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REQUEST FOR LIMITED PLAN WAIVER

PLAN NAME: SECURITY BENEFIT FUND OF THE UNIFORMED FIREFIGHTE.RS ASSOCIATION OF


NEW YORK CITY
PLAN TYPE: MUNICIPAL SUPPLEMENTAL HEALTH AND WELFARE 8ENEFlT FUND
PLAN YEAR FOR WHICH WAIVER IS REQUESTED' JULY 1, 2011 - JUNE 30, 2012
BACKGROUND: The Plan is a health and welfare benefit plan established under the proviSions of an
Agreement and Declaration of Trust between Its Trustees and the Uniformed Firefighters Associatton of
Greater New York, Local 94 IAF.F., AFL-CIO (the UFA). Participants are firefighters, fire marshals, marine
engmeers, pilots, and uniformed wipers who are covered by collective bargaining agreements between the
City of New York and the UFA.
Benefits The Plan provides preSCrIption drug, dental, optical, hearing aid. life insurance. supplemental
health insurance, certain widows' benefits and other benefits to eligible participants and their covered
dependents.
Contributions - The Plan is funded by employer contributions and participants' COBRA contributions.
Employer contributions are determined by collective bargaining agreements between the City of New York
and the UFA.
APPLICATION COMPONENTS:
The terms of the plan or policy fOrln(s) for which a waiver is sought
SEE ATTACHED
2. The number of individuals covered by 1I1e plan or policy form(s);
APROX1MATELY_EXCLUDING DEPENDENTS
3. The annual and rates applicable to the plan or policy form(s),
THE PRESCRIPTION DRUG BENEF!T IS LIMITED TO fIIIPER FAMILY PER
CALENDAR YEAR
4. A brief description Of why compliance with the regulations would result ill a significant
decrease in access to i)enefits for those currently covered by the plan or policy. or a significant
increase in premiums paid by those covered by the plan or polley, along with any supporting
documentation; and
PRESCRIPTION DRUG EXPENSES REPRESENT APPROXIMATEL Y_/a OF
TOTAL FUND BENEFIT EXPENDITURE. AS SUCH, REMOVAL OF THE .A.NNUAL
BENEFIT CAP ON THE PHARMACY BENEFIT WILL NECESSITATE LARGE SCALE
PLAN REDESIGN RESULTING IN COST INCREASES FOR MEMBERS, EITHER IN
THE FORM OF INCREASED CO PAYS/COINSURANCE AND/OR REQUIRED MEMBER
CONTRIBUTUIONS TOWARDS COVERAGE. GIVEN THAT THE FUND'S INCOME IS
LIMITED TO FIXED DOLL.A,R CONTRIBUTIONS FROM THE CITY OF NEW YORK, AND
IS A SUBJECT OF COLLECTIVE BARGAINING, ELIMINATION OF THE BENEFIT CJ:\P
ON THE PHARMACY BENEFIT WILL HAVE AN ADVERSE IMPACT ON THE FUND'S
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LONG-TERM ABILITY TO CONTINUE TO PROVIDE ITS MEMBERS WITH ACCESS TO
PHARMACY BENEFITS AS WELL AS OTHER BENEFITS SUCH AS DENTAL, VISION,
HEARING.
5. An attestation, signed by the plan administrator or clllef executive officer of the insurer,
certifying thaI (i) the plan or policy was in force prior to September 23,2010, and (il) the application
of restricted annual limits to the plan or policy would result in a significant decrease in access to
benefits for those currently covered by the plan or policy, or a significant increase in premiums paid
by those covered by the plan or policy
I, THE UNDERSIGNED PLAN ADMINISTRATOR, CERTIFY THAT (i) THE PLAN
REFENCED IN THIS APPLICATION WAS IN FORCE PRIOR TO SEPTEMBER 23,2010.
AND (ii) THAT THE APPLICATION OF RESTRICTED ANNUAL LIMITS TO THE PLAN
WOULD RESULT IN SIGNIFICANT DECREASE IN ACCESS TO BENEFITS FOR
THOSE CURRENTLY COVERED BY THE PLAN. OR A SIGNIFICANT INCREASE IN
::::1UM/J R E D BY THE PLAN.
Title: TFflJ ;;Uf..ff(.
Date: -1J':> a I I ti __._._..__ .
Phone 1 ~
E-mail;
Address: B ::n .R A U B~ \.\ A N '1<:.... <:)RG
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file:///C|/...ty%20Benefit%20Fund%20of%20the%20Uniformed%20Firefighters%20Assoc%20of%20New%20York%20City/WAIVER.txt[08/15/2011 11:10:46 AM]
From: Carapella,Theresa [tcarapella@ufanyc.org]
Sent: Monday, November 22, 2010 2:25 PM
To: HHS HealthInsurance (HHS)
Subject: WAIVER
Attachments: B2_Health Book_Ch01_Security Benefits Fund_11-10.pdf;
Limited Plan Waiver..pdf
<<B2_Health Book_Ch01_Security Benefits Fund_11-10>> <<Limited Plan Waiver..pdf>>
The attached booklet summarizes Welfare Benefits for Active and Retired Firefighters although the Waiver application
is specific to the Active Fund.
STATEMENT OF CONFIDENTIALITY

The information contained in this electronic message and any attachments to this message are intended for the
exclusive use of the addressee(s) and may contain confidential or privileged information. If you are not the intended
recipient, please notify us immediately by e-mail reply to sender or by telephone to Uniformed Firefighters Association
at (212) 683-4832, and destroy all copies of this message and any attachments. Please note that any views or opinions
presented in this email are solely those of the author and do not necessarily represent those of the Uniformed
Firefighters Association.
Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts
no liability for any damage caused by any virus transmitted by this email.
UFireA:000003
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Pages 4 through 42 redacted for the following reasons:
- - - - - - - - - - - - - - - - - - - - - - - - - - - -
Exemption 4
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file:///C|/...ty/Uniformed%20Firefighters%20Association%20of%20New%20York%20Waiver%20Application%20Dec%209%202010.htm[08/15/2011 11:10:47 AM]
From: Morales, Veronica (HHS/OCIIO)
Sent: Thursday, December 09, 2010 3:02 PM
To: 'bstraub@ufanyc.org'
Cc: 'Tcarapella@ufanyc.org'; Sheer, Jennifer (HHS/OCIIO)
Subject: Uniformed Forefighters Association of New York, Waiver Application
Attachments: Waiver Application Form.xls

Dear Mr. Straub:

Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act
(PHS Act) Section 2711. In order to expedite your application, please provide the following information:

I. Please complete the entire annual limits spreadsheet, [attached to the email] [and available at:
http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html]. Please return the completed spreadsheet
to this email address as an attachment. We will only be able to process spreadsheets that are fully complete
(i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain to
your plan, please write None, and/or provide an explanation regarding why you are unable to complete
that particular cell in a separate document.

II. In addition, please provide the following information:

Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?

Confirm whether the plan was created pursuant to the Taft-Hartley Act.


In order to complete your application, please provide this information by 5:00 pm, December 10, 2010. Once this
information is received and the application is complete, it will be processed by the Department of Health and Human
Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30
days of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decision.

Thank you.

Veronica W. Morales, J.D.
U.S. Department of Health & Human Services
Office of Consumer Information & Insurance Oversight
Office of Consumer Support
Phone# (301) 492-4249
Email: veronica.morales@hhs.gov

INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distributed,
or copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.

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file:///C|/...f%20the%20Uniformed%20Firefighters%20Assoc%20of%20New%20York%20City/Request%20for%20info%2012.13.10.htm[08/15/2011 11:10:47 AM]
From: Moultrie, Cam (HHS/OCIIO)
Sent: Monday, December 13, 2010 2:54 PM
To: bstraub@ufanyc.org
Cc: Habit, Sandra (HHS/OCIIO)
Subject: Waiver Application for UFA Security Benefits Fund
Dear Mr. Straub:

Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act
(PHS Act) Section 2711. In order to expedite your application, please provide the following information:

I. Please complete the entire annual limits spreadsheet available at:
http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed spreadsheet
to this email address as an attachment. We will only be able to process spreadsheets that are fully complete
(i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain to
your plan, please write None, and/or provide an explanation regarding why you are unable to complete
that particular cell in a separate document.

II. In addition, please provide the following information:

Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?

Confirm whether the plan was created pursuant to the Taft-Hartley Act.

In order to complete your application, please provide this information by 5:00 pm, December 15, 2010. Once this
information is received and the application is complete, it will be processed by the Department of Health and Human
Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30
days of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decision.

