Sitel Corporation - Redacted Bates HW

Sr. Director, Global Benefits +1 615.301.7118 office +1 615.301.7297 fax jim.flynn@sitel.
com
Sitel
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**CONFIDENTIAL NOTICE** This e-mail and any files transmitted with it may contain PRIVILEGED or CONFIDENTIAL information and may be read or used only by the intended recipient. If you are not the intended recipient of the e-mail or any of its attachments, please be advised that you have received this e-mail in error and that any use, dissemination, distribution, forwarding, printing, or copying of this e-mail or any attached files is strictly prohibited. If you have received this email in error, please immediately purge it and all attachments and notify the sender by reply e-mail.
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Two American Center 3102 West End Avenue, Suite 1000 Nashville, TN 37203 USA +1 877.93LOGIC www.sitel.com
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J im Flynn
file:///T|/...res%20-%20YELLOW/Applications%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Waiver.htm[08/11/2011 3:39:27 PM]
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From: Jim Flynn-HR [Jim.Flynn@sitel.com] Sent: Friday, December 03, 2010 5:34 PM To: HHS HealthInsurance (HHS) Cc: Horrell, James; Ginni Goldsberry-HR Subject: Waiver Attachments: Sitel Corp Cornerstone Plan Waiver Request- Dec 2010.pdf Dear Mr. Mayhew: Attached please find an annual limit waiver request for the Sitel Corporation (EIN 16-1364816), Cornerstone Medical Plan. Please let me know if you have any questions. Kind Regards,
Document obtained by CompleteColorado.com
-------Document obtained by CompleteColorado.com
_._--
SfrEL
December 3,2010
Re: Waiver Via e-mail: healthinsurance@hhs.gov
1.
The plan is affordable primarily because the plan limits total annual benefits to $ Ex. 4
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The plan is funded through a combination of employee contributions and the general assets of Sitel. The plan is not insured through an insurance company but instead is self-insured. As of September, 2010, the Cornerstone plan covers approximately Ex. 4 employees and Ex. 4 members (employees and dependents combined). T ent annual limit for health benefits (medical and prescription drug) is $Ex. 4 The total cost of the plan for the current plan year is estimated to be or approximately $Ex. 4 per employee per month. The rates $Ex. 4 applicable to the Cornerstone Plan for the period July I, 2010 through June 30,2011, are shown below:
Single Employee: $Ex. 4 per m Ex. 4 Employee plus one dependent: $ per month Employee plus two or more dependents: $Ex. 4 per month
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The Cornerstone plan is offered to our new employees, who are generally lower-paid, in order to provide an affordable benefit for their ftrst two years of employment.
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In compliance with the guidance issued on September 3, 2010, from the Health and Human Services Office of Oversight, we are applying for a waiver of the annual limit requirement for the Sitel Corporation (BIN 16-1364816), Cornerstone Plan.
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Attention: James Mayhew
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Sitel:000002
Department ofHealth and Human Services Office of Consumer Information and Insurance Oversight Office of Oversight Room 737-F-04 200 Independence Ave. SW, Washington, DC 20201
SiTEL
4,
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Our actuary's letter is enclosed with this application.
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I, Jim Flynn, Senior Direct of Global Benefits and Plan Administrator, attest that the Cornerstone Plan was in place prior to September 23, 2010, and that that the application of the PPACA required limits to the Cornerstone Plan would result in a significant decrease in access to benefits for those currently covered by such plans or policies, or a significant increase in premiums paid by those covered by such plans or policies.
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The Cornerstone Plan was in force prior to September 23,2010 and the increase in the annual benefit limit to $750,000 will result in a significant decrease in access to these benefits or a significant increase in the premiums paid by the individuals covered by the Cornerstone Plan.
Signed by:
Two American Center, 3102 West End Avenue, Suite 1000 Nashville, Tennessee 37203
+1 615.301.7100T
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+1615.301.7150F
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Compliance with the interim final regulations would require increasing the annual benefit limit per person to at least $750,000, Our current $Ex. 4 actuary has estimated that the increase of the annual limit would increase costs l costs for the Cornerstone plan are by between Ex. 4% and Ex. 4%. Cu expected to be approximately $Ex. 4 The projected increase in costs to $ Ex. 4 noted above would increase annual expenses by $Ex. 4 Site)'s current budgetary restrictions would require that we pass most ofthis additional cost to our employees, which we believe would seriously affect whether the Cornerstone Plan would be affordable.
.IJI~ !:PI'
Sitel:000003
Page 4 redacted for the following reason: --------------------Exemption 4
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Cam Lynne Moultrie Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov
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 full extent of the law.
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From: Moultrie, Cam (HHS/OCIIO) Sent: Friday, December 17, 2010 10:57 AM To: jim.flynn@sitel.com Cc: Habit, Sandra (HHS/OCIIO) Subject: Waiver Application for Sitel Corp Cornerstone Plan Dear Mr. Flynn, Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act) Section 2711. In order to expedite your application, please provide the following information: I. Please complete the entire annual limits spreadsheet, [attached to the email available at: http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an explanation regarding why you are unable to complete that particular cell in a separate document. II. In addition, please provide the following information: Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with grandfathering provisions, pursuant to 45 CFR 147.140? Confirm whether your plan provides any lifetime limits. Confirm whether the plan was created pursuant to the Taft-Hartley Act and, if applicable, the effective and expiration dates of the collective bargaining agreement. In order to complete your application, please provide this information by 5:00 pm, December 21, 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. Thank you.
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Sitel:000005
file:///T|/...cations%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Request%20for%20info%2012.17.10.htm[08/11/2011 3:39:29 PM]
From: Moultrie, Cam (HHS/OCIIO) Sent: Monday, December 20, 2010 5:30 PM To: Moultrie, Cam (HHS/OCIIO); jim.flynn@sitel.com Cc: Habit, Sandra (HHS/OCIIO); claudia.mcgeee@sitel.com Subject: RE: Waiver Application for Sitel Corp Cornerstone Plan
From: Moultrie, Cam (HHS/OCIIO) Sent: Friday, December 17, 2010 10:57 AM To: 'jim.flynn@sitel.com' Cc: Habit, Sandra (HHS/OCIIO) Subject: Waiver Application for Sitel Corp Cornerstone Plan
Dear Mr. Flynn, Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act) Section 2711. In order to expedite your application, please provide the following information: I. Please complete the entire annual limits spreadsheet, [attached to the email available at: http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an explanation regarding why you are unable to complete that particular cell in a separate document. II. In addition, please provide the following information: Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with grandfathering provisions, pursuant to 45 CFR 147.140? Confirm whether your plan provides any lifetime limits. Confirm whether the plan was created pursuant to the Taft-Hartley Act and, if applicable, the effective and expiration dates of the collective bargaining agreement. In order to complete your application, please provide this information by 5:00 pm, December 21, 2010. Once this
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A reminder that I will need this information by tomorrow, Tuesday December 21 st at 5:00 pm, in order to process your application before the holidays. Cam Lynne Moultrie Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov
Sitel:000006
file:///T|/.../Applications%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Corrrespondence%2012.20.10.htm[08/11/2011 3:39:29 PM]
obtained CompleteColorado.com information is received and the applicationDocument is complete, itby 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. Thank you.
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file:///T|/.../Applications%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Corrrespondence%2012.20.10.htm[08/11/2011 3:39:29 PM]
From: Jim Flynn-HR [Jim.Flynn@sitel.com] Sent: Tuesday, December 21, 2010 5:49 PM To: Moultrie, Cam (HHS/OCIIO) Cc: Habit, Sandra (HHS/OCIIO) Subject: RE: Waiver Application for Sitel Corp Cornerstone Plan Attachments: Copy of Copy of waiver_application_form sitel.xls
The plan DOES have a lifetime limit of $ Ex. 4
limit).
Please let me know if you have any further questions. Regards,

