A few employers are beginning to offer eldercare as a benefit, realizing that many Baby Boomers have parents in need of a much-needed lifeline. In fact, 19% of Americans over the age of 18 are caring for someone 50 or older, according to the National Alliance for Caregiving.
The alliance also found that people responsible for taking care of an elderly relative or friend suffer poor health themselves, including depression, diabetes, hypertension or heart disease—which may cause many workers to take time off or distract them from their job. These unfortunate effects cost U.S. employers an additional 8% in healthcare a year, or $13.4 billion annually, reports the MetLife Study of Working Caregivers and Employer Health Care Costs.
As Prudential Vice President of Health, Life and Inclusion Maureen Corcoran succinctly put it, “If you have a care issue and you’re working on deadline and expected to be at your desk, what are you going to be thinking about?”
Thus, to head off these problems, many employers are beginning to provide eldercare to their employees. The most comprehensive offers in-home services for a maximum number of hours a year for a co-pay of as little as $4 an hour.
The MetLife report notes that 20% of employers with more than 500 workers offer eldercare referral services, 15% eldercare leave, 3% emergency eldercare, and 2% subsidized eldercare, while 1% paid for eldercare or had an on-site eldercare center
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Monday, March 29, 2010
Tuesday, March 16, 2010
Life Insurance Products Play Valuable Role in Estate Planning
By Joseph R. Crea, CLU, ChFC
While Washington debates its next move in dealing with estate tax legislation (as summarized in the article by John Tullio, Esq. in this newsletter), proactive estate planning continues to be an important focus for business owners and other individuals with significant wealth. Although federal taxes are a valid consideration in estate planning, there are many other factors that may impact your planning:
• Federal estate taxes
• State inheritance taxes
• Estate administration costs (e.g., attorneys, probate)
• Debt repayment (especially with highly leveraged assets earmarked for heirs’ retention
• Equalizing inheritances in family business estates between children who are active in the business and those who are not.
• Creating legacies for charitable organizations
• Planning for children or family members with special needs
• Protecting wealth against the potential erosion of the estate due to market values in volatile times
• Personal situation (e.g., divorce, separation)
Protecting your estate and ensuring that it is distributed in the way you intend requires careful planning and a variety of tools and strategies. Particularly during times of legislative and financial uncertainty, the enduring value of life insurance makes it an extremely attractive estate planning component.
Insurance Products That Work for You
Life insurance has traditionally been included in estate plans to provide family members with quick access to cash to take care of immediate financial needs and daily living expenses. Because life insurance proceeds are paid to named beneficiaries, they are not tied up in potentially lengthy probate proceedings. Properly designed life insurance policies are income tax-free and can be structured to be estate tax-free, making them even more attractive to beneficiaries.
Life insurance can also be useful in other ways in your estate planning. For example, life insurance can be used to:
• Provide a floor amount of assets for your heirs no matter what;
• Provide for transfer of wealth on a leveraged basis utilizing irrevocable trust (ILIT);
• Maximize wealth transfer; and
• Serve as a creative planning tool for charity and families with Charitable Lead and Remainder Trusts.
How life insurance fits into your estate plan will depend on your estate planning philosophy, your needs and your unique personal situation. A variety of life insurance products are available on the market today. Here are the most common options:
• Term Insurance. With term life insurance, the premium and death benefit is known and guaranteed for a period of time only – premiums are paid for a limited time and so is the death benefit. While the policyholder bears no risk with this type of policy (the full value is paid out even if the policyholder dies much earlier than expected), there is also no potential for an increase in value, decrease in premium, or flexibility to access value prior to death. If the insured lives beyond the term period, the premiums increase dramatically or the insurance terminates.
• Whole Life. Whole life policies were developed to share some of the downside risk as well as the upside potential with policyholders. In times of favorable mortality, interest and expense results, these policies pay dividends, which can be used to suspend premiums or increase the face amount.
• Universal Life and Variable Universal Life. Universal life insurance offers the same risks and opportunities as whole life, but with a more transparent and “unbundled” approach. Variable universal life takes the risk and opportunity sharing one step further, allowing the policyholder to almost completely assume the investment allocation control and investment risk. A hybrid of universal life and variable universal life, called Equity Index Universal Life, provides a combination of the two – allowing for investment participation while providing a guaranteed floor and typically a cap on earnings credited.
• Joint Second to Die Life. This life insurance provides coverage for two individuals and is specially designed for estate planning. It pays proceeds upon the second death (when the estate taxes are due). Premiums are based on two lives and are substantially reduced when compared to single life policies.
• Guaranteed Not to Lapse Policies. These policies stay in force through a designated age between 100 – 120 years of age.
Purchasing life insurance, particularly for high net worth individuals, can be complex. It is important to understand the different types of life insurance – including the risks and opportunities they include – as well as carefully evaluate different carrier’s offerings. BRG helps many clients evaluate and select the right combination of life insurance for their general and estate planning needs. Because the market and available offerings are constantly changing, it is also important to review your life insurance policies regularly – at least every three to five years. See Linda Cahill’s article, “Have You Reviewed Your Life Insurance Lately?” for more information about conducting life insurance policy audits.
BRG Can Help
Effective estate planning requires a comprehensive understanding of your family, business and financial situation. It requires a team of trusted advisors, which should include a qualified insurance professional to help you evaluate and select the products that are best suited to your needs. Contact BRG for assistance with your estate planning.
Joe Crea is the President and co-founder of Benefits Resource Group. He manages the development of leading edge solutions and services for BRG clients. You can contact Joe by phone at 216-393-1818 or by email at jcrea@benefitsrg.com.
Securities and Investment Advisory Services Offered through M Holdings Securities, Inc., A Registered Broker/Dealer, Member FINRA/SIPC; BRG is independently owned and operated; This material is intended for informational purposes only and is not intended to replace the advice of a qualified tax advisor; Product guarantees are subject to the claims paying ability of the issuing insurance company; Variable life insurance products are long-term investments and may not be suitable for all investors. An investment in variable life insurance is subject to fluctuating values of the underlying investment options and entails risk, including the possible loss of principal. The performance of your account will vary and you may receive more or less than the amount invested.