Thank you.


Cam Lynne Moultrie
Office of Consumer Information and Insurance Oversight
U.S. Department of Health and Human Services
(301) 492-4174
cam.moultrie@hhs.gov





INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distributed, or
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.

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file:///C|/...Uniformed%20Firefighters%20Assoc%20of%20New%20York%20City/Request%20for%20info%20resposne%2012.14.10.htm[08/15/2011 11:10:48 AM]
From: Moultrie, Cam (HHS/OCIIO)
Sent: Tuesday, December 14, 2010 3:52 PM
To: Habit, Sandra (HHS/OCIIO)
Subject: FW: Waiver Application for UFA Security Benefits Fund
Attachments: UFA waiver_application_form.xls


Cam Lynne Moultrie
Office of Consumer Information and Insurance Oversight
U.S. Department of Health and Human Services
(301) 492-4174
cam.moultrie@hhs.gov





INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distributed, or
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.

From: Carapella,Theresa [mailto:tcarapella@ufanyc.org]
Sent: Tuesday, December 14, 2010 2:54 PM
To: Moultrie, Cam (HHS/OCIIO)
Subject: FW: Waiver Application for UFA Security Benefits Fund

I. Please complete the entire annual limits spreadsheet available at:
http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed
spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that
are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet
does not pertain to your plan, please write None, and/or provide an explanation regarding why you are
unable to complete that particular cell in a separate document.
SEE ATTACHED FOR COMPLETED SPREADSHEET

II. In addition, please provide the following information:

Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140? YES, PLAN WAS IN EXISTENCE PRIOR TO MARCH 23,
2010. PLAN IS ALSO IN COMPLIANCE WITH GRANDFATHERING PROVISIONS.

Confirm whether the plan was created pursuant to the Taft-Hartley Act. NO

Please let me know if you have questions or need anything further.

Thank you.

Theresa Carapella
Benefits Administrator
Uniformed Firefighters Association
Security Benefit Fund
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file:///C|/...Uniformed%20Firefighters%20Assoc%20of%20New%20York%20City/Request%20for%20info%20resposne%2012.14.10.htm[08/15/2011 11:10:48 AM]

(212) 545-6960
STATEMENT OF CONFIDENTIALITY: The information contained in this electronic message and any attachments to this message are intended for the exclusive use of
the addressee(s) and may contain confidential or privileged information. If you are not the intended recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4723, and destroy all copies of this message and any attachments.

From: Straub,Bob
Sent: Monday, December 13, 2010 3:43 PM
To: Carapella,Theresa
Subject: FW: Waiver Application for UFA Security Benefits Fund



From: Moultrie, Cam (HHS/OCIIO) [mailto:Cam.Moultrie@hhs.gov]
Sent: Monday, December 13, 2010 2:54 PM
To: Straub,Bob
Cc: Habit, Sandra (HHS/OCIIO)
Subject: Waiver Application for UFA Security Benefits Fund
Dear Mr. Straub:

Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act
(PHS Act) Section 2711. In order to expedite your application, please provide the following information:

I. Please complete the entire annual limits spreadsheet available at:
http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed
spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that
are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet
does not pertain to your plan, please write None, and/or provide an explanation regarding why you are
unable to complete that particular cell in a separate document.

II. In addition, please provide the following information:

Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?

Confirm whether the plan was created pursuant to the Taft-Hartley Act.

In order to complete your application, please provide this information by 5:00 pm, December 15, 2010. Once this
information is received and the application is complete, it will be processed by the Department of Health and
Human Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision
within 30 days of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver
decision.

Thank you.

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file:///C|/...Uniformed%20Firefighters%20Assoc%20of%20New%20York%20City/Request%20for%20info%20resposne%2012.14.10.htm[08/15/2011 11:10:48 AM]

Cam Lynne Moultrie
Office of Consumer Information and Insurance Oversight
U.S. Department of Health and Human Services
(301) 492-4174
cam.moultrie@hhs.gov





INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distributed, or copied to
persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.



STATEMENT OF CONFI DENTI ALI TY

The i nf or mat i on cont ai ned i n t hi s el ect r oni c message and any at t achment s t o
t hi s message ar e i nt ended f or t he excl usi ve use of t he addr essee( s) and may
cont ai n conf i dent i al or pr i vi l eged i nf or mat i on. I f you ar e not t he i nt ended
r eci pi ent , pl ease not i f y us i mmedi at el y by e- mai l r epl y t o sender or by
t el ephone t o Uni f or med Fi r ef i ght er s Associ at i on at ( 212) 683- 4832, and dest r oy
al l copi es of t hi s message and any at t achment s. Pl ease not e t hat any vi ews or
opi ni ons pr esent ed i n t hi s emai l ar e sol el y t hose of t he aut hor and do not
necessar i l y r epr esent t hose of t he Uni f or med Fi r ef i ght er s Associ at i on.
Fi nal l y, t he r eci pi ent shoul d check t hi s emai l and any at t achment s f or t he
pr esence of vi r uses. The company accept s no l i abi l i t y f or any damage caused by
any vi r us t r ansmi t t ed by t hi s emai l .
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file:///C|/...%20Uniformed%20Firefighters%20Assoc%20of%20New%20York%20City/Additional%20info%20requested%2012.28.10.htm[08/15/2011 11:10:48 AM]
From: Moultrie, Cam (HHS/OCIIO)
Sent: Tuesday, December 28, 2010 3:07 PM
To: Carapella,Theresa
Cc: Habit, Sandra (HHS/OCIIO)
Subject: RE: Waiver Application for UFA Security Benefits Fund
Please provide a breakdown of individuals in each tier (column P).

Thank you.


Cam Lynne Moultrie
Office of Consumer Information and Insurance Oversight
U.S. Department of Health and Human Services
(301) 492-4174
cam.moultrie@hhs.gov





INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distributed, or
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.

From: Carapella,Theresa [mailto:tcarapella@ufanyc.org]
Sent: Tuesday, December 14, 2010 2:54 PM
To: Moultrie, Cam (HHS/OCIIO)
Subject: FW: Waiver Application for UFA Security Benefits Fund

I. Please complete the entire annual limits spreadsheet available at:
http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed
spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that
are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet
does not pertain to your plan, please write None, and/or provide an explanation regarding why you are
unable to complete that particular cell in a separate document.
SEE ATTACHED FOR COMPLETED SPREADSHEET

II. In addition, please provide the following information:

Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140? YES, PLAN WAS IN EXISTENCE PRIOR TO MARCH 23,
2010. PLAN IS ALSO IN COMPLIANCE WITH GRANDFATHERING PROVISIONS.

Confirm whether the plan was created pursuant to the Taft-Hartley Act. NO

Please let me know if you have questions or need anything further.

Thank you.

Theresa Carapella
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file:///C|/...%20Uniformed%20Firefighters%20Assoc%20of%20New%20York%20City/Additional%20info%20requested%2012.28.10.htm[08/15/2011 11:10:48 AM]
Benefits Administrator
Uniformed Firefighters Association
Security Benefit Fund

(212) 545-6960
STATEMENT OF CONFIDENTIALITY: The information contained in this electronic message and any attachments to this message are intended for the exclusive use of
the addressee(s) and may contain confidential or privileged information. If you are not the intended recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4723, and destroy all copies of this message and any attachments.

From: Straub,Bob
Sent: Monday, December 13, 2010 3:43 PM
To: Carapella,Theresa
Subject: FW: Waiver Application for UFA Security Benefits Fund



From: Moultrie, Cam (HHS/OCIIO) [mailto:Cam.Moultrie@hhs.gov]
Sent: Monday, December 13, 2010 2:54 PM
To: Straub,Bob
Cc: Habit, Sandra (HHS/OCIIO)
Subject: Waiver Application for UFA Security Benefits Fund
Dear Mr. Straub:

Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act
(PHS Act) Section 2711. In order to expedite your application, please provide the following information:

I. Please complete the entire annual limits spreadsheet available at:
http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed
spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that
are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet
does not pertain to your plan, please write None, and/or provide an explanation regarding why you are
unable to complete that particular cell in a separate document.

II. In addition, please provide the following information:

Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?

Confirm whether the plan was created pursuant to the Taft-Hartley Act.

In order to complete your application, please provide this information by 5:00 pm, December 15, 2010. Once this
information is received and the application is complete, it will be processed by the Department of Health and
Human Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision
within 30 days of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver
decision.

