Resolution - 2010 - 10-19 - Adopt The Cobra Amendment - 05/24/2010
RESOLUTION NO. 10-19
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF EAGLE, ADA COUNTY, IDAHO,
ADOPTING THE COBRA AMENDMENT; AUTHORIZING THE MAYOR TO SIGN THE
AMENDMENT; AND PROVIDING FOR AN EFFECTIVE DATE
WHEREAS, The City of Eagle, Ada County, Idaho (the "City"), is a municipal corporation duly
organized and operating under the laws of the State of Idaho; and
WHEREAS, the City Council desires to enter into an agreement with National Benefit Services, Inc. to
administer the COBRA Plan for the City; and
WHEREAS, the City Council desires to adopt the COBRA Amendment and authorize the Mayor to sign
accord ingly.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF EAGLE, ADA
COUNTY, IDAHO, as follows:
RESOLVED, that the COBRA Amendment to the City of Eagle Health Reimbursement Arrangement
HRA Plan (the Amendment) is hereby approved and adopted, and that the authorized representative of the
City, is hereby authorized and directed to execute and deliver to the Administrator of the Plan one or
more counterparts of the amendment.
This Resolution shall take effect and be in force from and after its passage and approval.
Dated this ~I/ M day of May, 2010
CITY OF EAGLE
Ada County, Idaho
,",.....",
'\ ,\ 'I,
........ or EAGf .....
~:- ~ ....... ....../.:-... #,
.:' "" ..- .... .#~*
.. "-.- 0 0 R A l'r-. - .
- I..' v.'
: ...!: o~ . "ic ~
: : u .., : :
: . 411I' __:
. ... . ~' ~ . -
. '. cC '-''''.0-
- . ~p ~. ~
~ ..:~0 ~<t.~.. ~ .:
":... .1'\ ...OR POIlI'...C\ ~ ......
, Y'r ...... ,v "
'" -1 7'E o~ \ ,....
"" ~"""
""11..11"
ATTEST:
A fl (AA-t~'i, ~
'"'SHARON K. BERGMANN
CITY CLERK/TREASURER
C.\Documents and Settings\sbergmann\Local Settings\Temporary Internet Files\ContentOutlook\37SG690F\Resolution 10-19 COBRA
AmendmenLdoc
SERVICE AGREEMENT
t iiS[Olner
RVICES, LLC
.,K
Organ Izu! ion al
ce
COBRA
SERVICE AGREEMENT
Employer:
City of Eagle
Engagement. The above named employer ("Employer") hereby retains National Benefit Services, LLC
("NBS"), a Utah limited liability company, (collectively referred to as the "parties" herein), to provide
certain non-discretionary, ministerial administrative services with respect to COBRA requirements as
described in Schedule A attached to this Agreement.
Relationship of the Parties. Because Employer is subject to federal requirements imposed by the
Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) to offer health benefit continuation
coverage to certain individuals who would otherwise lose group health coverage; and because NBS is
willing to provide administrative services to assist Employer in meeting the requirements of COBRA; the
parties agree as follows:
1. Definitions. The following terms have the associated meaning as used in this Agreement,
including any attachments.
A. Group Health Plan-Any plan, fund or program established or maintained by Employer
for the purpose of providing medical, surgical, or hospital care or benefits, or benefits in
the event of sickness, accident, disability or other enumerated benefits for its employees,
former employees, or their beneficiaries. As used herein, "enumerated benefits" shall
include any group dental, vision, or FSA plan which is established or maintained by
Employer.
B. Participant-Any Qualified Beneficiary or dependent of a Qualified Beneficiary who has
elected to participate in COBRA by completing a COBRA emollment application, and has
not been disqualified from participation because of non-payment of COBRA premiums.
C. Qualified Beneficiary-Any employee or dependent who is covered under the Group
Health Plan on the day before a Qualifying Event.
D. Qualifying Event-Any of the occurrences listed below, which cause an employee or
dependent who is covered under the Group Health Plan to be disqualified from group
coverage:
1. Termination of employment of employee for any reason (other than for gross
miscond uct)
ii. Reduction of employee's work hours, including work stoppage and non-FMLA
leave-of-absence
iii. Employee's divorce or legal separation from spouse which disqualifies the
spouse from coverage under the Group Health Plan
iv. Employee's dependent child's disqualification from coverage under the Group
Health Plan because the child loses dependent status under the terms of the
Group Health Plan.
v. Employee's dependent ceases to qualify for dependent coverage because
employee becomes entitled to Medicare.
vi. Employee's dependent ceases to qualify for dependent coverage because of the
death of the covered employee.
vii. Bankruptcy of the Employer may constitute a Qualifying Event for retirees (and
their dependents) who are covered by the Group Health Plan.