By Joseph R. Crea, CLU, ChFC
While Washington debates its next move in dealing with estate tax legislation (as summarized in the article by John Tullio, Esq. in this newsletter), proactive estate planning continues to be an important focus for business owners and other individuals with significant wealth. Although federal taxes are a valid consideration in estate planning, there are many other factors that may impact your planning:
• Federal estate taxes
• State inheritance taxes
• Estate administration costs (e.g., attorneys, probate)
• Debt repayment (especially with highly leveraged assets earmarked for heirs’ retention
• Equalizing inheritances in family business estates between children who are active in the business and those who are not.
• Creating legacies for charitable organizations
• Planning for children or family members with special needs
• Protecting wealth against the potential erosion of the estate due to market values in volatile times
• Personal situation (e.g., divorce, separation)
Protecting your estate and ensuring that it is distributed in the way you intend requires careful planning and a variety of tools and strategies. Particularly during times of legislative and financial uncertainty, the enduring value of life insurance makes it an extremely attractive estate planning component.
Insurance Products That Work for You
Life insurance has traditionally been included in estate plans to provide family members with quick access to cash to take care of immediate financial needs and daily living expenses. Because life insurance proceeds are paid to named beneficiaries, they are not tied up in potentially lengthy probate proceedings. Properly designed life insurance policies are income tax-free and can be structured to be estate tax-free, making them even more attractive to beneficiaries.
Life insurance can also be useful in other ways in your estate planning. For example, life insurance can be used to:
• Provide a floor amount of assets for your heirs no matter what;
• Provide for transfer of wealth on a leveraged basis utilizing irrevocable trust (ILIT);
• Maximize wealth transfer; and
• Serve as a creative planning tool for charity and families with Charitable Lead and Remainder Trusts.
How life insurance fits into your estate plan will depend on your estate planning philosophy, your needs and your unique personal situation. A variety of life insurance products are available on the market today. Here are the most common options:
• Term Insurance. With term life insurance, the premium and death benefit is known and guaranteed for a period of time only – premiums are paid for a limited time and so is the death benefit. While the policyholder bears no risk with this type of policy (the full value is paid out even if the policyholder dies much earlier than expected), there is also no potential for an increase in value, decrease in premium, or flexibility to access value prior to death. If the insured lives beyond the term period, the premiums increase dramatically or the insurance terminates.
• Whole Life. Whole life policies were developed to share some of the downside risk as well as the upside potential with policyholders. In times of favorable mortality, interest and expense results, these policies pay dividends, which can be used to suspend premiums or increase the face amount.
• Universal Life and Variable Universal Life. Universal life insurance offers the same risks and opportunities as whole life, but with a more transparent and “unbundled” approach. Variable universal life takes the risk and opportunity sharing one step further, allowing the policyholder to almost completely assume the investment allocation control and investment risk. A hybrid of universal life and variable universal life, called Equity Index Universal Life, provides a combination of the two – allowing for investment participation while providing a guaranteed floor and typically a cap on earnings credited.
• Joint Second to Die Life. This life insurance provides coverage for two individuals and is specially designed for estate planning. It pays proceeds upon the second death (when the estate taxes are due). Premiums are based on two lives and are substantially reduced when compared to single life policies.
• Guaranteed Not to Lapse Policies. These policies stay in force through a designated age between 100 – 120 years of age.
Purchasing life insurance, particularly for high net worth individuals, can be complex. It is important to understand the different types of life insurance – including the risks and opportunities they include – as well as carefully evaluate different carrier’s offerings. BRG helps many clients evaluate and select the right combination of life insurance for their general and estate planning needs. Because the market and available offerings are constantly changing, it is also important to review your life insurance policies regularly – at least every three to five years. See Linda Cahill’s article, “Have You Reviewed Your Life Insurance Lately?” for more information about conducting life insurance policy audits.
BRG Can Help
Effective estate planning requires a comprehensive understanding of your family, business and financial situation. It requires a team of trusted advisors, which should include a qualified insurance professional to help you evaluate and select the products that are best suited to your needs. Contact BRG for assistance with your estate planning.
Joe Crea is the President and co-founder of Benefits Resource Group. He manages the development of leading edge solutions and services for BRG clients. You can contact Joe by phone at 216-393-1818 or by email at jcrea@benefitsrg.com.
Securities and Investment Advisory Services Offered through M Holdings Securities, Inc., A Registered Broker/Dealer, Member FINRA/SIPC; BRG is independently owned and operated; This material is intended for informational purposes only and is not intended to replace the advice of a qualified tax advisor; Product guarantees are subject to the claims paying ability of the issuing insurance company; Variable life insurance products are long-term investments and may not be suitable for all investors. An investment in variable life insurance is subject to fluctuating values of the underlying investment options and entails risk, including the possible loss of principal. The performance of your account will vary and you may receive more or less than the amount invested.
Monday, March 15, 2010
New law modifies COBRA subsidy rules
by John Hickman, Esq. and Ashley Gillihan, Esq.
On March 2, 2010, President Obama signed into law the Temporary Extension Act of 2010 (the “Act”). The Act contains several modifications to the COBRA subsidy rules originally included in the American Recovery and Reinvestment Act of 2009 and later modified by the Department of Defense Appropriations Act of 2010.
The following is a summary of those key modifications.
New sunset date
The Act changes the subsidy eligibility sunset date---the date on or before which the qualifying event that is an involuntary termination of employment must occur--from Feb. 28, 2010 to March 31, 2010.
Assistance eligible individuals
Typically, a qualified beneficiary will qualify as an assistance eligible individual (AEI) only if the qualifying event is an involuntary termination of employment occurring prior to the sunset date.
However, under the Act, qualified beneficiaries who experience/d a qualifying event that is a reduction in hours of employment occurring anytime on or after Sept. 1, 2008, followed by an involuntarily termination of employment between March 2, 2010, and March 31, 2010, qualify as AEIs even though the subsequent involuntary termination of employment is not the qualifying event for COBRA purposes.
Although it is not the qualifying event giving rise to COBRA, the Act treats the subsequent involuntary termination of employment as the “qualifying event” for purposes of determining eligibility for the subsidy (and for purposes of identifying the notice due date—see “Notices” below for more information).
This new subsidy rule only applies to periods of coverage beginning after March 2, 2010. Thus, if the COBRA periods typically begin on the first of the month, the first subsidized COBRA coverage period resulting solely from this new rule would begin April 1, 2010.
Practice Pointer: The rule does not operate to extend the qualified beneficiary’s COBRA coverage; the COBRA period is still measured based on the original qualifying event that was a reduction in hours of employment. It simply provides a subsidy for any remaining periods of COBRA coverage beginning after that involuntary termination of employment.