J im Flynn
Sr. Director, Global Benefits +1 615.301.7118 office +1 615.301.7297 fax jim.flynn@sitel.com
From: Moultrie, Cam (HHS/OCIIO) [mailto:Cam.Moultrie@hhs.gov] Sent: Friday, December 17, 2010 9:57 AM To: Jim Flynn-HR Cc: Habit, Sandra (HHS/OCIIO) Subject: Waiver Application for Sitel Corp Cornerstone Plan
Dear Mr. Flynn, Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act) Section 2711. In order to expedite your application, please provide the following information: I. Please complete the entire annual limits spreadsheet, [attached to the email available at: http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an explanation regarding why you are unable to complete
Sitel:000008
file:///T|/...ith%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Reqeust%20for%20info%20response%2012.21.10.htm[08/11/2011 3:39:29 PM]
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, but the annual limit is $ Ex. 4 only Ex. years. As a practical matter, the limit is $ per year. 4 The plan was NOT created pursuant tothe Taft-Hartley Act.
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Ex. 4
Hi Cam, per your request, attached please find the completed annual limits spreadsheet to accompany our waiver application. As a point of clarification the plan in question does have coinsurance rate of Ex. 4% company/ Ex. 4% employee. I mention this because it was not immediately clear which side of the equation was represented on the file. In addition, please find below the answers to your other questions: The plan was in existence prior to 3/23/10, but is NOT grandfathered (the OV copay increase on 7/1/10 exceeded the $Ex. 4
and employees can enroll in the plan for
obtained by CompleteColorado.com that particular cell in a separateDocument document. II. In addition, please provide the following information:
Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with grandfathering provisions, pursuant to 45 CFR 147.140? Confirm whether your plan provides any lifetime limits. Confirm whether the plan was created pursuant to the Taft-Hartley Act and, if applicable, the effective and expiration dates of the collective bargaining agreement.
In order to complete your application, please provide this information by 5:00 pm, December 21, 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. Thank you.
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Sitel:000009
file:///T|/...ith%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Reqeust%20for%20info%20response%2012.21.10.htm[08/11/2011 3:39:29 PM]
From: Jim Flynn-HR [Jim.Flynn@sitel.com] Sent: Tuesday, December 21, 2010 9:09 AM To: Moultrie, Cam (HHS/OCIIO) Cc: Habit, Sandra (HHS/OCIIO); claudia.mcgeee@sitel.com Subject: RE: Waiver Application for Sitel Corp Cornerstone Plan
Thank you very much. Im reviewing our responses right now and will have them to you by tomorrow afternoon. Kind Regards,
J im Flynn
Sitel
From: Moultrie, Cam (HHS/OCIIO) Sent: Friday, December 17, 2010 10:57 AM To: 'jim.flynn@sitel.com' Cc: Habit, Sandra (HHS/OCIIO) Subject: Waiver Application for Sitel Corp Cornerstone Plan
Dear Mr. Flynn, Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act
Sitel:000010
file:///T|/.../Applications%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Correspondence%2012.21.10.htm[08/11/2011 3:39:30 PM]
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A reminder that I will need this information by tomorrow, Tuesday December 21 st at 5:00 pm, in order to process your application before the holidays. Cam Lynne Moultrie Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov
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From: Moultrie, Cam (HHS/OCIIO) [mailto:Cam.Moultrie@hhs.gov] Sent: Monday, December 20, 2010 4:30 PM To: Moultrie, Cam (HHS/OCIIO); Jim Flynn-HR Cc: Habit, Sandra (HHS/OCIIO); claudia.mcgeee@sitel.com Subject: RE: Waiver Application for Sitel Corp Cornerstone Plan
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Document by CompleteColorado.com (PHS Act) Section 2711. In order to expedite yourobtained application, please provide the following information: I. Please complete the entire annual limits spreadsheet, [attached to the email available at: http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an explanation regarding why you are unable to complete that particular cell in a separate document. II. In addition, please provide the following information: Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with grandfathering provisions, pursuant to 45 CFR 147.140? Confirm whether your plan provides any lifetime limits. Confirm whether the plan was created pursuant to the Taft-Hartley Act and, if applicable, the effective and expiration dates of the collective bargaining agreement. In order to complete your application, please provide this information by 5:00 pm, December 21, 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. Thank you.
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file:///T|/.../Applications%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Correspondence%2012.21.10.htm[08/11/2011 3:39:30 PM]
From: Moultrie, Cam (HHS/OCIIO) Sent: Wednesday, December 22, 2010 10:47 AM To: Jim Flynn-HR Cc: Habit, Sandra (HHS/OCIIO) Subject: RE: Waiver Application for Sitel Corp Cornerstone Plan Thank you for the information.
In your application, your plan(s) or policy(ies) provide a lifetime limit. Pursuant to Section 2711 of the PHS Act, you may not have any lifetime limit on your plan as of September 23, 2010, except in the case of non-essential benefits that are permitted under Federal or State law. Plans that previously had a lifetime limit may add an annual limit not less than the lifetime limit without affecting the grandfather status of the plan. Please confirm whether this lifetime limit will be eliminated from your plan.
From: Jim Flynn-HR [mailto:Jim.Flynn@sitel.com] Sent: Tuesday, December 21, 2010 5:49 PM To: Moultrie, Cam (HHS/OCIIO) Cc: Habit, Sandra (HHS/OCIIO) Subject: RE: Waiver Application for Sitel Corp Cornerstone Plan
limit). The plan DOES have a lifetime limit of $ Ex. 4 , but the annual limit is $Ex. 4 Ex. 4 4 only years. As a practical matter, the limit is $ per year. The plan was NOT created pursuant tothe Taft-Hartley Act.
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Hi Cam, per your request, attached please find the completed annual limits spreadsheet to accompany our waiver application. Ex. 4% employee. I mention this As a point of clarification the plan in question does have coinsurance rate of Ex. 4 % company/ because it was not immediately clear which side of the equation was represented on the file. In addition, please find below the answers to your other questions: The plan was in existence prior to 3/23/10, but is NOT grandfathered (the OV copay increase on 7/1/10 exceeded the $4
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J im Flynn
Sr. Director, Global Benefits
Sitel:000012
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and employees can enroll in the plan for
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+1 615.301.7118 office +1 615.301.7297 fax jim.flynn@sitel.com
Sitel