UFireA:000011
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file:///C|/...%20Uniformed%20Firefighters%20Assoc%20of%20New%20York%20City/Additional%20info%20requested%2012.28.10.htm[08/15/2011 11:10:48 AM]
Thank you.


Cam Lynne Moultrie
Office of Consumer Information and Insurance Oversight
U.S. Department of Health and Human Services
(301) 492-4174
cam.moultrie@hhs.gov





INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distributed, or copied to
persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.



STATEMENT OF CONFIDENTIALITY

The information contained in this electronic message and any attachments to
this message are intended for the exclusive use of the addressee(s) and may
contain confidential or privileged information. If you are not the intended
recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4832, and destroy
all copies of this message and any attachments. Please note that any views or
opinions presented in this email are solely those of the author and do not
necessarily represent those of the Uniformed Firefighters Association.
Finally, the recipient should check this email and any attachments for the
presence of viruses. The company accepts no liability for any damage caused by
any virus transmitted by this email.
UFireA:000012
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file:///C|/...20Uniformed%20Firefighters%20Assoc%20of%20New%20York%20City/Reqeust%20for%20info%20response%201.6.11.htm[08/15/2011 11:10:49 AM]
From: Carapella,Theresa [tcarapella@ufanyc.org]
Sent: Thursday, January 06, 2011 12:56 PM
To: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO)
Subject: RE: Waiver Application for UFA Security Benefits Fund
Cam:

Below is the information requested

Contracts Members
Single
Family
TOTAL

Thank you.



Theresa Carapella
Benefits Administrator
Uniformed Firefighters Association
Security Benefit Fund

(212) 545-6960
STATEMENT OF CONFIDENTIALITY: The information contained in this electronic message and any attachments to this message are intended for the exclusive use of
the addressee(s) and may contain confidential or privileged information. If you are not the intended recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4723, and destroy all copies of this message and any attachments.

From: Moultrie, Cam (HHS/OCIIO) [mailto:Cam.Moultrie@hhs.gov]
Sent: Tuesday, December 28, 2010 3:07 PM
To: Carapella,Theresa
Cc: Habit, Sandra (HHS/OCIIO)
Subject: RE: Waiver Application for UFA Security Benefits Fund

Please provide a breakdown of individuals in each tier (column P).

Thank you.


Cam Lynne Moultrie
Office of Consumer Information and Insurance Oversight
U.S. Department of Health and Human Services
(301) 492-4174
cam.moultrie@hhs.gov





INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distributed, or copied to
Ex. 4
UFireA:000013
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file:///C|/...20Uniformed%20Firefighters%20Assoc%20of%20New%20York%20City/Reqeust%20for%20info%20response%201.6.11.htm[08/15/2011 11:10:49 AM]
persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.

From: Carapella,Theresa [mailto:tcarapella@ufanyc.org]
Sent: Tuesday, December 14, 2010 2:54 PM
To: Moultrie, Cam (HHS/OCIIO)
Subject: FW: Waiver Application for UFA Security Benefits Fund

I. Please complete the entire annual limits spreadsheet available at:
http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed
spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that
are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet
does not pertain to your plan, please write None, and/or provide an explanation regarding why you are
unable to complete that particular cell in a separate document.
SEE ATTACHED FOR COMPLETED SPREADSHEET

II. In addition, please provide the following information:

Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140? YES, PLAN WAS IN EXISTENCE PRIOR TO MARCH 23,
2010. PLAN IS ALSO IN COMPLIANCE WITH GRANDFATHERING PROVISIONS.

Confirm whether the plan was created pursuant to the Taft-Hartley Act. NO

Please let me know if you have questions or need anything further.

Thank you.

Theresa Carapella
Benefits Administrator
Uniformed Firefighters Association
Security Benefit Fund

(212) 545-6960
STATEMENT OF CONFIDENTIALITY: The information contained in this electronic message and any attachments to this message
are intended for the exclusive use of the addressee(s) and may contain confidential or privileged information. If you
are not the intended recipient, please notify us immediately by e-mail reply to sender or by telephone to Uniformed
Firefighters Association at (212) 683-4723, and destroy all copies of this message and any attachments.

From: Straub,Bob
Sent: Monday, December 13, 2010 3:43 PM
To: Carapella,Theresa
Subject: FW: Waiver Application for UFA Security Benefits Fund



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From: Moultrie, Cam (HHS/OCIIO) [mailto:Cam.Moultrie@hhs.gov]
Sent: Monday, December 13, 2010 2:54 PM
To: Straub,Bob
Cc: Habit, Sandra (HHS/OCIIO)
Subject: Waiver Application for UFA Security Benefits Fund
Dear Mr. Straub:

Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act
(PHS Act) Section 2711. In order to expedite your application, please provide the following information:

I. Please complete the entire annual limits spreadsheet available at:
http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed
spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that
are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet
does not pertain to your plan, please write None, and/or provide an explanation regarding why you are
unable to complete that particular cell in a separate document.

II. In addition, please provide the following information:

Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?

Confirm whether the plan was created pursuant to the Taft-Hartley Act.

In order to complete your application, please provide this information by 5:00 pm, December 15, 2010. Once this
information is received and the application is complete, it will be processed by the Department of Health and
Human Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision
within 30 days of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver
decision.

Thank you.


Cam Lynne Moultrie
Office of Consumer Information and Insurance Oversight
U.S. Department of Health and Human Services
(301) 492-4174
cam.moultrie@hhs.gov





INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distributed, or copied to
persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
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STATEMENT OF CONFIDENTIALITY

The information contained in this electronic message and any attachments to
this message are intended for the exclusive use of the addressee(s) and may
contain confidential or privileged information. If you are not the intended
recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4832, and destroy
all copies of this message and any attachments. Please note that any views or
opinions presented in this email are solely those of the author and do not
necessarily represent those of the Uniformed Firefighters Association.
Finally, the recipient should check this email and any attachments for the
presence of viruses. The company accepts no liability for any damage caused by
any virus transmitted by this email.
STATEMENT OF CONFIDENTIALITY

The information contained in this electronic message and any attachments to
this message are intended for the exclusive use of the addressee(s) and may
contain confidential or privileged information. If you are not the intended
recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4832, and destroy
all copies of this message and any attachments. Please note that any views or
opinions presented in this email are solely those of the author and do not
necessarily represent those of the Uniformed Firefighters Association.
Finally, the recipient should check this email and any attachments for the
presence of viruses. The company accepts no liability for any damage caused by
any virus transmitted by this email.
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ANNUAL LIMIT WAIVER APPLICATION 2010
Annual
Limit Waiver
Request
Applicant
Name
Policy Name
(use a new
row for each
policy
application)
Applicant
(Plan/ Policy
Situs) City
Applicant
(Plan/
Policy
Situs)
State
Plan/ Policy
Effective Date
(mm/dd/yyyy)
Contact
Name
Street
Address City State Zip Code
Phone
Number
(including
area code)
Email
Address
Type of
Coverage
(e.g., Limited
Benefit, HRA,
Rx only, Other)
Self-
Insured
(Yes/No)
Individual or
Group Policy
Total
Number of
Individuals
Covered by
Policy
(include all
dependents
covered)
Current
Plan Overall
Annual
Limit (in
dollars)
Security
Benefit Fund
of the
Uniformed
Firefighters
Association
of New York
City
Security
Benefit Fund
of the
Uniformed
Firefighters
Association of
New York City New York NY 07/01/2011
Robert
Straub
204 East
23rd Street New York NY 10010
212-545-
6975
bstraub@ufa
nyc.org RX Only Yes Group



