Specialty Lines

By John Sallade 

By John Sallade 

My apologies for an omission in the April issue of the newsletter. I neglected to include Lynne Dillon on the PELICAN SAC listing. Lynne is the administrator of Saxony Health Center.

Several county officials and staff contacted us about the openings on the various insurance boards, which is much appreciated. Here are the positions still vacant: 

• Two positions on the COMCARE board for county commissioners or their home rule equivalents.
• A position on the COMCARE PRO SAC for a county commissioner or their home rule equivalent. 

Anyone interested in serving on these boards should please contact John Sallade.

Final Employer Mandate Rules and Another ACA Implementation Delay

Provided by the CCAP Health Alliance and the Delaware Valley Health Insurance Trust  

The Final Rules for compliance with the Affordable Care Act (ACA) "Employer Mandate" were published on February 10, 2014. While the delay (again) of the mandate captured much of the attention, there were several elements to the Final Rules which will help provide clarity for plan sponsors. In this latest edition of the ACA Outlook, we will summarize key elements of these regulations. 

Additional Year Delay for "Mid-sized" Employers
Employers with a total of 50 to 99 full-time (FT) and "full-time equivalent employees" ("FTEs") will not be required to offer "minimum essential coverage" ("MEC") to their FT employees (and their dependents) until January 1, 2016. This additional one year delay means that those "mid-sized" employers will have another year to determine their "large employer" status and identify their FT employees, which also means that the commencement of any "measurement", "administrative" and "stability" periods can be deferred until later this year or in 2015. 

To obtain the benefit of this transition relief, each "mid-sized" employer must later certify to the IRS that it:

• employed an average of at least 50 but fewer than 100 FT employees (including FTEs) during 2014;
• did not reduce the size of its workforce or the overall hours of service of its employees from February 9, 2014 through December 31, 2014 in order to satisfy the 50 to 99 FT employee requirement; and
• maintained previously offered health coverage for its FT employees during the "coverage maintenance period" (February 9, 2014 through December 31, 2015 for calendar year plans; February 9, 2014 through June 30, 2016 for July 1 plans), with allowance for limited benefit changes. 

Reduced Coverage Threshold for "Larger Employers"
"Larger employers" with a total of 100 or more FT employees (including FTEs) are still required to offer MEC as of January 1, 2015, but are only required to offer that coverage to at least seventy percent of their FT employees (and their dependents) in 2015. Effective January 1, 2016, this seventy percent coverage threshold increases to ninety-five percent. By meeting the seventy percent threshold in 2015 a larger employer can avoid the $2,000 per FT employee penalty that is imposed if the employer offers no MEC and at least one of their FT employees purchases a subsidized Exchange plan. Please note that "larger employers" who are subject to the Employer Mandate will not be subject to the $2,000 penalty on their first 80 FT employees in 2015 and their first 30 FT employees in 2016 (and future years). All larger employers also remain subject to the $3,000 penalty for each FT employee who is offered MEC which lacks "minimum value" or is "unaffordable", and buys a subsidized Exchange plan. 

For 2015, employers can determine whether they had at least 100 FT employees (including FTEs) using any period of at least six consecutive months in 2014. The hours of service for all full-time, part-time, variable hour and seasonal employees during this six month period must be taken into account in determining whether that threshold is reached. 

Transitional Relief for Non-Calendar Year Plans
One of the uncertain issues which has been dangling for months is the availability of "transitional relief" for non-calendar year plans. The Final Rules confirmed that non-calendar year plans will not be required to comply with the Employer Mandate until the anniversary date of their particular plan year. For example, a county that is a "larger employer" with a July 1 through June 30 plan year is not subject to the Employer Mandate until July 1, 2015. 

Volunteers, Seasonal and Part-Time Employees
The Final Rules confirmed that the hours worked by bona fide volunteer firefighters and volunteer emergency responders at governmental or tax-exempt organizations will not be counted as "hours of service" for the Employer Mandate. Moreover, those volunteers cannot be considered full-time employees entitled to benefits under the ACA even if they receive nominal compensation for the performance of their official duties. The Final Rules cite expense reimbursements or stipends, employee benefit plan contributions and "nominal" fees as examples of compensation that bona fide volunteers may accept and not lose their volunteer status under the Employer Mandate. 

The Final Rules also clarify the status of "seasonal employees" by further defining them as employees whose "customary annual employment" is six months or less. This clarification is important for employers that use the "look-back measurement method" to identify their full-time employees. Note: the optimum "measurement period" should be 12 months. An employer that uses a 12 month measurement period is unlikely to have seasonal employees who will be classified as full-time employees because using that period a seasonal employee would have to average at least 60 hours of service per week during his or her six month employment period. 

