limitations – the UPS example I gave earlier – and even increasingly narrow networks, not only within the public exchanges, but with the employer plans.

One of the key – this chart is a key one in terms of providing new guidance. It walks you through the issue of how to avoid a penalty. The first question is are you an applicable large employer. As I said, I think almost everybody on the call today is. The second one is how do you avoid the general $2,000 penalty, the penalty that would apply to all of your employees without exception, if anyone of them goes to an exchange and gets a subsidy?

And there are two requirements for avoiding this penalty. One, that your plan, you have a plan that offers minimum essential coverage. The best way to determine that is to get confirmation from your broker and your insurance carrier that your plans meet the minimum essential coverage requirements. And in fact, I would document most of the new requirements as you go forward. Either your legal documentation or your insurance provider or your administrator providing you written documentation that what you told them to do, in their opinion, meets the requirements.

Second piece of this, in addition to providing minimum essential coverage is again, the offering requirement. Making sure that you’ve offered this minimum essential coverage to at least 95% of your ACA full-time employees. If you cannot do these first two threshold requirements, you should consider canceling your benefit plans because you will end up paying benefit costs for those who enroll and it’s almost 100% certain that you will also end up paying a $2,000 non-deductible penalty on behalf of every one of your ACA full-time people.

So critical consideration here is meeting these two requirements. Once you’ve got past that threshold, you’re looking at a $3,000, what will likely be an individual $3,000 non-deductible penalty. It’s not as certain that it will occur. It only occurs in the event that somebody goes to an exchange and gets a subsidy, and you can avoid it by one, making sure that you have at least a plan that has a minimum 60% actuarial value; and two, making sure that the cost of individual coverage for that low cost plan is affordable to the employee. Now, failing either of those will not necessarily trigger the penalty, but it can and you may want to accrue for that if you know you’re going to fail on either of those for any particular employee.

So for example, an employer could charge me more than 9.5% of my W-2 for the 60% plan, but if I sign up for that plan, there’s no penalty. If I don’t sign up for the plan but get coverage through a spouse, there’s no penalty. Or if I decide not to get coverage at all, there would be no penalty to the employer. So this is more of a question of if you fail these you might incur a penalty, and obviously the more people that you fail to provide either of the requirements for, you will incur, your likelihood increases.

Having said that, it’s important to understand who’s eligible to get a subsidy, because those people will be attracted to the exchanges in the event you fail to provide affordable or minimum essential coverage or 60% coverage and the income levels for people to be eligible for subsidies is extremely high. You can see the chart in front of you. I won’t go through it in detail, but a family of four could qualify for a subsidy with income in 2013 of $94,200. That family of four will be able to have a higher income in 2014 and ’15, since the basis of this calculation is the federal poverty level and it increases with CPI annually.

One other thing to keep in mind is the cost of coverage in the exchanges. We’ve seen a lot of information as the federal exchanges and some of the state exchanges have gone live over the past 8 or 10 days. The key thing to keep in mind here is, though, if they are eligible for subsidies, the cost is going to be the same regardless of which exchange there in. We’ve highlighted the bottom of the page. You can see I’ve highlighted someone making 200% of the federal poverty level. A family of four in that instance, going all the way across to the right, would only have to pay $242 a month for silver level coverage through an exchange. Now that means 200% of the federal poverty level in 2013 is over $47,000. It will be higher in ’14 and ’15. This does create a potential issue for employers and that the cost of their coverage could actually – that they charge employees – the cost of the coverage they charge employees could actually be equal to or higher than the subsidized rate. Having said that, if an employer does meet the requirements and offers qualified coverage, the employee will not be eligible to get a subsidized rate in the exchange.

The look back period we’ve talked about, so I won’t spend time on this chart in the interest of time but you can see that, if you look at the middle of the chart in particular, it begins in the first pay cycle in October. I want to spend one second on the excise tax, before we go to Q&A. The excise tax is going to impact, as I mentioned earlier, probably 60% to 70% of all employer plans, unless they make changes to those plans before 2018.