However, it does operate to provide a new election period for those who would be AEIs under this rule but failed to elect or elected and subsequently lost coverage. See “New election period” below for more information.
Illustration of the new rule:
#1: ABC, Inc. sponsors a group health plan that only covers full-time employees of the company. Prior to Jan. 15, 2010, Bob was a full-time employee of the company and a participant in ABC’s group health plan.
On Jan. 15, 2010, Bob changes from full-time status to part-time status. Assume for purposes of this illustration that the transition from full-time to part-time status was not a “material negative change” that would otherwise cause the reduction in hours to be treated as an involuntary termination of employment.
Under the terms of ABC’s plan, Bob’s coverage will continue until the end of the month, Jan. 31, 2010, after which he is offered an opportunity to elect 18 months of COBRA.
Bob elects COBRA continuation coverage but he must pay 102% of the applicable premium since the qualifying event was a reduction in hours of employment and not an involuntary termination of employment. On March 10, Bob is involuntarily terminated from the company due to a reduction in force.
Even though Bob’s COBRA qualifying event was a reduction in hours of employment, he is an AEI who may be eligible for up to 15 months of federally subsidized continuation coverage (assuming he is not eligible for other coverage).
Since ABC’s COBRA coverage periods begin on the first of each month, Bob’s first federally subsidized COBRA period will be April 1, 2010 (the first coverage period after the enactment date March 2).
New election period
Individuals who would be an AEI under the new rule described above, but who failed to elect COBRA or elected COBRA and subsequently lost coverage, are entitled to a new election.
Illustrations of this rule:
#2: Same facts as Illustration #1 above except that Bob did not elect COBRA continuation coverage following his qualifying event that was a reduction in hours of employment (i.e., transition from full-time to part-time). Bob is now an AEI entitled to a new election.
#3: Same facts as Illustration #1 above except that Bob’s spouse was also covered under ABC’s health plan on the date of the qualifying event. Although Bob chose COBRA, Bob’s spouse did not. Bob’s spouse is now an AEI entitled to a new election.
Practice Pointer: This new rule does not operate to give would-be AEIs whose COBRA period has already expired a new COBRA continuation period simply because they have an involuntary termination of employment between March 2 and March 31, 2010.
Although the involuntary termination of employment is treated as the qualifying event for purposes of determining eligibility for the new election and the subsidy, the maximum COBRA period is determined in this instance based on the original qualifying event that was a reduction in hours of employment (e.g., if COBRA is typically measured from the date of the qualifying event, COBRA will be measured here from the date of the reduction in hours of employment).
Also, any break in coverage between the reduction in hours and the involuntary termination of employment is not treated as a "break in coverage" for HIPAA portability purposes.
Thus, periods of creditable coverage preceding this break must be included on any certificate of creditable coverage otherwise required by HIPAA and applied towards any pre-existing condition exclusion or limitation period.
Practice Pointer: This new election period should operate similarly to the special extended election period provided under the original ARRA legislation to those would-be AEIs who experienced an involuntary termination of employment on or after Sept. 1, 2008, and who chose not to elect coverage or elected coverage but lost it prior to Feb.17, 2009.
Thus, the same procedures adopted to comply with that rule should, with appropriate modifications, apply here as well.
This new rule is only applicable for periods of coverage beginning after March 2, 2010. Thus, if the plan typically requires that COBRA continuation coverage be paid for on a calendar month basis, then the date that continuation coverage would begin in this instance is April 1, 2010 (see, e.g., Q-48 of IRS Notice 2009-27).
If, however, the plan typically requires COBRA continuation to be paid for on a monthly basis computed from the date coverage is lost, then the coverage start date is not as clear.
The date that COBRA coverage would appear to begin in this instance is the first day of the next COBRA period determined as though the qualified beneficiary elected COBRA following the reduction of hours in employment—and not the date that the subsequent involuntary termination of employment occurs.
This is because the maximum COBRA period is determined based on the qualifying event that is the reduction in hours of employment.
Illustration of this rule:
#4: Same facts as Illustration #2 except that ABC typically requires COBRA continuation coverage be paid for on a monthly basis computed from the date coverage is lost. In this illustration, Bob would have lost coverage on Jan. 15, 2010, and his monthly COBRA periods would run from the 15th of each month through the 14th of the next month. The next COBRA period following Bob’s March 10 termination, if Bob had elected COBRA following the reduction in hours, would begin March 15, 2010.
Arguably, this is the date that Bob’s subsidized COBRA continuation coverage would start under this new rule (although the maximum COBRA coverage period would be measured from the date of the reduction in hours of employment in this example).
Practice Pointer: Using prior IRS guidance, it would appear that plan sponsors may permit would-be AEIs entitled to a new election under this rule to choose a later start date.
Notices
The same general election rules applicable under ARRA and the Defense Act apply equally to qualified beneficiaries whose qualifying event occurs between March 1, 2010, and March 31, 2010. Election notices should be revised to reflect the new sunset date.
In addition, there are special notice rules for those individuals who are AEIs under the Act as a result of a reduction in hours of employment. If AEIs are already receiving COBRA, notice of the new rules must be furnished to such AEIs within 60 days of the date of the involuntary termination of employment.
Although not specifically stated in the Act, the DOL’s reasoning with respect to prior notices suggests that the notice must be furnished to those qualified beneficiaries who experience a voluntary or involuntary termination of employment.
If the would-be AEI is not currently enrolled but is entitled to a new election under the Act, then a revised election notice describing the availability of the subsidy (and the corresponding terms and conditions of eligibility) must be furnished within 60 days of the date of the involuntary termination of employment.
Practice Pointer: The Act refers to the relevant ARRA provisions to describe the notice contents. Under those ARRA rules, notice of the option to enroll in less expensive coverage, if available, had to be included.
Thus, it would appear that same opportunity may be offered would-be AEIs entitled to a new election under the Act.
Other issues
The Act allows the regulators to impose up to a $110/day penalty on plan sponsors who fail to implement the DOL's/Treasury's determination of eligibility within 10 days after receiving notice of the determination.
The Act revised the date that the now 15-month subsidy period begins. Under ARRA, the subsidy period began as of the “first of the month” that the COBRA subsidy period applied.
Thus, if the first COBRA period to which the subsidy applied was July 15, 2009, through August 14, 2009, the subsidy period was measured from July 1, 2009. The act deletes the “first of the month” language. Therefore, the 15-month COBRA subsidy period will be measured from the first day of the first COBRA coverage period to which the subsidy applies.
