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Healthcare: What You Need To Know

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Healthcare: What You Need To Know

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    2. Overview of Session Content Mike McCallum Chief Strategy Officer National Restaurant Association

    3. AGENDA Overview of session content A marketplace perspective – factors that brought us where we are What the law says now Business Implications for the restaurant industry What NRA is doing What Paths are Smart People Taking? Q and A

    4. A Marketplace Perspective: Factors That Brought Us Where We Are Randy Spicer Restaurant Industry Project Leader United Healthcare

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    6. PUBLIC POLICY CONTEXT Scott Defife Executive Vice President Public Policy National Restaurant Association

    7. Health Care History 2008 Strategic Plan - Illustrated Need for NRA to focus on Health Care Escalating costs Attract and retain employees March 2009 – Began search for industry partner June 2009 – Began discussions with United Health Care Summer and Fall 2009 – Health Care Reform hotly debated March 2010 – Reform passes

    8. Five Key Priorities 1. Protect the part-time worker exemption from any total employee calculation or penalties. Protect small business with as robust an exemption as possible. 3. Secure a 90-day waiting period before employer requirements begin. Modify the definition of full-time employee as one working 390 hours/calendar quarter (13 weeks). Defend current ERISA protections for multi-state employers.

    9. Overview and Status H.R. 3590, Patient Protection and Affordable Care Act, signed by President into law (PL 111-148) on March 23, 2010. H.R. 4872, the Health Care and Education Reconciliation Act of 2010, modified PL 111-148 and signed into law on March 30, 2010. Over the next several years, federal and state agencies will write regulations to clarify and implement the law. For example: Dept. of Labor, Dept. of Health and Human Services, Internal Revenue Service. The Association will be actively engaged in the regulatory process.

    10. Implementation Timeline

    11. Implementation Timeline 2010 Small business tax credit available 1/1/2010. HHS informational website established – 7/1/2010. Grandfathered plans – some changes required for plan years beginning after 9/23/2010. 2011 Employer report health care coverage costs on W-2 forms – Applies to tax years beginning after 12/31/2010. Flexible Spending Account contribution limits begin – no more than $2500, Begins 2011, indexed in 2013. Over-the-counter medicines may no longer be reimbursed under HRAs, HSAs, FSAs beginning 1/1/2011. Increased penalty to 20% for non-qualified medical expenses from HSAs/Archer MSAs, Begins 1/1/2011.

    12. Implementation Timeline (cont’d) 2012 Employer 1099 reporting for payments >$600 to corporate providers of property and services. Applies after 12/31/2011. 2013 Medicare Contribution Tax (3.8%) now applied on unearned income (over $200K/$250K) Begins 1/1/2013. Increase in Medicare Hospital Insurance Tax for $200k/$250K taxpayers. Employee pays entire .9% increase in tax. Begins 1/1/2013. All employers must provide employees written notice about exchanges, how to contact exchange, etc. Begins 3/1/2013.

    13. Implementation Timeline (cont’d) 2014 Exchanges open in each state for individual and small group markets. Individual mandate begins Employer responsibilities begin 90 day waiting period allowed Automatic enrollment for employers with 200+ employees Grandfathered plans – further insurance reforms apply 2017 Large employer participation in exchanges allowed; requires state-by-state action.

    14. What Does The Law Require? Scott What we are presenting here today is the best information we know as of right now. As guidance and regulations are developed over the next several years and beyond, more details will become known. Think of the bill that passed as the outline, and the regulatory process as filling in all the details. But we know you don’t have the luxury of the years it will take to develop the regulations and you need to start thinking about how this will impact your business now. Which is why we are here talking about this new law today. What we will present today is meant to give you a general understanding of what is in this massive new law and how it could impact your businesses. Nothing we say here today should be considered legal or financial guidance or advice.Scott What we are presenting here today is the best information we know as of right now. As guidance and regulations are developed over the next several years and beyond, more details will become known. Think of the bill that passed as the outline, and the regulatory process as filling in all the details. But we know you don’t have the luxury of the years it will take to develop the regulations and you need to start thinking about how this will impact your business now. Which is why we are here talking about this new law today. What we will present today is meant to give you a general understanding of what is in this massive new law and how it could impact your businesses. Nothing we say here today should be considered legal or financial guidance or advice.