Now, what is included in the determination of whether you’re going to be subject to the excise tax is employer and employee contributions for health care and prescription drugs. If you’re a self-insured plan, you’ve got to include your ASO fees and your pending and not revealed claim reserves as well. For a self-insured plan, think of the number that you use to create your COBRA rate. That base number is what you’ve got to take into account. It’s not just the claims. But in addition, you’ve got to take into account contributions to an FSA, as well as employer pretax contributions to an HRA or an HSA. All of that gets rolled up into determining what the cost of the coverages that you are providing to employees. And if that cost exceeds $10,200 for individual coverage or $27,500 for family coverage, beginning in 2018, the employer will be subject to a 40% non-deductible excise tax on every dollar above those limits. Now those limits are indexed CPI going forward but it’s important to realize that for the past 48 consecutive years, without a single exception, per capita health care spending has gone up faster than the rate of CPI, so the likelihood is that your costs will increase far faster than CPI, and that’s the issue of why most employer plans are going to bump into these limits.

One other item that you should be aware of is as you bump into these limits, our expectation is employers will, in fact, reduce their benefits. That the financial folks in the organizations will not want to pay, or will not allow us to pay these excise taxes, and it will mean that benefit plans become more and more alike. An example on this page shows you some of the impact. I’ll only look at Example 1, but you can see very simply a company that in 2018 that just marginally exceeds these limits – and this is an employer with 2,000 employees, instead of $10,200, they actually cost them $10,550 for their single people and $28,250 for their family – they’re not a lot over the limits. The impact to that company is over a half-million dollars in a non-deductible excise tax in 2018. Obviously, if the size of the employer increases or the amount that you exceed the limits increase, this will be a significant impact on bottom lines.

This is another illustration, and this is actually the type of analysis we’re recommending employers do. We don’t have time to get through it today in detail, but here what we’ve done is we’ve trended current costs for a particular employer forward on three key trend assumptions, and we’ve compared that to the cap beginning in 2018 on a CPI assumption. And you can see by the chart that in every instance, the employer costs will eventually cross over the cap. The only question is when does it cross over the cap. Does it occur in ’18, ’19, ’20 – but that’s a critical consideration and employers should be thinking about this.

So with that, I’m going to turn it back to Joe and see if we can respond to a few questions. Joe, are you there?

Joe McCafferty: Yes, sorry about that. Again, our guest is John Haslinger, Vice President of ADP’s Strategic Advisory Services, and if you’d like a copy of the slides he’s presented, you can download them from the drop-down menu on the left, bottom left-hand side of your screen. Let’s take some questions from our audience.

John, a very good question here. We’re looking at if an employer lowers full-time employees’ hours to part-time, is the employer liable for doing this in any way and what if those same employees then join the exchanges to the non-coverage from their employer? Is the employer penalized in any way? Can you walk us through that?

John Haslinger: Sure. So again, I want to emphasize that I’m not providing legal advice. I think that’s critical, but our perspective and our understanding, having chatted with this with our regulatory compliance folks, our legal folks as well and outside counsel, is that employers can restructure their workforce any way they choose to. There are no requirements that you have to maintain a certain percentage of your population as full-time people or even the people today who are full-time as full-time. So employers have the flexibility to rethink how they want to provide their goods or services to the marketplace, using the workforce that is the most sense to them. It’s important, as I mentioned earlier, under ERISA, to make sure that if you do classify somebody as a part-time person, that they, in fact, work part time hours and you don’t, at some point during the year, dramatically reduce their hours solely with the intent of avoiding ACA requirements, because that has the potential of triggering class-action activity under ERISA.