E
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ANNUAL LIMIT WAIVER APPLICATION 2010
Annual
Limit Waiver
Request
Applicant
Name Ambulatory Emergency Hospitalization Laboratory Pediatric
Maternity/
Newborn
Mental Health/
Substance
Abuse
Rehabilitative/
Devices
Preventive/
Wellness Prescription
Plan
Deductible
Copay (if
applicabl
e)
Coinsuranc
e (if
applicable)
Copay (if
applicabl
e)
Coinsura
nce (if
applicabl
e)
Copay (if
applicabl
e)
Coinsura
nce (if
applicabl
e)
Copay (if
applicabl
e)
Office Visit
Copays/Coinsurance
Hospital Inpatient
Copay/Coinsurance
Emergency Room
Copay/Coinsurance Current Essential Benefits Annual Limits (Annual Limit for Each Essential Benefit)
R
Copay/Co
Security
Benefit Fund
of the
Uniformed
Firefighters
Association
of New York
City

n/a n/a n/a n/a n/a n/a



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ANNUAL LIMIT WAIVER APPLICATION 2010
Annual
Limit Waiver
Request
Applicant
Name
Coinsuran
ce (if
applicable)
Individual/ Employee
Tier*
Employee
contribution
(if applicable)
Employer
contribution
(if applicable) Total
Employee
contribution
(if applicable)
Employer
contribution
(if applicable) Total
Employee
contribution
(if applicable)
Employer
contribution
(if applicable) Total
Projected Rate Increase
that would result from
compliance with $750,000
Annual Limit Restriction
(in dollars)(Average
Premium by Individual)
(Difference of Column AT
and AQ divided by
Column AQ)
Decrease in
Access to
Benefits that
would result
from
compliance
with $750,000
Annual Limit
Restriction
(describe
briefly in cell
or in a
Plan
Administr
ator/ CEO
of Health
Insuranc
e Issuer
Name
Title of Individual
Providing
Attestation
Elimination of
the benefit cap
on the
pharmacy
benefit will
have an
adverse
Projected Rate Increase that would result
from compliance with $750,000 Annual Limit
Restriction (in dollars) (Average Premium
by Individual)*
Current Monthly Premium Rates or
Premium Equivalent Rates (in dollars)*:
Rx
ninsurance
Renewal Monthly Premium Rates or
Premium Equivalent Rates if Waiver Granted
(in dollars)*
Security
Benefit Fund
of the
Uniformed
Firefighters
Association
of New York
City n/a Individual
impact of the
Fund's long-
term ability to
continue to
provide its
members with
access to
pharmacy
benefits as
well as other
benefits such
as dental,
vision and
hearing.
Robert
Straub Treasurer
E
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file:///C|/...0Uniformed%20Firefighters%20Assoc%20of%20New%20York%20City/Request%20for%20info%20response%201.10.11.htm[08/15/2011 11:10:49 AM]
From: Carapella,Theresa [tcarapella@ufanyc.org]
Sent: Monday, January 10, 2011 9:32 AM
To: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO)
Cc: Straub,Bob; Eustace, John; Spollen,Jim
Subject: RE: Waiver Application for UFA Security Benefits Fund
From: Carapella,Theresa
Sent: Thursday, J anuary 06, 2011 12:56 PM
To: 'Moultrie, Cam (HHS/OCIIO)'; 'Sandra.Habit@hhs.gov'
Subject: RE: Waiver Application for UFA Security Benefits Fund

Cam:

Below is the information requested

Contracts Members
Single
Family
TOTAL

Thank you.



Theresa Carapella
Benefits Administrator
Uniformed Firefighters Association
Security Benefit Fund

(212) 545-6960
STATEMENT OF CONFIDENTIALITY: The information contained in this electronic message and any attachments to this message are intended for the exclusive use of
the addressee(s) and may contain confidential or privileged information. If you are not the intended recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4723, and destroy all copies of this message and any attachments.

From: Moultrie, Cam (HHS/OCIIO) [mailto:Cam.Moultrie@hhs.gov]
Sent: Tuesday, December 28, 2010 3:07 PM
To: Carapella,Theresa
Cc: Habit, Sandra (HHS/OCIIO)
Subject: RE: Waiver Application for UFA Security Benefits Fund

Please provide a breakdown of individuals in each tier (column P).

Thank you.


Cam Lynne Moultrie
Office of Consumer Information and Insurance Oversight
U.S. Department of Health and Human Services
(301) 492-4174
cam.moultrie@hhs.gov

Ex. 4
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INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distributed, or copied to
persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.

From: Carapella,Theresa [mailto:tcarapella@ufanyc.org]
Sent: Tuesday, December 14, 2010 2:54 PM
To: Moultrie, Cam (HHS/OCIIO)
Subject: FW: Waiver Application for UFA Security Benefits Fund

I. Please complete the entire annual limits spreadsheet available at:
http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed
spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that
are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet
does not pertain to your plan, please write None, and/or provide an explanation regarding why you are
unable to complete that particular cell in a separate document.
SEE ATTACHED FOR COMPLETED SPREADSHEET

II. In addition, please provide the following information:

Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140? YES, PLAN WAS IN EXISTENCE PRIOR TO MARCH 23,
2010. PLAN IS ALSO IN COMPLIANCE WITH GRANDFATHERING PROVISIONS.

Confirm whether the plan was created pursuant to the Taft-Hartley Act. NO

Please let me know if you have questions or need anything further.

Thank you.

Theresa Carapella
Benefits Administrator
Uniformed Firefighters Association
Security Benefit Fund

(212) 545-6960
STATEMENT OF CONFIDENTIALITY: The information contained in this electronic message and any attachments to this message
are intended for the exclusive use of the addressee(s) and may contain confidential or privileged information. If you
are not the intended recipient, please notify us immediately by e-mail reply to sender or by telephone to Uniformed
Firefighters Association at (212) 683-4723, and destroy all copies of this message and any attachments.

From: Straub,Bob
Sent: Monday, December 13, 2010 3:43 PM
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To: Carapella,Theresa
Subject: FW: Waiver Application for UFA Security Benefits Fund



From: Moultrie, Cam (HHS/OCIIO) [mailto:Cam.Moultrie@hhs.gov]
Sent: Monday, December 13, 2010 2:54 PM
To: Straub,Bob
Cc: Habit, Sandra (HHS/OCIIO)
Subject: Waiver Application for UFA Security Benefits Fund
Dear Mr. Straub:

Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act
(PHS Act) Section 2711. In order to expedite your application, please provide the following information:

I. Please complete the entire annual limits spreadsheet available at:
http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html. Please return the completed
spreadsheet to this email address as an attachment. We will only be able to process spreadsheets that
are fully complete (i.e., every cell should contain the information requested). If a cell on the spreadsheet
does not pertain to your plan, please write None, and/or provide an explanation regarding why you are
unable to complete that particular cell in a separate document.

II. In addition, please provide the following information:

Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?

Confirm whether the plan was created pursuant to the Taft-Hartley Act.

In order to complete your application, please provide this information by 5:00 pm, December 15, 2010. Once this
information is received and the application is complete, it will be processed by the Department of Health and
Human Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision
within 30 days of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver
decision.

Thank you.


Cam Lynne Moultrie
Office of Consumer Information and Insurance Oversight
U.S. Department of Health and Human Services
(301) 492-4174
cam.moultrie@hhs.gov


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INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distributed, or copied to
persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.



STATEMENT OF CONFIDENTIALITY

The information contained in this electronic message and any attachments to
this message are intended for the exclusive use of the addressee(s) and may
contain confidential or privileged information. If you are not the intended
recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4832, and destroy
all copies of this message and any attachments. Please note that any views or
opinions presented in this email are solely those of the author and do not
necessarily represent those of the Uniformed Firefighters Association.
Finally, the recipient should check this email and any attachments for the
presence of viruses. The company accepts no liability for any damage caused by
any virus transmitted by this email.
STATEMENT OF CONFIDENTIALITY

The information contained in this electronic message and any attachments to
this message are intended for the exclusive use of the addressee(s) and may
contain confidential or privileged information. If you are not the intended
recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4832, and destroy
all copies of this message and any attachments. Please note that any views or
opinions presented in this email are solely those of the author and do not
necessarily represent those of the Uniformed Firefighters Association.
Finally, the recipient should check this email and any attachments for the
presence of viruses. The company accepts no liability for any damage caused by
any virus transmitted by this email.
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file:///C|/...und%20of%20the%20Uniformed%20Firefighters%20Assoc%20of%20New%20York%20City/Correspondence%201.11.11.htm[08/15/2011 11:10:50 AM]
From: Sheer, Jennifer (HHS/OCIIO)
Sent: Tuesday, January 11, 2011 11:39 AM
To: 'tcarapella@ufanyc.org'
Cc: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO); Morales, Veronica (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of New York, Waiver Application
Hi Theresa

I have checked with my colleagues and we did receive your spreadsheet and the supplemental information submitted on Jan.
6, 2011 (the number of individuals in each tier). At this time, we do not require additional information; however, further
information may be requested during the processing of your application.

Someone from this office should be in touch with you next week.

Good luck with the snowstorm.

----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight
U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov
301-492-4487



INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:

This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be
disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution
to the full extent of the law.