The Act codifies the clarifications made by the DOL in its model notices with respect to the transition period provided under the Defense Act.
On March 2, 2010, President Obama signed into law the Temporary Extension Act of 2010 (the “Act”). The Act contains several modifications to the COBRA subsidy rules originally included in the American Recovery and Reinvestment Act of 2009 and later modified by the Department of Defense Appropriations Act of 2010.
The following is a summary of those key modifications.
New sunset date
The Act changes the subsidy eligibility sunset date---the date on or before which the qualifying event that is an involuntary termination of employment must occur--from Feb. 28, 2010 to March 31, 2010.
Assistance eligible individuals
Typically, a qualified beneficiary will qualify as an assistance eligible individual (AEI) only if the qualifying event is an involuntary termination of employment occurring prior to the sunset date.
However, under the Act, qualified beneficiaries who experience/d a qualifying event that is a reduction in hours of employment occurring anytime on or after Sept. 1, 2008, followed by an involuntarily termination of employment between March 2, 2010, and March 31, 2010, qualify as AEIs even though the subsequent involuntary termination of employment is not the qualifying event for COBRA purposes.
Although it is not the qualifying event giving rise to COBRA, the Act treats the subsequent involuntary termination of employment as the “qualifying event” for purposes of determining eligibility for the subsidy (and for purposes of identifying the notice due date—see “Notices” below for more information).
This new subsidy rule only applies to periods of coverage beginning after March 2, 2010. Thus, if the COBRA periods typically begin on the first of the month, the first subsidized COBRA coverage period resulting solely from this new rule would begin April 1, 2010.
Practice Pointer: The rule does not operate to extend the qualified beneficiary’s COBRA coverage; the COBRA period is still measured based on the original qualifying event that was a reduction in hours of employment. It simply provides a subsidy for any remaining periods of COBRA coverage beginning after that involuntary termination of employment.
However, it does operate to provide a new election period for those who would be AEIs under this rule but failed to elect or elected and subsequently lost coverage. See “New election period” below for more information.
Illustration of the new rule:
#1: ABC, Inc. sponsors a group health plan that only covers full-time employees of the company. Prior to Jan. 15, 2010, Bob was a full-time employee of the company and a participant in ABC’s group health plan.
On Jan. 15, 2010, Bob changes from full-time status to part-time status. Assume for purposes of this illustration that the transition from full-time to part-time status was not a “material negative change” that would otherwise cause the reduction in hours to be treated as an involuntary termination of employment.
Under the terms of ABC’s plan, Bob’s coverage will continue until the end of the month, Jan. 31, 2010, after which he is offered an opportunity to elect 18 months of COBRA.
Bob elects COBRA continuation coverage but he must pay 102% of the applicable premium since the qualifying event was a reduction in hours of employment and not an involuntary termination of employment. On March 10, Bob is involuntarily terminated from the company due to a reduction in force.
Even though Bob’s COBRA qualifying event was a reduction in hours of employment, he is an AEI who may be eligible for up to 15 months of federally subsidized continuation coverage (assuming he is not eligible for other coverage).
Since ABC’s COBRA coverage periods begin on the first of each month, Bob’s first federally subsidized COBRA period will be April 1, 2010 (the first coverage period after the enactment date March 2).
New election period
Individuals who would be an AEI under the new rule described above, but who failed to elect COBRA or elected COBRA and subsequently lost coverage, are entitled to a new election.
Illustrations of this rule:
#2: Same facts as Illustration #1 above except that Bob did not elect COBRA continuation coverage following his qualifying event that was a reduction in hours of employment (i.e., transition from full-time to part-time). Bob is now an AEI entitled to a new election.
#3: Same facts as Illustration #1 above except that Bob’s spouse was also covered under ABC’s health plan on the date of the qualifying event. Although Bob chose COBRA, Bob’s spouse did not. Bob’s spouse is now an AEI entitled to a new election.
Practice Pointer: This new rule does not operate to give would-be AEIs whose COBRA period has already expired a new COBRA continuation period simply because they have an involuntary termination of employment between March 2 and March 31, 2010.
Although the involuntary termination of employment is treated as the qualifying event for purposes of determining eligibility for the new election and the subsidy, the maximum COBRA period is determined in this instance based on the original qualifying event that was a reduction in hours of employment (e.g., if COBRA is typically measured from the date of the qualifying event, COBRA will be measured here from the date of the reduction in hours of employment).
Also, any break in coverage between the reduction in hours and the involuntary termination of employment is not treated as a "break in coverage" for HIPAA portability purposes.
Thus, periods of creditable coverage preceding this break must be included on any certificate of creditable coverage otherwise required by HIPAA and applied towards any pre-existing condition exclusion or limitation period.
Practice Pointer: This new election period should operate similarly to the special extended election period provided under the original ARRA legislation to those would-be AEIs who experienced an involuntary termination of employment on or after Sept. 1, 2008, and who chose not to elect coverage or elected coverage but lost it prior to Feb.17, 2009.
Thus, the same procedures adopted to comply with that rule should, with appropriate modifications, apply here as well.
This new rule is only applicable for periods of coverage beginning after March 2, 2010. Thus, if the plan typically requires that COBRA continuation coverage be paid for on a calendar month basis, then the date that continuation coverage would begin in this instance is April 1, 2010 (see, e.g., Q-48 of IRS Notice 2009-27).
If, however, the plan typically requires COBRA continuation to be paid for on a monthly basis computed from the date coverage is lost, then the coverage start date is not as clear.
The date that COBRA coverage would appear to begin in this instance is the first day of the next COBRA period determined as though the qualified beneficiary elected COBRA following the reduction of hours in employment—and not the date that the subsequent involuntary termination of employment occurs.
This is because the maximum COBRA period is determined based on the qualifying event that is the reduction in hours of employment.
Illustration of this rule:
#4: Same facts as Illustration #2 except that ABC typically requires COBRA continuation coverage be paid for on a monthly basis computed from the date coverage is lost. In this illustration, Bob would have lost coverage on Jan. 15, 2010, and his monthly COBRA periods would run from the 15th of each month through the 14th of the next month. The next COBRA period following Bob’s March 10 termination, if Bob had elected COBRA following the reduction in hours, would begin March 15, 2010.