    15. What ALL Restaurateurs Need to Know Grandfathered Plans: Plan that existed as of 3/23/2010, not subject to some of the changes in the law. Exchanges: Marketplace for individual and small group plans, to be set up by each State. Notification Requirements: All employers must provide written notice at the time of hiring about the exchange (3/1/2013) Disclose the value of health benefits on W-2 form (2011) 1099 Reporting: Issue for any amount greater than $600 to corporate providers of property and services (2012) Scott Regardless of whether the employer requirements for coverage or liability for penalties applies to you, there are things that every employer needs to know. Grandfathered plan: We expect guidance from HHS very soon. (i.e. how to maintain status, what you can change in the plan without loosing status) Exchange: This is where individuals can use premium tax credits (subsidies) to access minimum essential coverage. Small businesses will also be able to buy coverage for their employees there as well. 1099 Reporting : we Expect IRS to issue guidance in this area soon.Scott Regardless of whether the employer requirements for coverage or liability for penalties applies to you, there are things that every employer needs to know. Grandfathered plan: We expect guidance from HHS very soon. (i.e. how to maintain status, what you can change in the plan without loosing status) Exchange: This is where individuals can use premium tax credits (subsidies) to access minimum essential coverage. Small businesses will also be able to buy coverage for their employees there as well. 1099 Reporting : we Expect IRS to issue guidance in this area soon.

    16. How Does the Law Apply To Me? Are you a single employer? How many restaurants? What is their ownership structure? How many employees do you have? (monthly calculation) Full-time (>30 per week in a month) __________ Part-time workers total hours in a month __________ Seasonal workers part-time __________ full-time __________ Calculate your number of full-time equivalent employees (50 full-time equivalent employee threshold). If below…exempt from coverage requirements or penalties If above…provide coverage or pay penalties on full-time workers. Are you eligible for the small business tax credit? Comply with large employer requirements, if applicable. Comply with the requirements applicable to all employers. Scott Here are some introductory questions that should help you as you think about how this massive new law will apply to you. We’ll refer back to these questions as we work through the requirements of the bill.Scott Here are some introductory questions that should help you as you think about how this massive new law will apply to you. We’ll refer back to these questions as we work through the requirements of the bill.

    17. 1. Are you a single employer? Defined by “Common Control Clause” of the tax code – consult a tax advisor. Ownership requirement: In order for 2 or more restaurant organizations to be considered a single employer under Common Control, each restaurant organization must be 80% owned by the same 5 or fewer owners. Scott Common Control is an existing concept in the tax code that has been used in other areas of the business (like overtime). Rules for determining Common Control are very intricate and technical. Those with multiple restaurant organizations should consult their tax advisor to determine if they would be considered a single employer. Even if the ownership requirement is satisfied, based on the other rules an employer may single not be a single employer. Generalized examples: If single restaurateur owns 100% of 3 S-corps, for purposes of the new law, the 3 S-corps would be treated as a single employer. If restaurateur 1 and 2 own 90% of Partnership A and 50% of Corporation B, restaurant organizations A and B would not be considered a single employer. If restaurateur 1 and 2 own 90% of Partnership A and 80% of Corporation B, restaurant organizations A and B would be considered a single employer. Scott Common Control is an existing concept in the tax code that has been used in other areas of the business (like overtime). Rules for determining Common Control are very intricate and technical. Those with multiple restaurant organizations should consult their tax advisor to determine if they would be considered a single employer. Even if the ownership requirement is satisfied, based on the other rules an employer may single not be a single employer. Generalized examples: If single restaurateur owns 100% of 3 S-corps, for purposes of the new law, the 3 S-corps would be treated as a single employer. If restaurateur 1 and 2 own 90% of Partnership A and 50% of Corporation B, restaurant organizations A and B would not be considered a single employer. If restaurateur 1 and 2 own 90% of Partnership A and 80% of Corporation B, restaurant organizations A and B would be considered a single employer.

    18. 2. How many employees do you have? Full-time Employee: “With respect to any given month, an employee who is employed on average at least 30 hours of service per week.” Part-time Employee: Employers not required to provide health coverage nor pay any penalties on part-time workers. However, for determining if you are above or below the small business threshold, must consider part-time employees. Seasonal Workers: =120 days. Not counted for purposes of the small business threshold. May be counted towards penalties based on their full-time status. Scott How many… Full-time? Part-time? Seasonal Full-time? Seasonal Part-time?Scott How many… Full-time? Part-time? Seasonal Full-time? Seasonal Part-time?