From: Sheer, J ennifer (HHS/OCIIO)
Sent: Monday, J anuary 10, 2011 4:27 PM
To: 'bstraub@ufanyc.org'
Cc: 'tcarapella@ufanyc.org'
Subject: Uniformed Firefighters Association of New York, Waiver Application

Hello

On Dec. 9, 2010, my colleague Veronica Morales sent you the email below (please see below my signature for the original
message). We have not yet received a reply regarding this information request. Without your reply, we are unable to process
your application for an annual limit waiver. Please provide the requested information by 5pm Tuesday, January 11, 2011.
Please feel free to email or call me if you have any questions.

Thank you.

----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight
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U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov
301-492-4487


[ORINGAL MESSAGE]

From: Morales, Veronica (HHS/OCIIO)
Sent: Thursday, December 09, 2010 3:02 PM
To: 'bstraub@ufanyc.org'
Cc: 'Tcarapella@ufanyc.org'; Sheer, Jennifer (HHS/OCIIO)
Subject: Uniformed Forefighters Association of New York, Waiver Application
Attachments: Waiver Application Form.xls

Dear Mr. Straub:

Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act)
Section 2711. In order to expedite your application, please provide the following information:

I. Please complete the entire annual limits spreadsheet, [attached to the email] [and available at:
http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html]. Please return the completed spreadsheet
to this email address as an attachment. We will only be able to process spreadsheets that are fully complete
(i.e., every cell should contain the information requested). If a cell on the spreadsheet does not pertain to
your plan, please write None, and/or provide an explanation regarding why you are unable to complete
that particular cell in a separate document.

II. In addition, please provide the following information:

Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?

Confirm whether the plan was created pursuant to the Taft-Hartley Act.


In order to complete your application, please provide this information by 5:00 pm, December 10, 2010. Once this information
is received and the application is complete, it will be processed by the Department of Health and Human Services (HHS). As
stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30 days of receiving a complete
application. You will receive an e-mail from HHS notifying you of the waiver decision.

Thank you.

Veronica W. Morales, J.D.
U.S. Department of Health & Human Services
Office of Consumer Information & Insurance Oversight
Office of Consumer Support
Phone# (301) 492-4249
Email: veronica.morales@hhs.gov



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INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:

This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be
disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution
to the full extent of the law.

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From: Sheer, Jennifer (HHS/OCIIO)
Sent: Tuesday, January 11, 2011 8:20 AM
To: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO)
Subject: Uniformed Firefighters Association of NYC
Hi

I just wanted to check on who is handling this application. Veronica Morales had this in her set of waivers, and she passed it to
me when she left on annual leave. I was told that there was no response from this organization. I have since spoken with
Theresa Carapella, who said she has been in contact with you two regarding her application. Could you please let me know if
this should be on your to do list or mine? Theyre hoping to hear if the application is complete or a request for more info
before the storm hits this evening (since they are anticipating not being in the office tomorrow due to weather conditions). Id
like to get back to them with that much today, since the confusion on our end has led to some worries on their side. Please let
me know how to proceed (and if you reply to Theresa about the application status, can you CC me?).

Thanks.

Jen

----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight
U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov
301-492-4487



INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:

This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be
disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution
to the full extent of the law.

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file:///C|/...%20of%20the%20Uniformed%20Firefighters%20Assoc%20of%20New%20York%20City/Additional%20info%201.18.11.htm[08/15/2011 11:10:50 AM]
From: Moultrie, Cam (HHS/OCIIO)
Sent: Tuesday, January 18, 2011 10:54 AM
To: Sheer, Jennifer (HHS/OCIIO); Habit, Sandra (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of NYC
I believe Veronica was handling this application. I had received a redundant copy of the application and turned it back over to
Veronica.

Cam Lynne Moultrie
Office of Consumer Information and Insurance Oversight
U.S. Department of Health and Human Services
(301) 492-4174
cam.moultrie@hhs.gov





INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distributed, or
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.

From: Sheer, J ennifer (HHS/OCIIO)
Sent: Tuesday, J anuary 11, 2011 8:20 AM
To: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO)
Subject: Uniformed Firefighters Association of NYC

Hi

I just wanted to check on who is handling this application. Veronica Morales had this in her set of waivers, and she passed it to
me when she left on annual leave. I was told that there was no response from this organization. I have since spoken with
Theresa Carapella, who said she has been in contact with you two regarding her application. Could you please let me know if
this should be on your to do list or mine? Theyre hoping to hear if the application is complete or a request for more info
before the storm hits this evening (since they are anticipating not being in the office tomorrow due to weather conditions). Id
like to get back to them with that much today, since the confusion on our end has led to some worries on their side. Please let
me know how to proceed (and if you reply to Theresa about the application status, can you CC me?).

Thanks.

Jen

----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight
U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov
301-492-4487



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INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:

This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be
disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution
to the full extent of the law.

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From: Sheer, Jennifer (HHS/OCIIO)
Sent: Tuesday, January 18, 2011 11:08 AM
To: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of NYC
Ok, then I guess it's in my pile now. Sandra, it looks like you saved the relevant emails/materials onto the G-drive; if I
have any questions, I hope you won't mind if I email you (since from what I can tell this applicant sent everything to
you and Cam). Thanks.
Jen
----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services
jennifer.sheer@hhs.gov
301-492-4487
________________________________________
From: Moultrie, Cam (HHS/OCIIO)
Sent: Tuesday, January 18, 2011 10:53 AM
To: Sheer, Jennifer (HHS/OCIIO); Habit, Sandra (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of NYC
I believe Veronica was handling this application. I had received a redundant copy of the application and turned it back
over to Veronica.
Cam Lynne Moultrie
Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services
(301) 492-4174
cam.moultrie@hhs.gov
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and confidential. It is for internal government
use only and must not be disseminated, distributed, or copied to persons not authorized to receive the information.
Unauthorized disclosure may result in prosecution to the full extent of the law.
From: Sheer, Jennifer (HHS/OCIIO)
Sent: Tuesday, January 11, 2011 8:20 AM
To: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO)
Subject: Uniformed Firefighters Association of NYC
Hi
I just wanted to check on who is handling this application. Veronica Morales had this in her set of waivers, and she
passed it to me when she left on annual leave. I was told that there was no response from this organization. I have since
spoken with Theresa Carapella, who said she has been in contact with you two regarding her application. Could you
please let me know if this should be on your to do list or mine? Theyre hoping to hear if the application is complete or
a request for more info before the storm hits this evening (since they are anticipating not being in the office tomorrow
due to weather conditions). Id like to get back to them with that much today, since the confusion on our end has led to
UFireA:000030
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some worries on their side. Please let me know how to proceed (and if you reply to Theresa about the application
status, can you CC me?).
Thanks.
Jen
----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services
jennifer.sheer@hhs.gov
301-492-4487
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and confidential. It is for internal government
use only and must not be disseminated, distributed, or copied to persons not authorized to receive the information.
Unauthorized disclosure may result in prosecution to the full extent of the law.
UFireA:000031
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From: Sheer, Jennifer (HHS/OCIIO)
Sent: Tuesday, January 18, 2011 11:08 AM
To: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of NYC
Ok, then I guess it's in my pile now. Sandra, it looks like you saved the
relevant emails/materials onto the G-drive; if I have any questions, I hope
you won't mind if I email you (since from what I can tell this applicant sent
everything to you and Cam). Thanks.
Jen
----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight U.S. Department of
Health and Human Services
jennifer.sheer@hhs.gov
301-492-4487
________________________________________
From: Moultrie, Cam (HHS/OCIIO)
Sent: Tuesday, January 18, 2011 10:53 AM
To: Sheer, Jennifer (HHS/OCIIO); Habit, Sandra (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of NYC
I believe Veronica was handling this application. I had received a redundant
copy of the application and turned it back over to Veronica.
Cam Lynne Moultrie
Office of Consumer Information and Insurance Oversight U.S. Department of
Health and Human Services
(301) 492-4174
cam.moultrie@hhs.gov
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and
confidential. It is for internal government use only and must not be
disseminated, distributed, or copied to persons not authorized to receive the
information. Unauthorized disclosure may result in prosecution to the full
extent of the law.
From: Sheer, Jennifer (HHS/OCIIO)
Sent: Tuesday, January 11, 2011 8:20 AM
To: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO)
Subject: Uniformed Firefighters Association of NYC
Hi
I just wanted to check on who is handling this application. Veronica Morales
UFireA:000032
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had this in her set of waivers, and she passed it to me when she left on
annual leave. I was told that there was no response from this organization. I
have since spoken with Theresa Carapella, who said she has been in contact
with you two regarding her application. Could you please let me know if this
should be on your to do list or mine? Theyre hoping to hear if the
application is complete or a request for more info before the storm hits this
evening (since they are anticipating not being in the office tomorrow due to
weather conditions). Id like to get back to them with that much today, since
the confusion on our end has led to some worries on their side. Please let me
know how to proceed (and if you reply to Theresa about the application status,
can you CC me?).
Thanks.
Jen
----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight U.S. Department of
Health and Human Services
jennifer.sheer@hhs.gov
301-492-4487
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and
confidential. It is for internal government use only and must not be
disseminated, distributed, or copied to persons not authorized to receive the
information. Unauthorized disclosure may result in prosecution to the full
extent of the law.
UFireA:000033
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From: Scelzo, Kathleen (HHS/OCIIO)
Sent: Tuesday, January 25, 2011 12:09 PM
To: Habit, Sandra (HHS/OCIIO)
Subject: FW: Uniformed Firefighters Association of New York, Waiver Application