2. NBS Services. NBS shall provide for Employer the services enumerated on Schedule A, which is
attached and hereby incorporated into this Agreement. The provision of any services which are not
included on Schedule A by NBS shall not constitute a modification of this agreement, and shall not
guaranty the ongoing provision of such services.
3. Employer Obligations to NBS. Employer shall perform the responsibilities enumerated on Schedule
C, which is attached and hereby incorporated into this Agreement. The failure to perform the
Employer Obligations enumerated on Schedule C will constitute a material breach of the provisions
of this agreement. Employer also shall pay the fees enumerated on Schedule B unless payment is
arranged through a third party.
4. NBS Trust Account. Employer agrees that all funds and contributions under the Plan remitted to
NBS shall be deposited to NBS's trust account. Employer agrees to be bound by the operating
guidelines for such trust account as set forth herein. Such funds or contributions from Employer
shall, at all times, be and remain subject to control of Employer until disbursed pursuant to the Plan.
NBS shall pay the payments and reimbursements allowed under the Plan as well as fees and costs of
NBS (if payment or reimbursement is not otherwise made or provided for), and any other amounts
authorized by Employer. All such books and records, bank statements and canceled checks regarding
the Plan and the trust account shall be retained and stored by NBS. The operating guidelines for such
trust account are as follows:
A. An administration fee of 2% of the entire premium for coverage under the Group Health
Plan will be retained by NBS from payments received from participants and is not included
as a part of the trust assets;
SERVICE AGREEMENT (REv. 6.1.09)
PAGE 2 OF 5
B. NBS will maintain accurate records of the amounts remitted to NBS with respect to the Plan
so as to facilitate proper accounting of the contributions into and from the trust account;
C. NBS will draw no check from the trust account on behalf of the Plan where such check would
have the effect of drawing the balance for the Plan into a negative status;
D. The name of the trust account will be in the name of NBS but designated as a "trust account"
or as an "agency account" or other designation which indicates the agency position of NBS
with respect to the trust account;
E. NBS shall not be liable for any earnings on the trust account; and
F. NBS shall maintain fidelity bonding in an amount of not less than $50,000 on all of its
employees who handle or control funds or moneys in the trust account.
5. Access to Records. The records of the Plan maintained by NBS shall be open to examination by
the Employer (the Administrator of the Plan), government regulatory agencies, or any other
person or authorized representative who, by law or provisions of the Plan, is permitted access to
such records.
6. Written Directions. So that adequate records may be maintained, the parties each agree to give
directions, instructions and other communications, as needed, to each other in written form in the
manner and location ideated below as acceptable for delivery and receipt of notice of termination
under this agreement.
7. Nonexclusive Services. The parties hereto acknowledge and agree that NBS will be performing
similar services and other types of work for other employee benefit Plans. Nothing contained in
this Agreement shall grant to any party any right, title or interest in or to the business activities or
opportunities of any other party or the power or authority to contract on behalf of the other
parties other than as specifically provided in this Agreement.
8. Termination. Either party may terminate this agreement upon giving at least thirty (30) days
prior written notice to the other party. NBS shall be entitled to the full payment of all fees for
services rendered through the date of termination and for copy charges associated with any
requests for Plan records or documents. Notice of termination may be delivered personally or by
the following means:
By Mail: COBRA at National Benefit Services
P.O. Box 6980
West Jordan, UT 84084
By E-Mail: service@nbsbenefits.com
By Fax: 866-909-6525
9. Indemnification. Employer agrees to defend, hold harmless and indemnify NBS from all liability
arising from Employer's failure to satisfy the obligations under this agreement, and NBS agrees
to defend, hold harmless and indemnify Employer from all liability arising from NBS' failure to
satisfy the obligations under this agreement. The indemnification includes the expenses of
defending or settling any court proceeding brought against NBS or Employer by any third party.
Employer is not required to indemnify NBS and NBS is not required to indemnify Employer for
any liability for which the other Party is found to be solely responsible.