Dear Mr. Flynn, Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act) Section 2711. In order to expedite your application, please provide the following information: I. Please complete the entire annual limits spreadsheet, [attached to the email available at: http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an explanation regarding why you are unable to complete that particular cell in a separate document. II. In addition, please provide the following information: Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with grandfathering provisions, pursuant to 45 CFR 147.140? Confirm whether your plan provides any lifetime limits. Confirm whether the plan was created pursuant to the Taft-Hartley Act and, if applicable, the effective and expiration dates of the collective bargaining agreement. In order to complete your application, please provide this information by 5:00 pm, December 21, 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. Thank you.
Cam Lynne Moultrie Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services (301) 492-4174
Sitel:000013
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cam.moultrie@hhs.gov
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From: Jim Flynn-HR [Jim.Flynn@sitel.com] Sent: Wednesday, December 22, 2010 11:00 AM To: Moultrie, Cam (HHS/OCIIO) Cc: Habit, Sandra (HHS/OCIIO) Subject: RE: Waiver Application for Sitel Corp Cornerstone Plan
Hi Cam, our plan year is from July 1 through June 30. The lifetime limit will be removed as of July 1, which is the beginning of the first plan year following September 23, 2010. Kind Regards, Jim
From: Moultrie, Cam (HHS/OCIIO) [mailto:Cam.Moultrie@hhs.gov] Sent: Wednesday, December 22, 2010 9:47 AM To: Jim Flynn-HR Cc: Habit, Sandra (HHS/OCIIO) Subject: RE: Waiver Application for Sitel Corp Cornerstone Plan
Thank you for the information.
Hi Cam, per your request, attached please find the completed annual limits spreadsheet to accompany our waiver application. As a point of clarification the plan in question does have coinsurance rate of Ex. 4% company/ Ex. 4% employee. I mention this because it was not immediately clear which side of the equation was represented on the file. In addition, please find below the answers to your other questions:
Sitel:000015
file:///T|/...ith%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Request%20for%20info%20response%2012.22.10.htm[08/11/2011 3:39:31 PM]
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In your application, your plan(s) or policy(ies) provide a lifetime limit. Pursuant to Section 2711 of the PHS Act, you may not have any lifetime limit on your plan as of September 23, 2010, except in the case of non-essential benefits that are permitted under Federal or State law. Plans that previously had a lifetime limit may add an annual limit not less than the lifetime limit without affecting the grandfather status of the plan. Please confirm whether this lifetime limit will be eliminated from your plan.
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limit).
The plan was in existence prior to 3/23/10, but is NOT grandfathered (the OV copay increase on 7/1/10 exceeded the $4 The plan DOES have a lifetime limit of $Ex. 4
, but the annual limit is $Ex. 4 only Ex. years. As a practical matter, the limit is $Ex. 4 per year. 4 The plan was NOT created pursuant tothe Taft-Hartley Act. and employees can enroll in the plan for