Kathleen M. Scelzo, RN, MSN
Rules Compliance Division
Office of Insurance Oversight
Office of Consumer Information and Insurance Oversight (OCIIO)
Department of Health and Human Services
7501 Wisconsin Avenue
Bethesda, MD
301-492-4121

From: Moultrie, Cam (HHS/OCIIO)
Sent: Monday, J anuary 24, 2011 2:55 PM
To: Scelzo, Kathleen (HHS/OCIIO)
Subject: FW: Uniformed Firefighters Association of New York, Waiver Application

I forgot to send this to you. This is the conversation regarding the firefighter application that was discussed today.





INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distributed, or
copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.

From: Carapella,Theresa [mailto:tcarapella@ufanyc.org]
Sent: Monday, J anuary 24, 2011 9:24 AM
To: Sheer, J ennifer (HHS/OCIIO)
Cc: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of New York, Waiver Application

Good Morning Jennifer:

I have not heard anything with regard to the status of the Waiver Application. Please advise.

Thank you.

Theresa Carapella
Benefits Administrator
Uniformed Firefighters Association
Security Benefit Fund

(212) 545-6960
STATEMENT OF CONFIDENTIALITY: The information contained in this electronic message and any attachments to this message are intended for the exclusive use of
the addressee(s) and may contain confidential or privileged information. If you are not the intended recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4723, and destroy all copies of this message and any attachments.

From: Sheer, J ennifer (HHS/OCIIO) [mailto:J ennifer.Sheer@hhs.gov]
Sent: Tuesday, J anuary 11, 2011 11:39 AM
UFireA:000034
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To: Carapella,Theresa
Cc: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO); Morales, Veronica (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of New York, Waiver Application

Hi Theresa

I have checked with my colleagues and we did receive your spreadsheet and the supplemental information submitted on Jan.
6, 2011 (the number of individuals in each tier). At this time, we do not require additional information; however, further
information may be requested during the processing of your application.

Someone from this office should be in touch with you next week.

Good luck with the snowstorm.

----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight
U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov
301-492-4487



INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:

This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be
disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution
to the full extent of the law.

From: Sheer, Jennifer (HHS/OCIIO)
Sent: Monday, January 10, 2011 4:27 PM
To: 'bstraub@ufanyc.org'
Cc: 'tcarapella@ufanyc.org'
Subject: Uniformed Firefighters Association of New York, Waiver Application

Hello

On Dec. 9, 2010, my colleague Veronica Morales sent you the email below (please see below my signature for the original
message). We have not yet received a reply regarding this information request. Without your reply, we are unable to process
your application for an annual limit waiver. Please provide the requested information by 5pm Tuesday, January 11, 2011.
Please feel free to email or call me if you have any questions.

Thank you.

----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight
UFireA:000035
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U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov
301-492-4487


[ORINGAL MESSAGE]

From: Morales, Veronica (HHS/OCIIO)
Sent: Thursday, December 09, 2010 3:02 PM
To: 'bstraub@ufanyc.org'
Cc: 'Tcarapella@ufanyc.org'; Sheer, Jennifer (HHS/OCIIO)
Subject: Uniformed Forefighters Association of New York, Waiver Application
Attachments: Waiver Application Form.xls

Dear Mr. Straub:

Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act)
Section 2711. In order to expedite your application, please provide the following information:

I. Please complete the entire annual limits spreadsheet, [attached to the email] [and available at:
http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html]. Please return the completed spreadsheet to this email address
as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the
information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an
explanation regarding why you are unable to complete that particular cell in a separate document.

II. In addition, please provide the following information:

Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?

Confirm whether the plan was created pursuant to the Taft-Hartley Act.


In order to complete your application, please provide this information by 5:00 pm, December 10, 2010. Once this information
is received and the application is complete, it will be processed by the Department of Health and Human Services (HHS). As
stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30 days of receiving a complete
application. You will receive an e-mail from HHS notifying you of the waiver decision.

Thank you.

Veronica W. Morales, J.D.
U.S. Department of Health & Human Services
Office of Consumer Information & Insurance Oversight
Office of Consumer Support
Phone# (301) 492-4249
Email: veronica.morales@hhs.gov



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INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:

This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be
disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution
to the full extent of the law.



STATEMENT OF CONFIDENTIALITY

The information contained in this electronic message and any attachments to
this message are intended for the exclusive use of the addressee(s) and may
contain confidential or privileged information. If you are not the intended
recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4832, and destroy
all copies of this message and any attachments. Please note that any views or
opinions presented in this email are solely those of the author and do not
necessarily represent those of the Uniformed Firefighters Association.
Finally, the recipient should check this email and any attachments for the
presence of viruses. The company accepts no liability for any damage caused by
any virus transmitted by this email.
UFireA:000037
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From: Carapella,Theresa [tcarapella@ufanyc.org]
Sent: Monday, January 24, 2011 9:24 AM
To: Sheer, Jennifer (HHS/OCIIO)
Cc: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of New York, Waiver Application
Good Morning Jennifer:

I have not heard anything with regard to the status of the Waiver Application. Please advise.

Thank you.

Theresa Carapella
Benefits Administrator
Uniformed Firefighters Association
Security Benefit Fund

(212) 545-6960
STATEMENT OF CONFIDENTIALITY: The information contained in this electronic message and any attachments to this message are intended for the exclusive use of
the addressee(s) and may contain confidential or privileged information. If you are not the intended recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4723, and destroy all copies of this message and any attachments.

From: Sheer, J ennifer (HHS/OCIIO) [mailto:J ennifer.Sheer@hhs.gov]
Sent: Tuesday, J anuary 11, 2011 11:39 AM
To: Carapella,Theresa
Cc: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO); Morales, Veronica (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of New York, Waiver Application

Hi Theresa

I have checked with my colleagues and we did receive your spreadsheet and the supplemental information submitted on Jan.
6, 2011 (the number of individuals in each tier). At this time, we do not require additional information; however, further
information may be requested during the processing of your application.

Someone from this office should be in touch with you next week.

Good luck with the snowstorm.

----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight
U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov
301-492-4487



INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:

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This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be
disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution
to the full extent of the law.

From: Sheer, Jennifer (HHS/OCIIO)
Sent: Monday, January 10, 2011 4:27 PM
To: 'bstraub@ufanyc.org'
Cc: 'tcarapella@ufanyc.org'
Subject: Uniformed Firefighters Association of New York, Waiver Application

Hello

On Dec. 9, 2010, my colleague Veronica Morales sent you the email below (please see below my signature for the original
message). We have not yet received a reply regarding this information request. Without your reply, we are unable to process
your application for an annual limit waiver. Please provide the requested information by 5pm Tuesday, January 11, 2011.
Please feel free to email or call me if you have any questions.

Thank you.

----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight
U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov
301-492-4487


[ORINGAL MESSAGE]

From: Morales, Veronica (HHS/OCIIO)
Sent: Thursday, December 09, 2010 3:02 PM
To: 'bstraub@ufanyc.org'
Cc: 'Tcarapella@ufanyc.org'; Sheer, Jennifer (HHS/OCIIO)
Subject: Uniformed Forefighters Association of New York, Waiver Application
Attachments: Waiver Application Form.xls

Dear Mr. Straub:

Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act)
Section 2711. In order to expedite your application, please provide the following information:

I. Please complete the entire annual limits spreadsheet, [attached to the email] [and available at:
http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html]. Please return the completed spreadsheet to this email address
as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the
information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an
explanation regarding why you are unable to complete that particular cell in a separate document.

UFireA:000039
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II. In addition, please provide the following information:

Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?