SERVICE AGREEMENT (REv 6.I09)
PAGE 3 OF 5
10. Integration and Severability. This Service Agreement, together with all attachments hereto, represents
the entire agreement of the parties, and supersedes any prior agreement as to the subject matter
contained herein. In the event that any provision or portion of this agreement is declared void or
unenforceable in a court of law, the remaining provisions of this contract shall remain binding upon the
parties as if the void or unenforceable provision had not been included. No modification of this
agreement shall be effective unless in writing and signed by both parties.
11. NBS Not a Plan Administrator or Fiduciary. By signing below, the parties acknowledge that NBS'
provision of record-keeping and administrative services hereunder is not intended to make NBS a Plan
Administrator or a Fiduciary to the Plan as those terms are defined in ERISA 9 3. The parties further
acknowledge that this agreement does not grant to NBS any discretionary authority or control respecting
management or administration of the Plan. The parties understand that NBS provides no accounting
services outside of the record-keeping services required for the Plan. NBS does not provide legal
services. Accordingly, all plan documents and forms completed by NBS should be reviewed by
competent legal counsel.
12. Compliance/Breach. If Employer fails to comply with any of the terms and conditions contained in the
Service Agreement, Employer will be in breach of contract and NBS shall have the right to cease
immediately to provide any further services to Employer or Plan without waiving NBS' right to receive
payment for services rendered and costs incurred.
13. Miscellaneous provisions:
A. The nonprevailing party shall pay all costs and expenses, including reasonable attorney fees,
incurred by the prevailing party in enforcing its rights under this agreement.
B. Each party shall obtain the prior written consent of the other party concerning the content and
plan of distribution of any public announcement, press release or advertisement concerning this
agreement.
C. NBS shall keep confidential, and may not disclose to any third person, all information that it has,
obtains, develops or utilizes in connection with performing services pursuant to this Agreement,
including but not limited to (a) all written or oral information, data, reports, opinions,
conclusions, analyses, materials, and other work product, regardless of format, which are
provided by Employer or developed for Employer; (b) any credit, legal, asset, economic,
marketing, collateral files, donor lists, patient information and (c) the substance, terms, conditions
or fact or any discussions between Employer and NBS concerning this agreement or any of the
foregoing (collectively the "Confidential Information"). Both parties acknowledge that the
restrictions relating to Confidential Information obtained pursuant to this Agreement are
reasonable and necessary, that violation of these restrictions could cause damage to the other
party, and that the other party will be entitled to injunctive relief against each violation. This
section shall survive any termination, cancellation or expiration of this Agreement.
SERVICE AGREEMENT (REv. 6.109)
PAGE 4 OF 5
D. Paragraph headings are for convenience. It is agreed that the standard of care imposed upon
NBS by this Agreement is to act with the care, skill, prudence, and diligence under the
circumstances then prevailing that a prudent person acting in a like capacity and familiar with
such matters would use in the conduct of an enterprise of a like character and with like aims.
NBS shall be solely responsible for the conduct and control of the work to be performed under
this Agreement by NBS and its representatives, subcontractors, agents or employees. The parties
submit to the exclusive jurisdiction of and venue in the appropriate courts located in Salt Lake
County, Utah.
E. For provision of all services selected by the employer and provided by NBS, time is of the
essence. Failure by the Employer to comply with the timing provisions specifically
identified herein shall constitute a violation of the terms of this agreement. In the context
of Employer's provision of information, in no event is the furnishing of information
considered timely if it occurs beyond the deadline specified in the request for
information. For most plans, NBS requires information necessary to perform year-end
testing no later than one month following the end of the plan year. Other deadlines may
apply depending upon the type of Plan, which will be identified with specificity in
notices provided to the Employer.
IN WITNESS HEREOF, the parties hereto have executed this Service Agreement on the date below written.
EMPLOYER
Signed:
Title:
Date:
NATIONAL BENEFIT SER~ LLC
Signed: -Pc &Q ~ ~
Title: President
Date: Mav 5. 2010
SERVICE AGREEMENT (REv. 6.1.09)
PAGE 5 OF 5
SCHEDULE A
fioil'il
COBRA
SCHEDULE OF NBS SERVICES
NBS shall provide the following services for Employer:
A. Create and mail initial COBRA notification to Employer's employees and dependents when
they first become eligible for coverage through the Group Health Plan
B. Create and mail the COBRA notice and election packet to Qualified Beneficiaries within
fourteen (14) days of notice from Employer that a Qualifying Event has occurred.