But assuming you are doing this for business reasons and you would apply it consistently and you apply it appropriately, we think you can classify any portion of your population as full-time or part-time, depending on your business requirements. Any employee, full-time or part-time, who is not eligible for qualified coverage as ACA defines it – that’s the minimum essential, the 60% actuarial value, and the affordability requirement – if they’re not eligible under those considerations, they can in fact go to a state or the federal exchanges. They can apply for the subsidy and assuming they qualify, based on income and family size, they will be eligible for subsidy but if they were part-time people, there is no penalty, if they’re truly part-time people.

So if they did not meet the ACA full-time requirement of averaging 30 or more hours per week, they go to the exchange and get a subsidy, the employer has no liability. If they did average 30 or more hours a week and keep in mind, that’s going to include their unpaid leave for FMLA, USERRA, and jury duty, then the employer is going to be subject to a penalty. At best case, the penalty would be a $3,000 individual, non-deductible penalty. Worst case is you failed as a result of miscalculation; you failed to offer coverage to at least 95% of your ACA full-time people and one of those people triggered this penalty, and then it becomes a $2,000 penalty on everybody in the organization whose full-time, minus your first 30 employees

Joe McCafferty: I see and another – and I think you addressed this a little bit when you are talking about FSAs, and I think we’re seeing a lot of questions like this out there.

If a small employer cancels their group health plan with the goal of letting employees get insurance and the exchanges, can they then go and reimburse employees for their out-of-pocket medical expenses with tax-free dollars for the employee’s share of the premium?

John Haslinger: And the answer is no. So FSAs have never been allowable to reimburse premiums through. HRAs, in fact, can be utilized to reimburse premiums, but the guidance that has come out, and it’s very consistent, historically, is that for retiree plans, you can utilize an HRA and you can, in fact reimburse premiums. For an active employee situation, that is not going to be permitted. The employer can only offer the HRA on a pretax basis with, in conjunction with a structured health plan. Now, should the employer want to reimburse premiums directly, they would, one, be subject to penalties and the shared responsibility penalties would kick in; and two, the reimbursement would have to be on an after-tax basis.

Joe McCafferty: We’re also getting some questions here about downloading slides, and I’m just going to mention that. There’s a drop-down menu on the bottom that’s on the bottom left-hand side of your screen. You should be able to use that to download the slides.

John, I was wondering if you could give us a sense, a little bit, about how far along you think most companies are with putting their reporting together for the employer mandate. We know that that’s been moved back to January 2015. A lot of companies are breathing a sigh of relief out there. Are they kind of waking up to this massive reporting requirement or how far along do you think most companies are?

John Haslinger: I think they are less far along than they probably need to be. What I’m finding is companies were really scrambling in the spring to get their data in place and in I would say the majority of companies, did not have clean data because again, if this had not been postponed, their data would have had to go back, potentially, until October of ’12, but certainly at least six months prior to their administrative period leading up to their benefit plan year commencing. Many companies were not ready for it and what happened, unfortunately, is some companies misunderstood the delay. In their mind, they were saying, “Okay, the delay means I don’t have to worry about any of this until 2015.” So we are, as we are emphasizing, the look back calculations should be used already for 14, but certainly, even if you decided you’re not going to fully comply because there’s no penalty out there, beginning in ’15, you have to. And in order to do that, you’ve got to be able to track this data probably for most employers, beginning in the first pay cycle in October. And we’re finding a lot of employers are struggling with that. They were not aware that they were going to have ’13 data tracking requirements that were going to impact ’15.

So I think – it’s hard to give you an exact figure because when you ask employers, “Are you ready?” In survey after survey, were getting an increasing number, in fact probably a majority now for saying yes. When you actually sit down and talk to employers about the details, we are finding that even people who are saying yes in many cases were not aware of all the requirements or the timing of the requirements and they’re probably a little less ready than they thought they were.

Joe McCafferty: I see. You also talked – another question here – you talked a little bit about the excise tax. You know we’ve also heard that referred to as the Cadillac tax.

John Haslinger: Yep.