Confirm whether the plan was created pursuant to the Taft-Hartley Act.


In order to complete your application, please provide this information by 5:00 pm, December 10, 2010. Once this information
is received and the application is complete, it will be processed by the Department of Health and Human Services (HHS). As
stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30 days of receiving a complete
application. You will receive an e-mail from HHS notifying you of the waiver decision.

Thank you.

Veronica W. Morales, J.D.
U.S. Department of Health & Human Services
Office of Consumer Information & Insurance Oversight
Office of Consumer Support
Phone# (301) 492-4249
Email: veronica.morales@hhs.gov



INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:

This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be
disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution
to the full extent of the law.

STATEMENT OF CONFIDENTIALITY

The information contained in this electronic message and any attachments to
this message are intended for the exclusive use of the addressee(s) and may
contain confidential or privileged information. If you are not the intended
recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4832, and destroy
all copies of this message and any attachments. Please note that any views or
opinions presented in this email are solely those of the author and do not
necessarily represent those of the Uniformed Firefighters Association.
Finally, the recipient should check this email and any attachments for the
presence of viruses. The company accepts no liability for any damage caused by
any virus transmitted by this email.
UFireA:000040
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From: Habit, Sandra (HHS/OCIIO)
Sent: Tuesday, January 25, 2011 2:51 PM
To: 'tcarapella@ufanyc.org'
Subject: Uniformed Firefighters Association of NY
January 25, 2011
Dear Ms. Carapella,
Thank you for your information.
Your application is now complete and you will receive a determination of your application within 30 days. Take care
and if you have any questions, please feel free to contact me.
Thank you,
Sandy


Sandy Habit
Department of Health and Human Services
Office of Consumer Information and Insurance Oversight
301-492-4175
Sandra.Habit@hhs.gov




INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW: This information has not been publicly
disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distributed,
or copied to persons not authorized to receive the information. Unauthorized disclosures may result in prosecution to the full extent
of the law.