C. Create and mail other notices to Qualified Beneficiaries when and as required under changes
to federal law, including but not limited to any additional notices required under the
American Recovery and Reinvestment Act of 2009.
D. Upon receipt of COBRA election and payment of initial premium, emoll Qualified
Beneficiaries in COBRA.
E. Create and mail monthly premium statements to COBRA emollees.
F. Receive Participant payments.
G. Provide monthly reports to Employer which shall include:
1. Notification Report listing any Qualifying Events for which notices were mailed out
for the previous month;
ii. Department of Labor Report listing any general notices mailed to newly eligible
employees for the previous month;
m. Payment History Report listing any payments received from Participants for the
previous month;
lV. Termination Report listing any Qualifying Events consisting of termination for any
reason for the previous month; and
v. ARRA Premium Report (any reduced premiums received from ARRA-eligible
Participants for the previous month.
H. Serve as a COBRA non-discretionary information resource to Employer and Participants as
follows:
i. COBRA information is available online at www.nbsbenefits.com.
Schedule B
Page 2 of 2
H. You may also contact us at (801) 532-4000 (Salt Lake City Area) and (800) 274-0503,
Monday through Friday, 8:00 a.m.-5:00 p.m., Mountain Time.
I. Manage relationship with Participants and Employer through provision of telephone
information and support regarding eligibility, emollment and billing.
J. Perform all duties enumerated in this Agreement in accordance with COBRA requirements.
K. Manage relationship with Participants to collect COBRA premiums and notices
regarding late payments or termination of coverage.
L. Transmission of insurance premium portion of payment received from Participant to
Employer.
Employer understands that the Services enumerated herein reflect the requirements and
procedures dictated by federal law. If the requirements and procedures are changed by law, NBS
may amend this Schedule to incorporate the changes in the law and provide such amendment to
the Employer. Employer will be deemed to have accepted and approved each amendment hereto if
Employer does not notify NBS in writingt within 30 days after receipt of the amendment that it
objects to any provision of the Amendment hereto.
Schedule B
nee
COBRA
FEE SCHEDULE
SET-UP
Set Up............................................................................................................................ .............. ...Included
· Includes Consultation and Toll-Free Phone Assistance, Customized Database for all Plan Types offered and
Insurance Rates, Establish Web Site Access for Notification
Takeover Fee for those Currently on COBRA ...................................................................................................................... Waived
OneTime Charge. Includes Correspondence, Takeover of Billing, Notices (including ARRA) and Support Services.
Initial Notification - All Employees ................................................................................................................................... Included
· COBRA requires Description Material be sent to each Eligible Employee and Eligible Dependents. Fee Waived if
Employer Certifies Compliance.
ADMINISTRATION SERVICES
Monthly Maintenance Fee........................................................................................................... . (Paid for by your Agent/Broker)
· Includes Consultation and Support Services to Company and Employees, Insurance. Company Interface and Rate
Changes, Computer Program and Web Maintenance, COBRA Legislative Updates, and Maintenance of Database Files.
Qualifying Event Fee................................................................................................................................... .............................. Included
· Notification and Election Form, Enrollment and Eligibility Processing, Monthly Premium Billing and Collection,
Late Notices, Data Archiving and other Services such as Terminated Employees Phone Calls.
Initial Notification - Newly Eligible Employees ................. ..... .................................. ............... .......................................... Included
· Includes Initial Notification sent to each Newly Insured Employee and Covered Spouse, and Document Archiving.
National Benefit Services, LLC appreciates the opportunity to satisfy your plan administration and consulting needs. We
look forward to being of service
Company Name City of Eagle
Employer Signature Date
t1~~~~
National Benefit Services, LLC Signature
Date
8523 South Red?:vood
Hiesl Jordan, trr 84088 '"
27,i-V503 w www.NBSbenefits.com
COBRA.2KB
Sched ule C
C~usfo!'nf!r 'C~fJ're ..
izalimlal F:
enef
COBRA
SCHEDULE OF EMPLOYER RESPONSIBILITIES
Employer shall have the following obligations to NBS:
A. Make available to COBRA Participants the same Group Health Plan options as are
available to Employer's current employees and dependents.
B. Complete the COBRA initial notice form online on the NBS website
www.NBSbenefits.com and submit to NBS when employees or dependents first become
eligible for coverage under the Group Health Plan, within 31 days of the effective date
for coverage under the Group Health Plan.
e. Notify NBS of the following Qualifying Events no later than 30 days after occurrence on
the NBS website www.NBSbenefits.com:
a. death of a covered employee;
b. termination or reduction of hours of the covered employee;
c. the covered employee becomes entitled to Medicare; or
d. the commencement of a bankruptcy proceeding of the employer.