Arguably, this is the date that Bob’s subsidized COBRA continuation coverage would start under this new rule (although the maximum COBRA coverage period would be measured from the date of the reduction in hours of employment in this example).
Practice Pointer: Using prior IRS guidance, it would appear that plan sponsors may permit would-be AEIs entitled to a new election under this rule to choose a later start date.
Notices
The same general election rules applicable under ARRA and the Defense Act apply equally to qualified beneficiaries whose qualifying event occurs between March 1, 2010, and March 31, 2010. Election notices should be revised to reflect the new sunset date.
In addition, there are special notice rules for those individuals who are AEIs under the Act as a result of a reduction in hours of employment. If AEIs are already receiving COBRA, notice of the new rules must be furnished to such AEIs within 60 days of the date of the involuntary termination of employment.
Although not specifically stated in the Act, the DOL’s reasoning with respect to prior notices suggests that the notice must be furnished to those qualified beneficiaries who experience a voluntary or involuntary termination of employment.
If the would-be AEI is not currently enrolled but is entitled to a new election under the Act, then a revised election notice describing the availability of the subsidy (and the corresponding terms and conditions of eligibility) must be furnished within 60 days of the date of the involuntary termination of employment.
Practice Pointer: The Act refers to the relevant ARRA provisions to describe the notice contents. Under those ARRA rules, notice of the option to enroll in less expensive coverage, if available, had to be included.
Thus, it would appear that same opportunity may be offered would-be AEIs entitled to a new election under the Act.
Other issues
The Act allows the regulators to impose up to a $110/day penalty on plan sponsors who fail to implement the DOL's/Treasury's determination of eligibility within 10 days after receiving notice of the determination.
The Act revised the date that the now 15-month subsidy period begins. Under ARRA, the subsidy period began as of the “first of the month” that the COBRA subsidy period applied.
Thus, if the first COBRA period to which the subsidy applied was July 15, 2009, through August 14, 2009, the subsidy period was measured from July 1, 2009. The act deletes the “first of the month” language. Therefore, the 15-month COBRA subsidy period will be measured from the first day of the first COBRA coverage period to which the subsidy applies.
The Act codifies the clarifications made by the DOL in its model notices with respect to the transition period provided under the Defense Act.
Monday, March 8, 2010
Dental ASO Plans Offer More Value at Lower Cost
By Jack Egan
With health care budgets constrained, companies that want to provide employees with quality dental benefits are discovering an attractive option – Administrative Services Only (ASO) insurance plans. Under an ASO arrangement, an employer self-insures for the benefits it pays out, but uses an outside company to deal with the nuts and bolts of handling claims and paying providers.
One main reason employers choose to go the ASO route is the potential to reduce dental coverage costs by eliminating the need to buy insurance. There are other advantages. A firm is free to customize the dental plan it offers its workers under an ASO. That’s because these self-insured contracts are generally outside the jurisdiction of state insurance regulators.
Self-insured ASO plans are especially appealing to employers with 500 to 5,000 lives because the level of annual claims is fairly predictable. With an ASO a firm is only responsible for paying a claims-processing fee to the administrator, bypassing the risk charge and premium taxes associated with fully insured benefits.
Sophisticated claims system
The Guardian Life Insurance Company of America’s cumulative knowledge and experience with these plans has made it No. 1 in new ASO business cases sold for six out of the past seven years.* “As ASO administrator, we offer the same sophisticated claims system whether a dental plan is fully insured by Guardian or it’s a self-funded ASO company plan,” says Chris Swanker, VP of Guardian Group Dental.
ASO clients gain access to Guardian’s extensive Preferred Provider (PPO) network and leading-edge back-office technologies. “There is no difference in how we administer the benefits or pay claims,” he declares. We treat the ASO customer’s money as if it were our own.”
Reviewing the strength of an ASO carrier’s dental network is also important. Guardian’s DentalGuard Preferred provider network has more than 70,000 dentists at more than 128,000 locations throughout the country. Such breadth permits Guardian to provide dental care discounts of up to 30% below what dentists ordinarily charge.
By having so many dentists in the Guardian PPO network “we can save the employer money for self-funded plans, and we can offer a more competitively priced product on our fully-insured plans,” Swanker observes.
Guardian also offers a unique guarantee to self-insuring employers, a point that brokers should emphasize. Guardian’s pledge is that the combination of our PPO network and automated Dental Review Logic (DRL) program will save companies an amount equal to their annual ASO fee. DRL is a sophisticated claims-processing system that detects unbundling, upcoding and other billing issues. For example, if a cavity is filled and local anesthesia is used, separate bills are sometimes submitted for each procedure. DRL combines the two, resulting in claims savings.
Response time is another factor companies should consider when selecting an ASO carrier. At Guardian, turnaround time for claims submitted is usually three days for either an insured dental plan or an ASO plan. “Our claims approvers do not know if a claim is from a fully insured plan or one in which we are only doing the administration,” notes Lloyd Tereno, second vice president of Guardian Dental Claims.
Guardian is known for its innovative, flexible menu of dental features that also add value – and these are all available on ASO plans as well. Maximum Rollover, for example, lets members store unused annual benefits for later use. The ability to tap what has been rolled over comes in handy if an employee’s benefits exceed the annual maximum at some point in the future. Another feature called Preventive Advantage allows members to obtain preventive care without subtracting the cost from their annual maximum. This frees up money for more extensive dental work.
Maximize choice, minimize cost
For employers, Guardian offers several ASO funding choices to dovetail with an employer group’s financial needs and billing preferences. A direct bill option helps a company manage its cash flow. Guardian pays claims as received and bills an ASO client at the end of month, along with the administrative fee.
With its comprehensive and innovative portfolio of dental plans that helps maximize choice and minimize costs, Guardian has earned a top reputation for servicing the needs of small companies. But midsize employer groups with 500 to 5,000 lives increasingly are finding that Guardian can address their dental coverage requirements with the same broad range of cost-effective options. Dental ASO is a great example of this.
“Guardian understands the needs of employers and their employees and offers options to match anyone’s target price point,” Swanker concludes. “And all of our products and services are available and useful for the entire spectrum of employers.”
* (Listed companies, LIMRA/NADP 2003-2009)
About the author
Jack Egan is a freelance writer based in Los Angeles who has covered most aspects of business, financial markets and personal investing.
With health care budgets constrained, companies that want to provide employees with quality dental benefits are discovering an attractive option – Administrative Services Only (ASO) insurance plans. Under an ASO arrangement, an employer self-insures for the benefits it pays out, but uses an outside company to deal with the nuts and bolts of handling claims and paying providers.