Joe McCafferty: And kind of shocking numbers here. That’s two-thirds of large employees could be subject, employers, sorry, could be subject to that. What’s driving that and do you suspect that as we get closer are to that day, and that’s the 2018 date, I believe –

John Haslinger: Yep.

Joe McCafferty – will the federal government take another look at where those thresholds are, if we’re all understanding what the goal of what that tax is for?

John Haslinger: Sure. Well we have two conflicting issues here. One is the – health care reform is meant to do two things: one is to expand coverage; the other is to help control costs. Health care reform has a number of things built into it to control costs – things like better pricing transparency, emphasis on wellness programs, Medicare panel that’s going to define what is medically effective and what Medicare should pay for it. So there’s a number of cost control components that are built into the system.

Having said that, in 48 years, nothing we or the federal government – we being the federal employers – or the federal government has tried has worked. We have 48 consecutive years, beginning from 1965 right through the present where per capita health care spending and medical CPI, both separate, measured separately, have increased faster than the rate of inflation. So I think the intent of the cap was kind of a line in the sand. That is the things that we’re building into health care reform failed to work. And similar types of strategies have not worked, historically. But they may hopefully, going forward, on a much larger scale. But if they fail to work, the cap was intended to be a stop. That we will not allow health care to consume the economy.

If you go back to 1960, right up through ’65, health care was one percent of GDP. In 1965, with the advent of Medicare and Medicaid, it jumped from 1% to 5.8% today, it’s approaching 20% of GDP. That means one out of every five dollars, almost, in this economy, our derived from, spent on health care. Now, if that trend were to continue, unabated, at some point – and it’s an absurd outcome – you end upwards of 100% of GDP, which would essentially mean as a country, we do nothing but health care. We don’t build automobiles; we don’t have hotels; we have hospitals and we have doctors and other health care providers. We can see that as an absurd outcome. It’s never going to get there, but I think the intent of the cap was when does it break the economy. It’s hurting us at 20%. We’re not competitive in world markets, but probably not breaking the economy. But does the economy collapse when it’s 30% or 40% or 50% or 60%? So I think the intent is very much there as a firewall where you cannot go beyond certain numbers because we know the economy can’t sustain this type of stress.

Now, having said that, the other side of the equation is going to be union plans and richer employer plans and people who have really high cost coverage today, and it’s just because where they live – states like California, New York, Massachusetts – those folks are going to be protesting that they don’t want to see their coverages cut. So there’s going to be a lot of political tension between the idea of controlling costs on the one hand and reducing, essentially by economic force, on the other hand, benefit levels. I don’t want to try to predict who’s going to win that battle, but I do think we’re going to do something to make sure health care costs stop growing as a percent of GDP. I don’t think that’s a sustainable trajectory for us.

Joe McCafferty: John, we’re running out of time here, but I just wanted a couple quick questions. I’m going to ask you to keep your answers brief. One of the questions is the plan year doesn’t start until June 1, does that mean they’ll have until June 1, 2015 to offer ACA full-time employees health care coverage?

John Haslinger: Yeah, the answer is no.

Joe McCafferty (Inaudible) timing on that.

John Haslinger: That’s a really good one and I’m glad you brought that up. I’m (inaudible) the answer’s no. Coverage will have to be – and it’ll be subject to penalties as of January 1, ’15, the intent – again, the expectation by Treasury right now is that employers will voluntarily comply with the law without the threat of penalties. Even if they choose not to, on January 1, ’15, they will be subject to reporting and penalties and even with a fiscal plan year, they should have already been covering those folks, or offering coverage to those folks. So failure to have those people and those enrolled and covered will trigger penalties for those employers.

Joe McCafferty: Another kind of lightning-round question here. The question is about interns, but I’m going to broaden that a little bit. Are there any types of employees that are exempt from this? I know part-time versus full-time is one scenario, but are there other categories of employees that might be exempt, such as interns?