J im Flynn
Sitel
Dear Mr. Flynn, Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act) Section 2711. In order to expedite your application, please provide the following information: I. Please complete the entire annual limits spreadsheet, [attached to the email available at: http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an explanation regarding why you are unable to complete that particular cell in a separate document. II. In addition, please provide the following information: Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with grandfathering provisions, pursuant to 45 CFR 147.140? Confirm whether your plan provides any lifetime limits. Confirm whether the plan was created pursuant to the Taft-Hartley Act and, if applicable, the effective and expiration dates of the collective bargaining agreement.
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Sitel:000016
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Document obtained CompleteColorado.com In order to complete your application, please provide this by information by 5:00 pm, December 21, 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. Thank you.
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**CONFIDENTIAL NOTICE** This e-mail and any files transmitted with it may contain PRIVILEGED or CONFIDENTIAL information and may be read or used only by the intended recipient. If you are not the intended recipient of the e-mail or any of its attachments, please be advised that you have received this e-mail in error and that any use, dissemination, distribution, forwarding, printing, or copying of this e-mail or any attached files is strictly prohibited. If you have received this email in error, please immediately purge it and all attachments and notify the sender by reply e-mail. **CONFIDENTIAL NOTICE** This e-mail and any files transmitted with it may contain PRIVILEGED or CONFIDENTIAL information and may be read or used only by the intended recipient. If you are not the intended recipient of the e-mail or any of its attachments, please be advised that you have received this e-mail in error and that any use, dissemination, distribution, forwarding, printing, or copying of this e-mail or any attached files is strictly prohibited. If you have received this email in error, please immediately purge it and all attachments and notify the sender by reply e-mail.
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Sitel:000017
ANNUAL LIMIT WAIVER APPLICATION 2010
PRA Disclosure Statement
According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless it displays a valid OMB control number. The valid OMB control number for this information collection is 0938-1105. The time required to complete this information collection is estimated to average ( 8 hours) or ( 240 minutes) per response, including the time to review instructions, search existing data resources, gather the data needed, and complete and review the information collection. If you have comments concerning the accuracy of the time estimate(s) or suggestions for improving this form, please write to: CMS, 7500 Security Boulevard, Attn: PRA Reports Clearance Officer, Mail Stop C4-26-05, Baltimore, Maryland 21244-1850.
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Policy Name Annual Limit Waiver (use a new row for each Applicant Request (Plan/ Policy policy Applicant application) Situs) City Name Applicant ABC Plan 1 Washington Applicant ABC Plan 1 Washington Sitel, Inc. Cornerstone Pla Nashville Cornerstone Pla Nashville Sitel, Inc. Sitel Inc. Sitel, Inc Cornerstone Pla Nashville
Applicant (Plan/ Plan/ Policy Policy Effective Date Contact Situs) (mm/dd/yyyy) Name State DC DC TN TN TN 01/01/2011 01/01/2011 07/01/2010 07/01/2010 07/01/2010 Jane Doe Jane Doe Jim Flynn Jim Flynn Jim Flynn
Street Address City State 100 ABC Drive Washington DC 100 ABC Drive Washington DC 2 West End Av Nashville TN 2 West End Av Nashville TN 2 West End Av Nashville TN
Phone Number (including Email Zip Code area code) Address 1-800-ABC- abc@abchea 20201 1234 lthplan.com Limited Benefit 1-800-ABC- abc@abchea lthplan.com Limited Benefit 20202 1234 37203 1-615-301-711 m.flynn@sitel.co Other 37203 1-615-301-711 m.flynn@sitel.co Other 37203 1-615-301-711 m.flynn@sitel.co flynn@sitel co Other
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Yes Yes Yes Yes Yes
Total Number of Individuals Current Covered by Type of Plan Overall Policy Coverage Annual (include all Self(e.g., Limited Limit (in Benefit, HRA, Insured Individual or dependents dollars) Rx only, Other) (Yes/No) Group Policy covered) Group Group Group Group Group 4,000 2,500 $100,000 $100,000
Ex. 4
Sitel:000018
Ambulatory None None None None None
Emergency None None None None None
Hospitalization None None None None None
Laboratory None None None None None
Pediatric None None None None None
Maternity/ Newborn None None None None None
Mental Health/ Substance Abuse None None None None None
Rehabilitative/ Devices None None None None None
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Preventive/ Wellness None Prescription $3,000.00 $3,000.00 None None None $500.00
Current Essential Benefits Annual Limits (Annual Limit for Each Essential Benefit)