    19. 3. Calculate the number of full-time equivalents. Scott Here is the formula to use in determining if you fall above or below the 50 full-time equivalent threshold. Part-time workers aggregate hours count towards the number of full-time equivalents (the 50 threshold). [emphasize] Employers are NOT required to provide health coverage or pay penalties for any part-time employees. Seasonal workers (full and part) are not included in this threshold calculation – BUT if they work more than 30 hours for you, you must offer coverage or may be liable for a penalty (because they are full-time).Scott Here is the formula to use in determining if you fall above or below the 50 full-time equivalent threshold. Part-time workers aggregate hours count towards the number of full-time equivalents (the 50 threshold). [emphasize] Employers are NOT required to provide health coverage or pay penalties for any part-time employees. Seasonal workers (full and part) are not included in this threshold calculation – BUT if they work more than 30 hours for you, you must offer coverage or may be liable for a penalty (because they are full-time).

    20. 4. Are you eligible for the small business tax credit? Small Business Tax Credit: Available 1/1/2010 (after 2014, for 2 years) for those who provide coverage. Full credit to employers who: Have 10 or fewer “full-time equivalent employees”; With average annual wages less than $25,000; and Contribute at least 50% of the premium. Phase out up to 25 full-time equivalents and $50,000 www.IRS.gov for more information; postcards mailed out Scott If you are under the small business threshold of 50 full-time equivalents and meet these requirements, this tax credit may be available to you… PLEASE NOTE that this full-time equivalent is based on 40 hours per week…Scott If you are under the small business threshold of 50 full-time equivalents and meet these requirements, this tax credit may be available to you… PLEASE NOTE that this full-time equivalent is based on 40 hours per week…

    21. Scott IRS has provided guidance and step by step tools like this one on their website to help small businesses determine if they are eligible for the tax credit. The IRS just recently released additional guidance on how employers can calculate the number of FTE they have for the purposes of this credit. There are 3 different methods you can use to determine hours and eligibility. The IRS also stated that employers can continue to take state tax credits in addition to this one.Scott IRS has provided guidance and step by step tools like this one on their website to help small businesses determine if they are eligible for the tax credit. The IRS just recently released additional guidance on how employers can calculate the number of FTE they have for the purposes of this credit. There are 3 different methods you can use to determine hours and eligibility. The IRS also stated that employers can continue to take state tax credits in addition to this one.

    22. 5. Comply with large employer requirements, if applicable. Starting in 2014, “large” employers must offer affordable “minimum essential coverage” to their full-time employees. Minimum Essential Coverage: Sec. of HHS to define essential health benefits Prohibits out-of-pocket limits greater than the HSA (2010: $5,950 self, $11,900 family). Provide either Bronze (60% actuarial value), Silver (70%), Gold (80%), Platinum (90%) level of coverage. Catastrophic plan is not minimum essential coverage. Scott So what does the law require of you if you are determined to be a large employer with more than 50 full-time equivalents? Offer – not provide coverage Affordable – employee contribution must be less than 9.5% of household income Minimum essential coverage – yet to be fully defined by regulations (Actuarial value does not refer to premiums) (An average employer plan you might have for yourself today is probably around 65% actuarial value and about $300 per month) Scott So what does the law require of you if you are determined to be a large employer with more than 50 full-time equivalents? Offer – not provide coverage Affordable – employee contribution must be less than 9.5% of household income Minimum essential coverage – yet to be fully defined by regulations (Actuarial value does not refer to premiums) (An average employer plan you might have for yourself today is probably around 65% actuarial value and about $300 per month)

    23. Possible Outcomes For Large Employers Does not offer coverage: $2000 annual penalty per full-time employee. Does offer coverage: $3000 per full-time employee access insurance on exchange with tax credit. Does offer coverage: free choice voucher (8-9.5% of employees’ household income). Allowed to exclude the first 30 full-time employees when calculating $2000 annual penalty amount or maximum limit on $3000 penalty. Scott These penalties are applied only if on full-time employee accesses the exchange using a premium tax credit or subsidy. If they do not but you still are not providing coverage, the employer is not subject to the penalty. $2000 annual or $167 monthly $3000 annual or $250 monthly Scott These penalties are applied only if on full-time employee accesses the exchange using a premium tax credit or subsidy. If they do not but you still are not providing coverage, the employer is not subject to the penalty. $2000 annual or $167 monthly $3000 annual or $250 monthly