John Haslinger: You have very few categories. The only real meaningful category are very narrowly defined religious exemptions and I’ve got to emphasize they are narrowly defined. Now that’s one of the topics the Supreme Court will be dealing with in this term – are they too narrowly defined? But they are exempt. There is some confusion over a couple of other categories and we chatted earlier as we were preparing for this, but American Indians and native Alaskans are not subject to the individual mandate, but it’s not 100% clear whether or not those employers, American Indian employers on reservations, are subject to shared responsibility. So it is a really – these are narrow, very narrow exceptions. Generally speaking, if you think you’re going to be exempt from this, you probably want to review it with your attorneys but I can assure that 99% of the folks on this call, maybe higher than that, are not going to have any exemptions.

Joe McCafferty: Unfortunately, I think we’re just about out of time here. I’m going to ask one more question. Take us out a year from now, two years from now. Do you expect more delays? Will there be lots of changes to this? Another way to put this is, what do you think it’s a wise compliance strategy to hope that this gets defunded in Congress so we never have to deal with it? I’m going to guess the answer to that is no. But where are we a year from now?

John Haslinger: I think it’s highly unlikely this gets defunded. The Republicans who are trying to do that own one piece of the government at this moment. This is the signature legislative achievement of the Obama administration, whether you think it’s a good idea or a bad idea. The Democrats have been looking for this for over 100 years, so this is a massive political achievement. It’s not going to go away and as people become involved, whether it 6 million people out of the box or it turns out to be 20 million or 30 million or 40 million over the next year or two, we create dependency. And so the people that become enrolled are not going to suddenly – they’re a political block. So we think that this is here to stay.

It may – it’s likely to get changed. We’re likely to see tweaks around the edges. We could see the affordability requirement morph into a funding mandate, for example. We’ve heard some people talk about that, but we don’t think it’s going away. We really do think that the employers are going to be involved, either by penalty assessments or funding requirements. They’re not going to get out of the game. The government will not allow that, as we see it. That health care reform is here to stay. The exchanges are going to be here to stay and in fact, the public exchanges will probably get better over time. The snafus that we’re dealing with right now are likely to get far improved. Whether they ever become as smooth as airline reservation systems or some of the online shopping sites is hard to say, but we anticipate that they’re going to become very acceptable and part of just normal consideration.

So from an employer point of view, I think employers probably want to continue to offer the benefits that they’re offering today by making sure they’re in compliance with the law. They want to look at the emergence of the both public and private exchanges and see if those make sense for them, but I wouldn’t jump out of the box. I wouldn’t do this day one. I’d let them kind of flesh out for a year or so, so that you’re – it’s kind of like the Blackberry/Android/Apple, which one’s going to be a winner or, the old days, Betamax and VHS. You want to make sure that – moving to a new model is going to be expensive and time-consuming. And waiting a year to find out, or even two years to find out which models seem to be the emerging victors, I think works to the benefit of employers, but I think employers will be moving to new models. I think health care reform is a fundamentally transformative event.

Joe McCafferty: Unfortunately, I think we’re going to leave it there, but John, I want to thank you for a very timely, of course, and just a wonderfully informative session here. Everyone, our guest is Vice President of ADP’s Strategic Advisory Services, John Haslinger. And a special thanks, as well, to ADP for making this webcast possible. The webcast has been recorded. It will be available sometime in the next few hours on our website. If you missed anything or you want to go back and check into that, also CPE credit is available to subscribers for our on-demand webcast, if you’re a subscriber, I encourage you to check those out. Tons of very good webcasts in there. You can find those on the webcast tab at www.complianceweek.com.

Once again, to obtain your CPE credit, after this presentation, wait until I finish the wrap up. Make sure you disable any pop-up blockers in order to access the exam. The webcast will close automatically in the final exam will be presented in a separate window. If you have any trouble viewing the CPE test or receiving the CPE certificate, make sure you send an email to info@complianceweek.com to request a copy.

I want to thank everyone for joining us this afternoon and have a great day. Thank you.

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