D. Notify NBS of receipt of notice from the Employee or Qualified Beneficiary of the
Qualifying Events of divorce or legal separation of the covered employee from his or her
spouse, and of a dependent child ceasing to be a dependent under the Group Health Plan
within 60 days of occurrence of the Qualifying Event.
E. Review NBS report of COBRA notices sent to confirm NBS was properly notified
F. Reinstate Participants in the Group Health Plan
G. Receive premium payments from NBS for COBRA participants and pay billing from
applicable insurance carrier
H. Terminate qualified beneficiary coverage with applicable insurance carrier based upon
review of the email termination report and/or an email of a written notification provided
by NBS
1. Communicate ALL transactions directly with the insurance carrier -NBS does not
correspond with the insurance carrier directly
J. Employer shall be responsible for all COBRA events prior to contract with NBS
Schedule C
Page 2 of 2
K. Pay NBS the costs associated with this agreement. Employer may arrange for payment
by a third party, but should the third party fail to pay, Employer will be billed for any
unpaid amounts.
Employer understands that as a condition of NBS providing the services enumerated in Schedule A, Employer shall
timely and accurately perform all of the enumerated responsibilities and provide the information required in this
Schedule and any amendments thereto. NBS reserves the right to request additional information from Employer at
any time. NBS shall be entitled to rely on any information provided by Employer as accurate, valid, and complete.
Employer understands that the Responsibilities enumerated herein reflect the requirements and procedures dictated
by federal law. If the requirements and procedures are changed by law, NBS may amend this Schedule to
incorporate the changes in the law and provide such amendment to the Employer. Employer will be deemed to have
accepted and approved each amendment hereto if Employer does not promptly notify NBS in writing within 30 days
after receipt of the amendment that it objects to any provision of the Amendment hereto.
ARRA
COBRA AMENDMENT
ARTICLE I
PREAMBLE
1.1 Adoption and effective date of amendment. The Employer adopts this Amendment to City of
Eagle HRA Plan ("Plan") to reflect certain provisions of the American Recovery and
Reinvestment Act of 2009 (ARRA). The sponsor intends this Amendment as good faith
compliance with the requirements of these provisions. This Amendment shall be effective on the
date stated in Section 2.1 below.
1.2 Supersession of inconsistent provisions. This Amendment shall supersede the provisions of the
Plan to the extent those provisions are inconsistent with the provisions of this Amendment.
ARTICLE II
COBRA
(If Applicable)
2.1 Effective Date. The COBRA provisions under the ARRA Amendment are effective as of
March 1, 2009.
2.2
COBRA provisions. The Plan's provisions concerning COBRA are amended as provided below
to allow for (1) payment of reduced premiums and the provision of a second election period by
certain COBRA qualified beneficiaries, (2) the provision for additional COBRA notices, and (3) an
exception to the rules for crediting certain prior coverage. This amendment does not apply to a
health flexible spending account.
\.
The COBRA continuation coverage provisions of the Plan shall be administered in accordance
with the requirements of ARRA Section 3001 with respect to "assistance eligible individuals," as
defined in ARRA Section 3001(a)(3). Notwithstanding any other Plan provision to the contrary,
the Plan shall determine whether an individual has had a 63-day break in coverage for purposes
of determining creditable coverage under the Health Insurance Portability and Accountability
Act (HIPAA), in accordance with the terms of ARRA Section 3001.
This amendment has been executed this Z,?,';'"
day of
~~
,2010.
Name of Employer:
City of Eagle
BY~~
ARRA
CERTIFICATE OF ADOPTING RESOLUTION
The undersigned authorized representative of City of Eagle (the Employer) hereby certifies that
the following resolutions were duly adopted by Employer on ,2010, and
that such resolutions have not been modified or rescinded as of the date hereof;
RESOLVED, that the Amendment to the City of Eagle HRA Plan (the Amendment) is hereby
approved and adopted, and that an authorized representative of the Employer is hereby authorized and
directed to execute and deliver to the Administrator of the Plan one or more counterparts of the
amendment.
The undersigned further certifies that attached hereto is a copy of the Amendment approved and
adopted in the foregoing resolution.
Date:
Signed:
[print name/title]
(
\