One main reason employers choose to go the ASO route is the potential to reduce dental coverage costs by eliminating the need to buy insurance. There are other advantages. A firm is free to customize the dental plan it offers its workers under an ASO. That’s because these self-insured contracts are generally outside the jurisdiction of state insurance regulators.
Self-insured ASO plans are especially appealing to employers with 500 to 5,000 lives because the level of annual claims is fairly predictable. With an ASO a firm is only responsible for paying a claims-processing fee to the administrator, bypassing the risk charge and premium taxes associated with fully insured benefits.
Sophisticated claims system
The Guardian Life Insurance Company of America’s cumulative knowledge and experience with these plans has made it No. 1 in new ASO business cases sold for six out of the past seven years.* “As ASO administrator, we offer the same sophisticated claims system whether a dental plan is fully insured by Guardian or it’s a self-funded ASO company plan,” says Chris Swanker, VP of Guardian Group Dental.
ASO clients gain access to Guardian’s extensive Preferred Provider (PPO) network and leading-edge back-office technologies. “There is no difference in how we administer the benefits or pay claims,” he declares. We treat the ASO customer’s money as if it were our own.”
Reviewing the strength of an ASO carrier’s dental network is also important. Guardian’s DentalGuard Preferred provider network has more than 70,000 dentists at more than 128,000 locations throughout the country. Such breadth permits Guardian to provide dental care discounts of up to 30% below what dentists ordinarily charge.
By having so many dentists in the Guardian PPO network “we can save the employer money for self-funded plans, and we can offer a more competitively priced product on our fully-insured plans,” Swanker observes.
Guardian also offers a unique guarantee to self-insuring employers, a point that brokers should emphasize. Guardian’s pledge is that the combination of our PPO network and automated Dental Review Logic (DRL) program will save companies an amount equal to their annual ASO fee. DRL is a sophisticated claims-processing system that detects unbundling, upcoding and other billing issues. For example, if a cavity is filled and local anesthesia is used, separate bills are sometimes submitted for each procedure. DRL combines the two, resulting in claims savings.
Response time is another factor companies should consider when selecting an ASO carrier. At Guardian, turnaround time for claims submitted is usually three days for either an insured dental plan or an ASO plan. “Our claims approvers do not know if a claim is from a fully insured plan or one in which we are only doing the administration,” notes Lloyd Tereno, second vice president of Guardian Dental Claims.
Guardian is known for its innovative, flexible menu of dental features that also add value – and these are all available on ASO plans as well. Maximum Rollover, for example, lets members store unused annual benefits for later use. The ability to tap what has been rolled over comes in handy if an employee’s benefits exceed the annual maximum at some point in the future. Another feature called Preventive Advantage allows members to obtain preventive care without subtracting the cost from their annual maximum. This frees up money for more extensive dental work.
Maximize choice, minimize cost
For employers, Guardian offers several ASO funding choices to dovetail with an employer group’s financial needs and billing preferences. A direct bill option helps a company manage its cash flow. Guardian pays claims as received and bills an ASO client at the end of month, along with the administrative fee.
With its comprehensive and innovative portfolio of dental plans that helps maximize choice and minimize costs, Guardian has earned a top reputation for servicing the needs of small companies. But midsize employer groups with 500 to 5,000 lives increasingly are finding that Guardian can address their dental coverage requirements with the same broad range of cost-effective options. Dental ASO is a great example of this.
“Guardian understands the needs of employers and their employees and offers options to match anyone’s target price point,” Swanker concludes. “And all of our products and services are available and useful for the entire spectrum of employers.”
* (Listed companies, LIMRA/NADP 2003-2009)
About the author
Jack Egan is a freelance writer based in Los Angeles who has covered most aspects of business, financial markets and personal investing.
Thursday, March 4, 2010
DOL Publishes Model CHIP Notice for Employers
The DOL has published a model notice that employers can use to satisfy the employer notice requirement under the Children’s Health Insurance Program Reauthorization Act of 2009 (CHIPRA). This legislation imposes notice and disclosure requirements on employers with group health plans in states that provide premium assistance for Medicaid or Children’s Health Insurance Programs (CHIPs).
Please note: Ohio does not have a CHIP premium assistance program, so employers who have employees ONLY in Ohio are not subject to this notification requirement. However, companies with employees who reside in any of the 40 states listed in the model notice must meet the requirement and may use the model notice to do so.
Employers subject to the requirement must provide the employer CHIP notice annually. The initial notice must be distributed by the
later of:
• the first day of the first plan year after February 4, 2010, or
• May 1, 2010.
For calendar-year plans, the first notice must be provided by
January 1, 2011.
Employers can satisfy the requirement by distributing a separate notice or by incorporating it in other plan materials, such as open enrollment materials. A single version of the notice can be distributed in multiple states, and may even be distributed to employees in states that don’t currently provide premium assistance.
If your company has employees outside of Ohio and you would like help ensuring that you meet these requirements, please contact Cindy LaQuatra at BRG. You can reach Cindy by phone at 216-393-1848 or by email at claquatra@benefitsrg.com.
Please note: Ohio does not have a CHIP premium assistance program, so employers who have employees ONLY in Ohio are not subject to this notification requirement. However, companies with employees who reside in any of the 40 states listed in the model notice must meet the requirement and may use the model notice to do so.
Employers subject to the requirement must provide the employer CHIP notice annually. The initial notice must be distributed by the
later of:
• the first day of the first plan year after February 4, 2010, or
• May 1, 2010.
For calendar-year plans, the first notice must be provided by
January 1, 2011.
Employers can satisfy the requirement by distributing a separate notice or by incorporating it in other plan materials, such as open enrollment materials. A single version of the notice can be distributed in multiple states, and may even be distributed to employees in states that don’t currently provide premium assistance.
If your company has employees outside of Ohio and you would like help ensuring that you meet these requirements, please contact Cindy LaQuatra at BRG. You can reach Cindy by phone at 216-393-1848 or by email at claquatra@benefitsrg.com.
Tuesday, March 2, 2010
Employee Communications: trends, fads, and what's next
Communication plays a critical role in engaging employees. Social media, eco-friendly, Web 2.0, traditional- which strategies and tactics connect most effectively with today's workforce?
Employee communications link the goals of the HR and benefits departments with employee awareness, commitment and engagement.