    24. What “Large” Businesses Need to Know Certification to IRS that offer minimum essential coverage, provide to employee as well (Begins 2014). Waiting Period: Large employers allowed up to 90 days waiting period before enrolling new full-time employees in health plan (Begins 2014). Automatic Enrollment: Employers with 200+ full-time employees must automatically enroll new full-time employees in an employer-sponsored plan. Scott Scott

    25. Scott Scott

    26. Other Provisions to Know Reasonable Break Time for Nursing Mothers: Amends FLSA, effective 3/23/2010. Employer-Offered Wellness Programs: Able to continue to offer and are encouraged enhance these programs. Nutritional Disclosure: Applies to restaurants with 20 or more locations nationwide; provide calorie counts on menus and menu boards and additional nutritional data upon request. More information available at www.restaurant.org/foodandhealthyliving Scott Scott

    27. Other Provisions To Know New and Expanded Medicare Taxes: Applies to taxpayers earning $200,000/$250,000 (2013). Over-the-counter medicines are no longer considered medical expense for Health Savings Accounts, etc. (2011) Limitation on FSAs to $2,500 (2011) Individual Mandate: Requires individuals to obtain “minimum essential coverage” for themselves and dependents (2014) Scott Individual mandate: Penalty is the greater of $695 per calendar year (2016) OR up to 2.5% of income. Scott Individual mandate: Penalty is the greater of $695 per calendar year (2016) OR up to 2.5% of income.

    28. Edward Pudlowski – Ernst & Young

    29. Health Care Reform: Business Implications for the Restaurant Industry NRA Show, May 22–25, 2010 Note to EY Speakers: The following slides are intended to facilitate client discussions on health care reform legislation that congressional leaders are attempting to move quickly through the House and Senate this month (July 2009). Because the status of legislative proposals can change on a daily basis, it is recommended that you review the EY Center for Tax Policy database for the latest updates before heading into a client meeting. To access the EY Center for Tax Policy database, go to the “EY Tax Alerts” database (also known as the “Daily Tax Update” database) and look for the “Center for Tax Policy” entry in the left-hand navigation window. Click on the Center for Tax Policy entry, and then click on “view by document type” to see a directory of thought leadership materials on health care reform. Among recommended sources are the following: EY Executive Brief article, “Healthcare reform: changes and challenges in store for US employers” (Jul ’09) EY Tax Alert, “House Committees Unveil Health Care Reform Bill” (July 14, 2009) Other Washington Council Tax Alerts that describe key legislative milestones such as a bill introduction, committee mark-up, or floor action Note to EY Speakers: The following slides are intended to facilitate client discussions on health care reform legislation that congressional leaders are attempting to move quickly through the House and Senate this month (July 2009). Because the status of legislative proposals can change on a daily basis, it is recommended that you review the EY Center for Tax Policy database for the latest updates before heading into a client meeting. To access the EY Center for Tax Policy database, go to the “EY Tax Alerts” database (also known as the “Daily Tax Update” database) and look for the “Center for Tax Policy” entry in the left-hand navigation window. Click on the Center for Tax Policy entry, and then click on “view by document type” to see a directory of thought leadership materials on health care reform. Among recommended sources are the following: EY Executive Brief article, “Healthcare reform: changes and challenges in store for US employers” (Jul ’09) EY Tax Alert, “House Committees Unveil Health Care Reform Bill” (July 14, 2009) Other Washington Council Tax Alerts that describe key legislative milestones such as a bill introduction, committee mark-up, or floor action

    30. Objectives of health care reform Provide affordable and accessible coverage for the uninsured “Bend the cost curve” At least budget neutral Cost effective delivery Maintain private insurance

    31. Business implications Effect on profit margins Employee workforce Recruitment and retention Administration

    32. Potential effect on profit margins Health care inflation Small business tax credits Fees and penalties Employee migration Administration

    33. Health care inflation

    34. Small employer tax credits Provides for tax credits for employers with no more than 25 FTEs and average annual wages of less than $50,000 that purchase health insurance: 2010 – 2013: Up to 35% of the employer’s contribution toward premiums if the employer contributes at least 50% of premium. 2014 and later: For employers that purchase coverage through the exchange, up to 50% of the employer’s contribution toward premium if the employer contributes at least 50% of premium (2 year limit).