Office Visit Hospital Inpatient Emergency Room Rx Copays/Coinsurance Copay/Coinsurance Copay/Coinsurance Copay/Coninsurance
Coinsura Coinsura Copay (if Coinsuranc Copay (if nce (if Copay (if nce (if Copay (if Coinsuran ce (if applicabl applicabl applicabl applicabl applicabl e (if applicabl Plan applicable) e) e) e) e) e) applicable) e) Deductible $15.00 50.00% 50.00% $100.00 $100.00 50.00% 50.00% $100.00 $100.00 50.00% 50.00% $10.00 $10.00 None None
Ex. 4
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None None None None
$1,000.00
$15.00
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Total $925.00 21.71%
Ex. 4
Current Monthly Premium Rates or Premium Equivalent Rates (in dollars)*:
Projected Rate Increase that would result Renewal Monthly Premium Rates or from compliance with $750,000 Annual Limit Premium Equivalent Rates if Waiver Granted Restriction (in dollars) (Average Premium (in dollars)* by Individual)*
Employer Employee Individual/ Employee contribution contribution (if applicable) (if applicable) Tier* Employee Employee + Family Employee Employee + 1 Employee + 2 $100.00 $600.00
Total $700.00
Employer Employee contribution contribution (if applicable) (if applicable) $110.00 $650.00
Total $760.00
Employer Employee contribution contribution (if applicable) (if applicable) $125.00 $800.00
Decrease in Access to Benefits that Projected Rate Increase would result that would result from from compliance with $750,000 compliance Annual Limit Restriction with $750,000 (in dollars)(Average Annual Limit Premium by Individual) Restriction (Difference of Column AT (describe and AQ divided by briefly in cell Column AQ) or in a None
Plan Administr ator/ CEO of Health Insuranc e Issuer Name Jane Doe Jane Doe Jim Flynn Jim Flynn Jim Flynn
Title of Individual Providing Attestation Plan Administrator Plan Administrator Plan Administrator Plan Administrator Plan Administrator
* When completing the columns requesting premium rate information, please express the premium rates as a composite rate (if premiums are a range based on years of service or age) and by tier (Employee, Employee + Spouse, Employee + Child, Family, etc.) as applicable. If you are an issuer, please provide the premium amount in the column titled, "Total" (Column AN, AQ and AT).
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None costly for emplo costly for emplo costly for emplo
Sitel:000020
From: Moultrie, Cam (HHS/OCIIO) Sent: Tuesday, December 28, 2010 10:25 AM To: Habit, Sandra (HHS/OCIIO) Subject: FW: Waiver Application for Sitel Corp Cornerstone Plan
From: Moultrie, Cam (HHS/OCIIO) Sent: Tuesday, December 28, 2010 10:25 AM To: 'Jim Flynn-HR' Subject: RE: Waiver Application for Sitel Corp Cornerstone Plan
From: Jim Flynn-HR [mailto:Jim.Flynn@sitel.com] Sent: Wednesday, December 22, 2010 11:00 AM To: Moultrie, Cam (HHS/OCIIO) Cc: Habit, Sandra (HHS/OCIIO) Subject: RE: Waiver Application for Sitel Corp Cornerstone Plan
Hi Cam, our plan year is from July 1 through June 30. The lifetime limit will be removed as of July 1, which is the beginning of
Sitel:000021
file:///T|/...LOW/Applications%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Completion%2012.28.10.htm[08/11/2011 3:39:32 PM]
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Thank you for your information. Your application is now complete and you will receive a determination of your application within 30 days. Thank you.
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Document obtained by CompleteColorado.com the first plan year following September 23, 2010. Kind Regards, Jim
From: Moultrie, Cam (HHS/OCIIO) [mailto:Cam.Moultrie@hhs.gov] Sent: Wednesday, December 22, 2010 9:47 AM To: Jim Flynn-HR Cc: Habit, Sandra (HHS/OCIIO) Subject: RE: Waiver Application for Sitel Corp Cornerstone Plan
Thank you for the information. In your application, your plan(s) or policy(ies) provide a lifetime limit. Pursuant to Section 2711 of the PHS Act, you may not have any lifetime limit on your plan as of September 23, 2010, except in the case of non-essential benefits that are permitted under Federal or State law. Plans that previously had a lifetime limit may add an annual limit not less than the lifetime limit without affecting the grandfather status of the plan. Please confirm whether this lifetime limit will be eliminated from your plan.
Hi Cam, per your request, attached please find the completed annual limits spreadsheet to accompany our waiver application. As a point of clarification the plan in question does have coinsurance rate of Ex. 4% company/ Ex. 4% employee. I mention this because it was not immediately clear which side of the equation was represented on the file. In addition, please find below the answers to your other questions: The plan was in existence prior to 3/23/10, but is NOT grandfathered (the OV copay increase on 7/1/10 exceeded the $Ex. 4
limit). The plan DOES have a lifetime limit of $ Ex. 4 the annual limit is $ Ex. 4 Ex. 4 only Ex. per year. 4 years. As a practical matter, the limit is $ The plan was NOT created pursuant tothe Taft-Hartley Act. and employees can enroll in the plan for
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Sitel:000022
Document obtained by CompleteColorado.com Please let me know if you have any further questions. Regards,
J im Flynn
Sitel