Messages from HR tend to concentrate on issues that have the most impact on the value of the employment experience: compensation, benefits, career development, training and work-life balance.
That means the effectiveness of these communications has a lot to do with how employees view their jobs. According to the 2009 Aon Consulting Benefits and Talent survey, one-third of employers believe communications have a significant impact on employee appreciation of the employment "deal."
With unemployment expected to ease, retaining and engaging employees will again be a critical issue for C-suite leaders. Yet, over the last several years, job satisfaction has been on the decline, with only 45% of Americans being satisfied with their jobs, as reported in the 2009 edition of The Conference Board annual job satisfaction survey.
In a recent study by CareerBuilder, 24% of workers report that they no longer feel loyal to their current company and 19% intend to leave this year. So, what can an organization do?
Clearly, employee communications play a critical role in engaging employees. But even the savviest organizational leaders can be challenged when it comes to effectively reaching their employees. How do you connect with employees when they represent different generations, cultures and communications styles? Should you integrate social media into your communications strategy? How do you get the most value for your communications dollar? What is the best way to deliver eco-friendly communications?
As employers consider how to modernize their employee communications strategies to succeed in today's business environment - and look to you for help - they may have to answer some or all of these questions. The responses will depend on each organization's culture and employee population. It's a challenging balance that requires finding the right mix of the new and the "tried and true."
Green communications
Organizations are embracing technology to reduce costs, be more environmentally friendly and increase efficiency. However, there is a right way to be "green" and a wrong way. Forcing print communications into a paperless format that is distributed electronically without considering how the materials will be used can be a path to failure.
Print communications are linear - typically read in order from the first page to the last page. Electronic and Web communications are more dimensional, with the reader, not the writer, selecting how to access the information.
As a result, electronic content should be organized and formatted differently, with information "chunked" into smaller components that are able to stand alone. Navigation is a key element, and graphics, color palettes and design elements play a different role.
In an effort to be eco-friendly and to save money, many organizations post electronic versions of print materials (such as PDFs) on their company Intranet site. There are several reasons why this is not "green," effective, or less costly:
* Cost-shifting, not cost-saving: It's hard to read print materials on a computer screen. So, the reader usually prints the electronic document to a local office printer. The document is no longer paperless and the cost is shifted from a commercial printer to the office supply vendor.
* Less return on your creative investment: The investment made in the design, look and feel of your important document may be lost when the materials are printed on a one-color office printer which has a much lower quality than the professional press for which it was intended. And, even if the reader doesn't print the document, the content is generally less effective because it was not written to be read and absorbed from a screen.
If your objective is to produce more eco-friendly communications and your documents are designed as print materials, work with your printer to use soy inks and recycled paper or paper that has been certified by the Forest Stewardship Council and the Sustainable Forestry Initiative.
If your intent is to make information available via the Web or an Intranet site, for optimal results make the investment from the beginning to develop communications that are designed to be consumed electronically.
The next level
Being more environmentally friendly is only one reason for using technology in your communications. LinkedIn, Facebook, Twitter, blogs, wikis and other social media have dramatically changed the way we interact with each other. Often referred to as Web 2.0, new media allows people to form communities based on common interests and shared ideas.
Originally popular with young people as a high-tech way to connect with each other, social media is now mainstream. For example, many corporations have Facebook pages and Twitter accounts. So, it makes sense for the HR community to embrace Web 2.0 as another way to communicate with employees.
For example, consider:
■ Creating blogs and wikis as part of the launch of a new program, initiative, or benefit plan to invite feedback and ideas.
■ Using text messages, instant messaging and tweets (Twitter updates) to send brief announcements and reminders (e.g., enrollment deadlines).
■ Building an internal social network site, a la Facebook, that allows employees to share information, ideas, photos, videos and documents, and stay connected.
■ Developing a YouTube-like repository for company videos and recorded presentations.
There are many ways in which new media can be used to engage employees from recruitment through retirement. With some creativity and a little IT help, social media can help employers rethink their HR communications beyond the traditional forms.
Don't abandon the traditional
Everyone is aware of the diversity of today's workforce. For the first time in American history, four different eras are represented in the workforce. Generally defined by age or generation, these groups can be loosely defined as:
■ Generation Y or millenials - born after 1982
■Generation X - born between 1960 and 1982
■Baby Boomers - born between 1943 and 1960
■Traditionalists - born before 1943
Each of these generations has been shaped by the experiences of their time, which affects their approach and preferences for work and communications. For example, consider how the telephone has evolved for each generation:
■Generation Y - everyone has a cell phone and can be reached anytime, anywhere.
■Generation X - home phones became cordless and cell phones were introduced but, early on, were too big to fit into a pocket.
■Baby Boomers - push-button phones were the new innovation.
■Traditionalists - party line phones were not unusual and phone numbers often started with letters, not numbers.
Layered on top of generational differences, employee demographics are diverse and multicultural. So, while there is a strong temptation to embrace technology, new media and eco-friendly methods of communications distribution, it's important to consider the effectiveness traditional communications methods may have for the organization, such as mailing to the home and face-to-face meetings.
If a large percentage of your workforce does not have access to a computer at work, you risk alienating these employees with a heavy reliance on electronic communications. In addition, there is research that shows that both print and Web "cues" are needed to make electronic communications perform as well as traditional print.
Learning information on the Web can be difficult because of the distractions of its interactive nature, such as following hyperlinks, navigating the site, scrolling down, etc. Therefore, if the information you need to share requires concentrated attention and careful decision-making, you may need to offer a variety of media, including print and in-person meetings.
Plus, the low-tech method of mailing communications to the home enables you to reach a very important audience - employees' families.
A matter of balance
As you navigate the new frontiers available in employee communications, you may feel you are in a world where you don't speak the language, completely fluent and well-acclimated, or somewhere in between. But, no matter how you integrate new approaches and techniques into your employee communications strategy, keep in mind these guiding principles:
■ Know your audience and its communications preferences.
■ Make your messages clear and communicate them in ways employees will understand.
■ Know how you need the information to be used by your workforce.
This will help ensure you have the right balance of communications methods that engage employees and achieve your communications objectives. EBA
--------------------------------------------------------------------------------
Box-Farnen is a vice president and communications consultant in Aon's Human Capital Consulting practice in Baltimore, and a member of EBA's editorial advisory board. She can be reached at helen_box-farnen@aon.com.