The Final Rules also define a "part-time employee" as a new employee whose employer "reasonably expects to be employed on average less than 30 hours of service per week during the initial measurement period". The employer's expectation must be based on the "facts and circumstances at the employee's start date". After a part-time employee completes the initial measurement period, their hours of service would be measured under the standard measurement period for ongoing employees. 

If you have any questions or would like additional information, please contact Julia Jackson, CCAP Health and Cooperative Programs Manager, at jjackson@pacounties.org or (800) 895-9039.

Emergency Evacuation Plans

By Andrew C. Smith, Loss Control Specialist

FACILITY EVACUATION PROCEDURES

Evacuation is required when the fire alarm sounds, when an evacuation announcement is made, or when ordered by court security, sheriff's office or members of facilities' management. An evacuation meeting point should be established. This ensures that all staff and visitors are accounted for in case of an evacuation.

FIRE EMERGENCY

When a fire is discovered, activate the closest fire alarm. Many fire alarm pull systems will be located next to exits. Call the emergency phone number applicable for your facility and notify the local fire department. The fire department will be notified when an alarm is pulled, but a follow up phone call should be made in addition.
 

Upon being notified of a fire emergency, occupants must remain calm and leave the building using the designated evacuation routes. Take jackets or clothing necessary for protection from the weather if it is safe to do so. Leave lights on and if you are away from your office or workstation when the alarm sounds, exit the facility and proceed to the designated meeting location. Remain outside until a designated official or designee provides further instructions or announces it is safe to reenter.

POWER LOSS

In the event of a power loss to a facility, remain calm and contact the emergency phone number applicable for your facility. Unnecessary electrical equipment should be turned off in the event that power restoration would surge causing damage to electronics and effecting sensitive equipment. Know where emergency flashlights are located. Provide assistance to visitors and staff in your immediate area. If you find yourself in an unlighted area, proceed safely to an area that has emergency lighting. If you are in an elevator, remain calm and use the elevator phone or your cellular phone to alert court security or sheriff's office. If the facility must be evacuated, follow your facilities evacuation procedures.

SEVERE WEATHER AMD NATURAL DISASTERS

When a tornado warning is issued by sirens or other means, seek inside shelter. Small interior rooms on the lowest floors and without windows are the best places to seek shelter. Hallways on the lowest floors away from windows and doors can also be utilized or rooms constructed with reinforced concrete, brick or rock. Stay away from outside walls and windows. Use your arms to protect your head and neck and remain sheltered until the tornado threat is announced to be over.

The nature of a hurricane provides for more warning than other natural and weather disasters. A hurricane watch is issued when it becomes a threat to a coastal area. A hurricane warning is issued when it reaches winds of 74 mph or higher, or a combination of dangerously high water and rough seas are expected in the area within 24 hours. Once a hurricane watch has been issued, remain indoors and consider small interior rooms on the lowest floors and without windows. Hallways on the lowest floors away from windows and doors can also be utilized or rooms constructed with reinforced concrete, brick or rock.

ACTIVE SHOOTER PROCEDURES

If you are involved in a situation where someone has entered the area and started shooting, exit the facility immediately. Notify anyone you may encounter to exit the facility immediately. Call the emergency number applicable to your facility. Provide the operator with your name, location or incident and your exact location, number of shooters (if known), identification of shooters (if known) and the number of persons involved and/or injuries.

If exiting the facility is not possible, go to the nearest room or office. Close and lock the doors, cover the windows, barricade the doors, stay calm and quiet, act as if no one is in the room and wait for first responders to assist you out of the facility.

As a last resort, take action! If you find yourself in imminent danger take action. Attempt to incapacitate or act with as much physical aggression as possible. Use items around you to defend yourself. Improvise weapons or throw items at the active shooter. Commit to your actions.

The first officers to arrive on scene will not stop to help the injured. Expect rescue teams to follow initial officers.

For more information, contact the CCAP Loss Control Department at (800) 895-9039; or email us at:
Gary Nicholson, Loss Control Services Manager, at (800) 895-9039

Maureen McMahon, Loss Control Specialist, at (412) 760-1421

Andrew Smith, Loss Control Specialist, at (800) 895-9039

Dennis Cutler, Loss Control Specialist, at (412) 600-6189

New U.S. Communities Contracts Deliver Added Value

Training Opportunities

By Linda Rosito, Insurance Training Director 

Although May brings the end of the spring workshops season, there are excellent educational opportunities still available. 

Quote of the Month
 

"Have you ever noticed that anybody driving slower than you is an idiot, and anyone

going faster than you is a maniac?"