Dear Mr. Flynn, Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act) Section 2711. In order to expedite your application, please provide the following information: I. Please complete the entire annual limits spreadsheet, [attached to the email available at: http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an explanation regarding why you are unable to complete that particular cell in a separate document. II. In addition, please provide the following information: Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with grandfathering provisions, pursuant to 45 CFR 147.140? Confirm whether your plan provides any lifetime limits. Confirm whether the plan was created pursuant to the Taft-Hartley Act and, if applicable, the effective and expiration dates of the collective bargaining agreement. In order to complete your application, please provide this information by 5:00 pm, December 21, 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. Thank you.
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Sitel:000023
Document obtained by CompleteColorado.com Cam Lynne Moultrie Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services (301) 492-4174 cam.moultrie@hhs.gov
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**CONFIDENTIAL NOTICE** This e-mail and any files transmitted with it may contain PRIVILEGED or CONFIDENTIAL information and may be read or used only by the intended recipient. If you are not the intended recipient of the e-mail or any of its attachments, please be advised that you have received this e-mail in error and that any use, dissemination, distribution, forwarding, printing, or copying of this e-mail or any attached files is strictly prohibited. If you have received this email in error, please immediately purge it and all attachments and notify the sender by reply e-mail. **CONFIDENTIAL NOTICE** This e-mail and any files transmitted with it may contain PRIVILEGED or CONFIDENTIAL information and may be read or used only by the intended recipient. If you are not the intended recipient of the e-mail or any of its attachments, please be advised that you have received this e-mail in error and that any use, dissemination, distribution, forwarding, printing, or copying of this e-mail or any attached files is strictly prohibited. If you have received this email in error, please immediately purge it and all attachments and notify the sender by reply e-mail.
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Sitel:000024
From: Habit, Sandra (HHS/OCIIO) Sent: Thursday, December 30, 2010 3:50 PM To: 'jim.flynn@sitel.com' Subject: Sitel, Inc. Approval Letter for a Waiver of the Annual Limits Requirements 12-30-2010 Importance: High Attachments: Updated Jan 1 Approval Letter .pdf Good Afternoon, Thank you for submitting an application for a Waiver of the Annual Limits Requirements of the PHS Act Section 2711 for Sitel, Inc. HHS has reviewed your application and made its determination. Please see 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 Habit Department of Health and Human Services Office of Consumer Information and Insurance Oversight 301-492-4175 Sandra.Habit@hhs.gov
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 disclosures may result in prosecution to the full extent of the law.
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Sitel:000025
file:///T|/...Inc.%20Approval%20Letter%20for%20a%20Waiver%20of%20the%20Annual%20Limits%20Requirements%2012-30-2010.htm[08/11/2011 3:39:32 PM]
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Sitel:000026
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Sitel:000027
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From: Jim Flynn-HR [Jim.Flynn@sitel.com] Sent: Monday, January 03, 2011 10:13 AM To: Habit, Sandra (HHS/OCIIO) Subject: RE: Sitel, Inc. Approval Letter for a Waiver of the Annual Limits Requirements 12-30-2010
Ms Habit: Thank you for your approval. I noticed in the approval letter the effective date of this waiver is January 1, 2011 to January 1, 2012. Our actual policy year is July 1, 2011 to July 1, 2012. My understanding is the annual limits requirement is effective on the first policy year beginning on or after September 23, 2010. Will this waiver apply to our entire policy year beginning on July 1, 2011? Kind Regards,
J im Flynn
Sitel
Good Afternoon, Thank you for submitting an application for a Waiver of the Annual Limits Requirements of the PHS Act Section 2711 for Sitel, Inc. HHS has reviewed your application and made its determination. Please see 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