    35. Determining available employer tax credits Employer must subsidize at least 50% of the cost of health care Employers with 10 or fewer employees and average annual wages not greater than $25,000 get the full credit available Reduction based on FTEs and average annual salary:

    36. Example: Small employer tax credit Full service restaurant with 19 FTEs, total sales of $950,000 with pre-tax profit of $30,000 Annual wages of $247,000 ($13,000 per FTE) Annual health care premiums total $171,000 Employer subsidizes 60% of health premiums ($102,600)

    37. Employer mandate penalties Employers with 50 or more full-time equivalents in any given month that don’t sponsor a health plan can be subject to penalties if at least one employee receives a federal tax credit Penalties equal $2,000 annually ($166.67 per month) times the number of full-time employees (work 30 hours or more) less the first 30 full-time employees. Example: 100 employees / 90 work more than 30 hours per week 5 employees receive individual premium assistance tax credit Penalty = (90 – 30) x $2,000 = $120,000 (about 2% - 3% of sales)

    38. Calculating full time equivalents for employer mandate Review all employee hours for which wages were paid during the month Hours for an employee in excess of 120 are not counted Excludes seasonal employees Example (60 employees): 25 employees work 120 hours each 5 employees work more than 130 hours each 30 employees work 60 hours each FTEs = (25 x 120) + (5 x 120) + (30 x 60) 120 = 45.0

    39. Coverage deemed “unaffordable” There are two ways a plan can be deemed “unaffordable”: Plan does not meet the “actuarial value” of 60% Employee’s contribution exceeds 9.5% of household income Employer pays the tax credit provided to qualified individuals up to a maximum of $2,000 times the number of full-time employees (30 hours or more). Tax credit can be as much as $3,000 annually per individual Employees must have household income below 400% of the federal poverty limit ($43,320 for an individual, $88,200 for a family of four) to qualify for premium assistance tax credit.

    40. Free choice voucher If employee can show that their contribution is between 8.0% and 9.5% of household income and their household income is below 400% of the Federal Poverty Limit then they are eligible for the “free choice voucher” program. Program provides that the employee is eligible for the employer subsidy if they elect coverage in a state insurance exchanges available in 2014 Example:

    41. Employee migration The individual mandate may “push” employees who previously did not elect employer-sponsored coverage to participate in the plan

    42. Coverage for all dependents to age 26 The health care reform laws requires all plans (even “grandfathered” plans) to cover all dependents to age 26 Most plans today provide coverage for dependents to age 18 and students dependents to age 23 or 25 Given the relatively young age of the restaurant industry’s workforce and the generally high cost of coverage to participants, this provision could push some employees to elect coverage under their parent’s employer plan Note, however, that many employers are now considering increases in employee contributions to counter this additional cost

    43. Health care excise tax This shows how the aggregate costs (bars) compare to the limit (line) in each year for individual coverage. The purple costs at the top of each bar for 2013 and after represent the excise tax assuming the insurer / TPA passes the costs back to the employer directly. This assumes no plan changes are implemented. I should also note that there is the possibility that the excise tax paid by an insurer / TPA could be spread across all clients in the form of an additional administrative charge such that even employers that do not exceed the limit could end up paying more and employers that do exceed the limit pay less than their fair share. There just is no requirement on an insurer / TPA t handle one way or another.This shows how the aggregate costs (bars) compare to the limit (line) in each year for individual coverage. The purple costs at the top of each bar for 2013 and after represent the excise tax assuming the insurer / TPA passes the costs back to the employer directly. This assumes no plan changes are implemented. I should also note that there is the possibility that the excise tax paid by an insurer / TPA could be spread across all clients in the form of an additional administrative charge such that even employers that do not exceed the limit could end up paying more and employers that do exceed the limit pay less than their fair share. There just is no requirement on an insurer / TPA t handle one way or another.