Employee communications link the goals of the HR and benefits departments with employee awareness, commitment and engagement.
Messages from HR tend to concentrate on issues that have the most impact on the value of the employment experience: compensation, benefits, career development, training and work-life balance.
That means the effectiveness of these communications has a lot to do with how employees view their jobs. According to the 2009 Aon Consulting Benefits and Talent survey, one-third of employers believe communications have a significant impact on employee appreciation of the employment "deal."
With unemployment expected to ease, retaining and engaging employees will again be a critical issue for C-suite leaders. Yet, over the last several years, job satisfaction has been on the decline, with only 45% of Americans being satisfied with their jobs, as reported in the 2009 edition of The Conference Board annual job satisfaction survey.
In a recent study by CareerBuilder, 24% of workers report that they no longer feel loyal to their current company and 19% intend to leave this year. So, what can an organization do?
Clearly, employee communications play a critical role in engaging employees. But even the savviest organizational leaders can be challenged when it comes to effectively reaching their employees. How do you connect with employees when they represent different generations, cultures and communications styles? Should you integrate social media into your communications strategy? How do you get the most value for your communications dollar? What is the best way to deliver eco-friendly communications?
As employers consider how to modernize their employee communications strategies to succeed in today's business environment - and look to you for help - they may have to answer some or all of these questions. The responses will depend on each organization's culture and employee population. It's a challenging balance that requires finding the right mix of the new and the "tried and true."
Green communications
Organizations are embracing technology to reduce costs, be more environmentally friendly and increase efficiency. However, there is a right way to be "green" and a wrong way. Forcing print communications into a paperless format that is distributed electronically without considering how the materials will be used can be a path to failure.
Print communications are linear - typically read in order from the first page to the last page. Electronic and Web communications are more dimensional, with the reader, not the writer, selecting how to access the information.
As a result, electronic content should be organized and formatted differently, with information "chunked" into smaller components that are able to stand alone. Navigation is a key element, and graphics, color palettes and design elements play a different role.
In an effort to be eco-friendly and to save money, many organizations post electronic versions of print materials (such as PDFs) on their company Intranet site. There are several reasons why this is not "green," effective, or less costly:
* Cost-shifting, not cost-saving: It's hard to read print materials on a computer screen. So, the reader usually prints the electronic document to a local office printer. The document is no longer paperless and the cost is shifted from a commercial printer to the office supply vendor.
* Less return on your creative investment: The investment made in the design, look and feel of your important document may be lost when the materials are printed on a one-color office printer which has a much lower quality than the professional press for which it was intended. And, even if the reader doesn't print the document, the content is generally less effective because it was not written to be read and absorbed from a screen.
If your objective is to produce more eco-friendly communications and your documents are designed as print materials, work with your printer to use soy inks and recycled paper or paper that has been certified by the Forest Stewardship Council and the Sustainable Forestry Initiative.
If your intent is to make information available via the Web or an Intranet site, for optimal results make the investment from the beginning to develop communications that are designed to be consumed electronically.
The next level
Being more environmentally friendly is only one reason for using technology in your communications. LinkedIn, Facebook, Twitter, blogs, wikis and other social media have dramatically changed the way we interact with each other. Often referred to as Web 2.0, new media allows people to form communities based on common interests and shared ideas.
Originally popular with young people as a high-tech way to connect with each other, social media is now mainstream. For example, many corporations have Facebook pages and Twitter accounts. So, it makes sense for the HR community to embrace Web 2.0 as another way to communicate with employees.
For example, consider:
■ Creating blogs and wikis as part of the launch of a new program, initiative, or benefit plan to invite feedback and ideas.
■ Using text messages, instant messaging and tweets (Twitter updates) to send brief announcements and reminders (e.g., enrollment deadlines).
■ Building an internal social network site, a la Facebook, that allows employees to share information, ideas, photos, videos and documents, and stay connected.
■ Developing a YouTube-like repository for company videos and recorded presentations.
There are many ways in which new media can be used to engage employees from recruitment through retirement. With some creativity and a little IT help, social media can help employers rethink their HR communications beyond the traditional forms.
Don't abandon the traditional
Everyone is aware of the diversity of today's workforce. For the first time in American history, four different eras are represented in the workforce. Generally defined by age or generation, these groups can be loosely defined as:
■ Generation Y or millenials - born after 1982
■Generation X - born between 1960 and 1982
■Baby Boomers - born between 1943 and 1960
■Traditionalists - born before 1943
Each of these generations has been shaped by the experiences of their time, which affects their approach and preferences for work and communications. For example, consider how the telephone has evolved for each generation:
■Generation Y - everyone has a cell phone and can be reached anytime, anywhere.
■Generation X - home phones became cordless and cell phones were introduced but, early on, were too big to fit into a pocket.
■Baby Boomers - push-button phones were the new innovation.
■Traditionalists - party line phones were not unusual and phone numbers often started with letters, not numbers.
Layered on top of generational differences, employee demographics are diverse and multicultural. So, while there is a strong temptation to embrace technology, new media and eco-friendly methods of communications distribution, it's important to consider the effectiveness traditional communications methods may have for the organization, such as mailing to the home and face-to-face meetings.
If a large percentage of your workforce does not have access to a computer at work, you risk alienating these employees with a heavy reliance on electronic communications. In addition, there is research that shows that both print and Web "cues" are needed to make electronic communications perform as well as traditional print.
Learning information on the Web can be difficult because of the distractions of its interactive nature, such as following hyperlinks, navigating the site, scrolling down, etc. Therefore, if the information you need to share requires concentrated attention and careful decision-making, you may need to offer a variety of media, including print and in-person meetings.
Plus, the low-tech method of mailing communications to the home enables you to reach a very important audience - employees' families.
A matter of balance
As you navigate the new frontiers available in employee communications, you may feel you are in a world where you don't speak the language, completely fluent and well-acclimated, or somewhere in between. But, no matter how you integrate new approaches and techniques into your employee communications strategy, keep in mind these guiding principles:
■ Know your audience and its communications preferences.
■ Make your messages clear and communicate them in ways employees will understand.
■ Know how you need the information to be used by your workforce.
This will help ensure you have the right balance of communications methods that engage employees and achieve your communications objectives. EBA
--------------------------------------------------------------------------------
Box-Farnen is a vice president and communications consultant in Aon's Human Capital Consulting practice in Baltimore, and a member of EBA's editorial advisory board. She can be reached at helen_box-farnen@aon.com.
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