Sitel:000028
file:///T|/...Applications%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Approval%20receipt%201.3.11.htm[08/11/2011 3:39:28 PM]
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From: Habit, Sandra (HHS/OCIIO) [mailto:Sandra.Habit@hhs.gov] Sent: Thursday, December 30, 2010 2:50 PM To: Jim Flynn-HR Subject: Sitel, Inc. Approval Letter for a Waiver of the Annual Limits Requirements 12-30-2010 Importance: High
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From: Habit, Sandra (HHS/OCIIO) Sent: Monday, January 03, 2011 4:03 PM To: 'Jim Flynn-HR' Subject: RE: Sitel, Inc. Approval Letter for a Waiver of the Annual Limits Requirements 12-30-2010 Attachments: July 1 .pdf
Mr. Flynn, My apologies. I have attached the July 1, 2011 approval letter. Please let me know if I can be of any further assistance. Thank you, Sandy From: Jim Flynn-HR [mailto:Jim.Flynn@sitel.com] Sent: Monday, January 03, 2011 10:13 AM To: Habit, Sandra (HHS/OCIIO) Subject: RE: Sitel, Inc. Approval Letter for a Waiver of the Annual Limits Requirements 12-30-2010
Sitel
From: Habit, Sandra (HHS/OCIIO) [mailto:Sandra.Habit@hhs.gov] Sent: Thursday, December 30, 2010 2:50 PM To: Jim Flynn-HR Subject: Sitel, Inc. Approval Letter for a Waiver of the Annual Limits Requirements 12-30-2010 Importance: High
Good Afternoon, Thank you for submitting an application for a Waiver of the Annual Limits Requirements of the PHS Act Section 2711 for Sitel, Inc. HHS has reviewed your application and made its determination. Please see the attached letter.
Sitel:000029
file:///T|/...20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Approval%20receipt%20corrected%201.3.11.htm[08/11/2011 3:39:33 PM]
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Ms Habit: Thank you for your approval. I noticed in the approval letter the effective date of this waiver is January 1, 2011 to January 1, 2012. Our actual policy year is July 1, 2011 to July 1, 2012. My understanding is the annual limits requirement is effective on the first policy year beginning on or after September 23, 2010. Will this waiver apply to our entire policy year beginning on July 1, 2011? Kind Regards,
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Document obtained by CompleteColorado.com Please confirm receipt of this letter by replying to this e-mail. Please let me know if I can be of further assistance. Sincerely
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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 disclosures may result in prosecution to the full extent of the law.
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Sitel:000030
file:///T|/...20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Approval%20receipt%20corrected%201.3.11.htm[08/11/2011 3:39:33 PM]