    44. Administrative costs Increased cost to insurers / health plans administrators Additional restaurant staff time to administer new requirements: 1099 reporting Employee communications (required and needed to help them understand health care reform) High cost excise tax reporting to insurers / administrators Payroll changes Increased cost to suppliers

    45. Restaurant employee workforce issues Expectation by employee to provide coverage Available of state insurance exchange options in 2014 Seasonal workforce Demographics create unique challenges Managing employee growth against loss of employer tax credits (25 FTEs) or possibility of penalties (50 FTEs)

    46. Recruitment and retention in the restaurant industry Greater mobility do to presence of exchanges How will health plan offerings be viewed as a factor in accepting an offer for employment Greater focus on wages

    47. Additional restaurant administration Required employee communications Coordination with state exchanges Payroll changes Excise tax reporting requirements Validation of penalty payments from federal government Outcomes research fees Flexible spending account changes (amount and eligible expenses) Auto-enrollment (200 employees) W2 reporting Corporate information reporting (1099s) Nursing mothers

    48. Going forward Important to understand the legislation and prepare for changes now The process did not end when the President signed the health care reform legislation into law -- guidance will continue to be provided with regard to how the law is interpreted (regulatory process) The NRA will continue to provide support to member organizations as the process continues

    49. Mike McCallum Chief Strategy Officer National Restaurant Association

    50. Program Overview To provide NRA/SRA members with access to affordable small group, individual insurance, and large group health insurance products, the NRA has partnered with the United Healthcare Services, Inc. (UHC) Effort driven from research conducted in Strategic Plan process. Recent Congressional action provides emphasis. NRA/SRA will need to utilize all components of organizations to meet challenge. Address member interests in advocating regulation that mitigates impact and allows for coverage avenues that we will provide. Need powerful communications to tell the industry how they should deal with this huge new cost Marketed through joint efforts of the NRA, SRAs and UHC sales. Small group product piloted beginning now CO and PA Large group and individual products sold on a nationwide basis, begun quoting Likely be a primary way industry judges NRA/SRA over the next few years. UHC, a subsidiary of United Health Group, is pursuing this relationship for financial, public affairs, and internal service/innovation development objectives.UHC, a subsidiary of United Health Group, is pursuing this relationship for financial, public affairs, and internal service/innovation development objectives.

    51. Program Products Discount card for access to health services, including medical care, prescriptions, dental care, vision care, hearing care, alternative care, wellness care, long-term care, infertility treatment, behavioral health services, and other wellness services, including UnitedHealth Allies discount program Health assessment tools including OptumHealth Consumer Solutions’ Intelligent Health Assessment for risk identification and OptumHealth Behavioral Solutions' WebNeuro for assessing brain health

    52. Program Products Individual health insurance products offered on an association membership basis to target customers using UnitedHealthOne, which will include the value-added services included in non-insurance products Small group health insurance products, which will include the value-added services, which may not otherwise normally be available to small group employers. This offering will include “Catalyst-type” benefit design, with non-high deductible initial coverage, “donut hole” features and an out-of-pocket threshold that triggers recommencement of benefits. 5% savings on all dental, vision, life and disability insurance plans offered by United, subject to Applicable Law. Dedicated telephone number for provision of clinical telephonic program service and health advocacy, with availability 24 hours a day to Program Customers, staffed by registered nurses adequate to meet the demands of such participants Program Products may also include discount programs between employers, employees and provider groups whereunder employers pay a portion of premiums, employees pay a portion of premiums, and providers offer discounts to employers that have not previously provided health insurance benefits, or other products as may be agreed by the parties Mike … is any of this useful?Mike … is any of this useful?

    53. Product Set

    54. Randy Spicer United Healthcare

    55. What Are Companies Doing Now?

    56. What Are Companies Doing Now?

    57. What Are Companies Doing Now?

    58. What Are Companies Doing Now? Large Restaurants and Franchisees Consider Consumer Driven Health Plans. Experts agree on two issues: People are removed from the true cost of health care and Health care costs are skyrocketing. Consumer Driven Health Plans can provide more choices, more control, and dedicated support to help you lower your costs and improve your and your employees’ health. We can show you how these plans work. Develop a wellness strategy. The rules around wellness programs are changing dramatically and they are likely to be a very important part of your benefit strategy going forward. You can use them to drive engagement and healthy behaviors and to manage your premium contributions and overall medical expenses. It is in your interest to implement these plans well in advance of 2014. We can talk to you about these strategies today. Act on mental health parity. Mental health parity is effective later this year and will require significant changes to mental health benefits. We can talk to you about these issues today.

    59. Questions and Answers Mike McCallum, Chief Strategy Officer mmccallum@restuarant.org Scott Defife, Executive Vice President Policy & Government Affairs sdefife@restaurant.org Randy Spicer, Restaurant Industry Project Leader randy.spicer@optumhealth.com Ed Pudlowski, Principal, Performance and Award edward.pudlowski@ey.org For more information, visit www.restaurant.org/healthcare

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