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Sr. Director, Global Benefits +1 615.301.7118 office +1 615.301.7297 fax jim.flynn@sitel.

file:///T|/...res%20-%20YELLOW/Applications%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Waiver.htm[08/11/2011 3:39:27 PM]

Document obtained by CompleteColorado.com

-------Document obtained by CompleteColorado.com

Re: Waiver Via e-mail: healthinsurance@hhs.gov

Attention: James Mayhew

Document obtained by CompleteColorado.com

Our actuary's letter is enclosed with this application.

Document obtained by CompleteColorado.com

Page 4 redacted for the following reason: --------------------Exemption 4

Document obtained by CompleteColorado.com

file:///T|/...cations%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Request%20for%20info%2012.17.10.htm[08/11/2011 3:39:29 PM]

Document obtained by CompleteColorado.com

file:///T|/.../Applications%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Corrrespondence%2012.20.10.htm[08/11/2011 3:39:29 PM]

file:///T|/.../Applications%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Corrrespondence%2012.20.10.htm[08/11/2011 3:39:29 PM]

Document obtained by CompleteColorado.com

The plan DOES have a lifetime limit of $ Ex. 4

Please let me know if you have any further questions. Regards,

file:///T|/...ith%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Reqeust%20for%20info%20response%2012.21.10.htm[08/11/2011 3:39:29 PM]

file:///T|/...ith%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Reqeust%20for%20info%20response%2012.21.10.htm[08/11/2011 3:39:29 PM]

Document obtained by CompleteColorado.com

file:///T|/.../Applications%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Correspondence%2012.21.10.htm[08/11/2011 3:39:30 PM]

file:///T|/.../Applications%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Correspondence%2012.21.10.htm[08/11/2011 3:39:30 PM]

Document obtained by CompleteColorado.com

Please let me know if you have any further questions. Regards,

file:///T|/...cations%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Request%20for%20info%2012.22.10.htm[08/11/2011 3:39:30 PM]

+1 615.301.7118 office +1 615.301.7297 fax jim.flynn@sitel.com

Document obtained by CompleteColorado.com

file:///T|/...cations%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Request%20for%20info%2012.22.10.htm[08/11/2011 3:39:30 PM]

Document obtained by CompleteColorado.com

file:///T|/...cations%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Request%20for%20info%2012.22.10.htm[08/11/2011 3:39:30 PM]

Document obtained by CompleteColorado.com

Thank you for the information.

file:///T|/...ith%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Request%20for%20info%20response%2012.22.10.htm[08/11/2011 3:39:31 PM]

Document obtained by CompleteColorado.com

Please let me know if you have any further questions. Regards,

file:///T|/...ith%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Request%20for%20info%20response%2012.22.10.htm[08/11/2011 3:39:31 PM]

Sr. Director, Global Benefits +1 615.301.7118 office +1 615.301.7297 fax jim.flynn@sitel.com

file:///T|/...ith%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Request%20for%20info%20response%2012.22.10.htm[08/11/2011 3:39:31 PM]

Document obtained by CompleteColorado.com

ANNUAL LIMIT WAIVER APPLICATION 2010

PRA Disclosure Statement

Document obtained by CompleteColorado.com

ANNUAL LIMIT WAIVER APPLICATION 2010

Ambulatory None None None None None

Emergency None None None None None

Hospitalization None None None None None

Laboratory None None None None None

Pediatric None None None None None

Maternity/ Newborn None None None None None

Mental Health/ Substance Abuse None None None None None

Rehabilitative/ Devices None None None None None

None None None None

Document obtained by CompleteColorado.com

ANNUAL LIMIT WAIVER APPLICATION 2010

Current Monthly Premium Rates or Premium Equivalent Rates (in dollars)*:

Document obtained by CompleteColorado.com

file:///T|/...LOW/Applications%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Completion%2012.28.10.htm[08/11/2011 3:39:32 PM]

file:///T|/...LOW/Applications%20with%20NO%2012600%20Response%20[YELLOW]/Sitel%20Corporation/Completion%2012.28.10.htm[08/11/2011 3:39:32 PM]