UFireA:000041
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From: Sheer, Jennifer (HHS/OCIIO)
Sent: Tuesday, January 25, 2011 7:27 AM
To: Pham, Erica (HHS/OCIIO); McCune, Julie (HHS/OCIIO); Habit, Sandra
(HHS/OCIIO)
Subject: FW: Uniformed Firefighters Association of New York, Waiver
Application
Hello
This was one of the waivers I returned to Jane late last week (when we turned back over the waiver work). It looks like
the information is on the G drive, but I did not have a chance to review it at all. Could someone please follow up with
Theresa?
Thanks.
Jen
----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services
jennifer.sheer@hhs.gov
301-492-4487
________________________________________
From: Carapella,Theresa [tcarapella@ufanyc.org]
Sent: Monday, January 24, 2011 9:24 AM
To: Sheer, Jennifer (HHS/OCIIO)
Cc: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of New York, Waiver Application
Good Morning Jennifer:
I have not heard anything with regard to the status of the Waiver Application. Please advise.
Thank you.
Theresa Carapella
Benefits Administrator
Uniformed Firefighters Association
Security Benefit Fund
(212) 545-6960
STATEMENT OF CONFIDENTIALITY: The information contained in this electronic message and any attachments
to this message are intended for the exclusive use of the addressee(s) and may contain confidential or privileged
information. If you are not the intended recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4723, and destroy all copies of this message and any
attachments.
________________________________
From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov]
Sent: Tuesday, January 11, 2011 11:39 AM
To: Carapella,Theresa
UFireA:000042
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Cc: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO); Morales, Veronica (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of New York, Waiver Application
Hi Theresa
I have checked with my colleagues and we did receive your spreadsheet and the supplemental information submitted
on Jan. 6, 2011 (the number of individuals in each tier). At this time, we do not require additional information;
however, further information may be requested during the processing of your application.
Someone from this office should be in touch with you next week.
Good luck with the snowstorm.
----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services
jennifer.sheer@hhs.gov
301-492-4487
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and confidential. It is for internal government
use only and must not be disseminated, distributed, or copied to persons not authorized to receive the information.
Unauthorized disclosure may result in prosecution to the full extent of the law.
From: Sheer, Jennifer (HHS/OCIIO)
Sent: Monday, January 10, 2011 4:27 PM
To: 'bstraub@ufanyc.org'
Cc: 'tcarapella@ufanyc.org'
Subject: Uniformed Firefighters Association of New York, Waiver Application
Hello
On Dec. 9, 2010, my colleague Veronica Morales sent you the email below (please see below my signature for the
original message). We have not yet received a reply regarding this information request. Without your reply, we are
unable to process your application for an annual limit waiver. Please provide the requested information by 5pm
Tuesday, January 11, 2011. Please feel free to email or call me if you have any questions.
Thank you.
----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services
jennifer.sheer@hhs.gov
301-492-4487
[ORINGAL MESSAGE]
UFireA:000043
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From: Morales, Veronica (HHS/OCIIO)
Sent: Thursday, December 09, 2010 3:02 PM
To: 'bstraub@ufanyc.org'
Cc: 'Tcarapella@ufanyc.org'; Sheer, Jennifer (HHS/OCIIO)
Subject: Uniformed Forefighters Association of New York, Waiver Application
Attachments: Waiver Application Form.xls
Dear Mr. Straub:
Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act
(PHS Act) Section 2711. In order to expedite your application, please provide the following information:
I. Please complete the entire annual limits spreadsheet, [attached to the email] [and available at:
http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html]. Please return the completed spreadsheet to this
email address as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell
should contain the information requested). If a cell on the spreadsheet does not pertain to your plan, please write
None, and/or provide an explanation regarding why you are unable to complete that particular cell in a separate
document.
II. In addition, please provide the following information:
Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?
Confirm whether the plan was created pursuant to the Taft-Hartley Act.
In order to complete your application, please provide this information by 5:00 pm, December 10, 2010. Once this
information is received and the application is complete, it will be processed by the Department of Health and Human
Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30
days of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decision.
Thank you.
Veronica W. Morales, J.D.
U.S. Department of Health & Human Services
Office of Consumer Information & Insurance Oversight
Office of Consumer Support
Phone# (301) 492-4249
Email: veronica.morales@hhs.gov<mailto:veronica.morales@hhs.gov>
UFireA:000044
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INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and confidential. It is for internal government
use only and must not be disseminated, distributed, or copied to persons not authorized to receive the information.
Unauthorized disclosure may result in prosecution to the full extent of the law.
STATEMENT OF CONFIDENTIALITY
The information contained in this electronic message and any attachments to this message are intended for the
exclusive use of the addressee(s) and may contain confidential or privileged information. If you are not the intended
recipient, please notify us immediately by e-mail reply to sender or by telephone to Uniformed Firefighters Association
at (212) 683-4832, and destroy all copies of this message and any attachments. Please note that any views or opinions
presented in this email are solely those of the author and do not necessarily represent those of the Uniformed
Firefighters Association.
Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts
no liability for any damage caused by any virus transmitted by this email.
UFireA:000045
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From: Habit, Sandra (HHS/OCIIO)
Sent: Tuesday, January 25, 2011 9:26 AM
To: Sheer, Jennifer (HHS/OCIIO); Pham, Erica (HHS/OCIIO); McCune, Julie
(HHS/OCIIO)
Cc: Moultrie, Cam (HHS/OCIIO); Scelzo, Kathleen (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of New York, Waiver
Application
Jen,
It looks like Kathleen has it but I will take the application from her so I can take care of it today. I will check the G
drive to see where Veronica and Cam left off and contact Theresa with any additional questions I have.
Thanks,
Sandy
-----Original Message-----
From: Sheer, Jennifer (HHS/OCIIO)
Sent: Tuesday, January 25, 2011 7:27 AM
To: Pham, Erica (HHS/OCIIO); McCune, Julie (HHS/OCIIO); Habit, Sandra (HHS/OCIIO)
Subject: FW: Uniformed Firefighters Association of New York, Waiver Application
Hello
This was one of the waivers I returned to Jane late last week (when we turned back over the waiver work). It looks like
the information is on the G drive, but I did not have a chance to review it at all. Could someone please follow up with
Theresa?
Thanks.
Jen
----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services
jennifer.sheer@hhs.gov
301-492-4487
________________________________________
From: Carapella,Theresa [tcarapella@ufanyc.org]
Sent: Monday, January 24, 2011 9:24 AM
To: Sheer, Jennifer (HHS/OCIIO)
Cc: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of New York, Waiver Application
Good Morning Jennifer:
I have not heard anything with regard to the status of the Waiver Application. Please advise.
Thank you.
Theresa Carapella
Benefits Administrator
UFireA:000046
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Uniformed Firefighters Association
Security Benefit Fund
(212) 545-6960
STATEMENT OF CONFIDENTIALITY: The information contained in this electronic message and any attachments
to this message are intended for the exclusive use of the addressee(s) and may contain confidential or privileged
information. If you are not the intended recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4723, and destroy all copies of this message and any
attachments.
________________________________
From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov]
Sent: Tuesday, January 11, 2011 11:39 AM
To: Carapella,Theresa
Cc: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO); Morales, Veronica (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of New York, Waiver Application
Hi Theresa
I have checked with my colleagues and we did receive your spreadsheet and the supplemental information submitted
on Jan. 6, 2011 (the number of individuals in each tier). At this time, we do not require additional information;
however, further information may be requested during the processing of your application.
Someone from this office should be in touch with you next week.
Good luck with the snowstorm.
----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services
jennifer.sheer@hhs.gov
301-492-4487
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and confidential. It is for internal government
use only and must not be disseminated, distributed, or copied to persons not authorized to receive the information.
Unauthorized disclosure may result in prosecution to the full extent of the law.
From: Sheer, Jennifer (HHS/OCIIO)
Sent: Monday, January 10, 2011 4:27 PM
To: 'bstraub@ufanyc.org'
Cc: 'tcarapella@ufanyc.org'
Subject: Uniformed Firefighters Association of New York, Waiver Application
Hello
On Dec. 9, 2010, my colleague Veronica Morales sent you the email below (please see below my signature for the
original message). We have not yet received a reply regarding this information request. Without your reply, we are
UFireA:000047
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unable to process your application for an annual limit waiver. Please provide the requested information by 5pm
Tuesday, January 11, 2011. Please feel free to email or call me if you have any questions.
Thank you.
----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services
jennifer.sheer@hhs.gov
301-492-4487
[ORINGAL MESSAGE]
From: Morales, Veronica (HHS/OCIIO)
Sent: Thursday, December 09, 2010 3:02 PM
To: 'bstraub@ufanyc.org'
Cc: 'Tcarapella@ufanyc.org'; Sheer, Jennifer (HHS/OCIIO)
Subject: Uniformed Forefighters Association of New York, Waiver Application
Attachments: Waiver Application Form.xls
Dear Mr. Straub:
Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act
(PHS Act) Section 2711. In order to expedite your application, please provide the following information:
I. Please complete the entire annual limits spreadsheet, [attached to the email] [and available at:
http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html]. Please return the completed spreadsheet to this
email address as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell
should contain the information requested). If a cell on the spreadsheet does not pertain to your plan, please write
None, and/or provide an explanation regarding why you are unable to complete that particular cell in a separate
document.
II. In addition, please provide the following information:
Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?
Confirm whether the plan was created pursuant to the Taft-Hartley Act.
In order to complete your application, please provide this information by 5:00 pm, December 10, 2010. Once this
information is received and the application is complete, it will be processed by the Department of Health and Human
Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30
days of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decision.
UFireA:000048
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Thank you.
Veronica W. Morales, J.D.
U.S. Department of Health & Human Services
Office of Consumer Information & Insurance Oversight
Office of Consumer Support
Phone# (301) 492-4249
Email: veronica.morales@hhs.gov<mailto:veronica.morales@hhs.gov>
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and confidential. It is for internal government
use only and must not be disseminated, distributed, or copied to persons not authorized to receive the information.
Unauthorized disclosure may result in prosecution to the full extent of the law.
STATEMENT OF CONFIDENTIALITY
The information contained in this electronic message and any attachments to this message are intended for the
exclusive use of the addressee(s) and may contain confidential or privileged information. If you are not the intended
recipient, please notify us immediately by e-mail reply to sender or by telephone to Uniformed Firefighters Association
at (212) 683-4832, and destroy all copies of this message and any attachments. Please note that any views or opinions
presented in this email are solely those of the author and do not necessarily represent those of the Uniformed
Firefighters Association.
Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts
no liability for any damage caused by any virus transmitted by this email.
UFireA:000049
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From: Sheer, Jennifer (HHS/OCIIO)
Sent: Tuesday, January 25, 2011 9:28 AM
To: Habit, Sandra (HHS/OCIIO); Pham, Erica (HHS/OCIIO); McCune, Julie
(HHS/OCIIO)
Cc: Moultrie, Cam (HHS/OCIIO); Scelzo, Kathleen (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of New York, Waiver
Application
Great thank you (I wasn't sure of its status with you all, thus the mass email).
----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services
jennifer.sheer@hhs.gov
301-492-4487
________________________________________
From: Habit, Sandra (HHS/OCIIO)
Sent: Tuesday, January 25, 2011 9:26 AM
To: Sheer, Jennifer (HHS/OCIIO); Pham, Erica (HHS/OCIIO); McCune, Julie (HHS/OCIIO)
Cc: Moultrie, Cam (HHS/OCIIO); Scelzo, Kathleen (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of New York, Waiver Application
Jen,
It looks like Kathleen has it but I will take the application from her so I can take care of it today. I will check the G
drive to see where Veronica and Cam left off and contact Theresa with any additional questions I have.
Thanks,
Sandy
-----Original Message-----
From: Sheer, Jennifer (HHS/OCIIO)
Sent: Tuesday, January 25, 2011 7:27 AM
To: Pham, Erica (HHS/OCIIO); McCune, Julie (HHS/OCIIO); Habit, Sandra (HHS/OCIIO)
Subject: FW: Uniformed Firefighters Association of New York, Waiver Application
Hello
This was one of the waivers I returned to Jane late last week (when we turned back over the waiver work). It looks like
the information is on the G drive, but I did not have a chance to review it at all. Could someone please follow up with
Theresa?
Thanks.
Jen
----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services
jennifer.sheer@hhs.gov
301-492-4487
UFireA:000050
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________________________________________
From: Carapella,Theresa [tcarapella@ufanyc.org]
Sent: Monday, January 24, 2011 9:24 AM
To: Sheer, Jennifer (HHS/OCIIO)
Cc: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of New York, Waiver Application
Good Morning Jennifer:
I have not heard anything with regard to the status of the Waiver Application. Please advise.
Thank you.
Theresa Carapella
Benefits Administrator
Uniformed Firefighters Association
Security Benefit Fund
(212) 545-6960
STATEMENT OF CONFIDENTIALITY: The information contained in this electronic message and any attachments
to this message are intended for the exclusive use of the addressee(s) and may contain confidential or privileged
information. If you are not the intended recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4723, and destroy all copies of this message and any
attachments.
________________________________
From: Sheer, Jennifer (HHS/OCIIO) [mailto:Jennifer.Sheer@hhs.gov]
Sent: Tuesday, January 11, 2011 11:39 AM
To: Carapella,Theresa
Cc: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO); Morales, Veronica (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of New York, Waiver Application
Hi Theresa
I have checked with my colleagues and we did receive your spreadsheet and the supplemental information submitted
on Jan. 6, 2011 (the number of individuals in each tier). At this time, we do not require additional information;
however, further information may be requested during the processing of your application.
Someone from this office should be in touch with you next week.
Good luck with the snowstorm.
----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services
jennifer.sheer@hhs.gov
301-492-4487
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
UFireA:000051
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This information has not been publicly disclosed and may be privileged and confidential. It is for internal government
use only and must not be disseminated, distributed, or copied to persons not authorized to receive the information.
Unauthorized disclosure may result in prosecution to the full extent of the law.
From: Sheer, Jennifer (HHS/OCIIO)
Sent: Monday, January 10, 2011 4:27 PM
To: 'bstraub@ufanyc.org'
Cc: 'tcarapella@ufanyc.org'
Subject: Uniformed Firefighters Association of New York, Waiver Application
Hello
On Dec. 9, 2010, my colleague Veronica Morales sent you the email below (please see below my signature for the
original message). We have not yet received a reply regarding this information request. Without your reply, we are
unable to process your application for an annual limit waiver. Please provide the requested information by 5pm
Tuesday, January 11, 2011. Please feel free to email or call me if you have any questions.
Thank you.
----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight U.S. Department of Health and Human Services
jennifer.sheer@hhs.gov
301-492-4487
[ORINGAL MESSAGE]
From: Morales, Veronica (HHS/OCIIO)
Sent: Thursday, December 09, 2010 3:02 PM
To: 'bstraub@ufanyc.org'
Cc: 'Tcarapella@ufanyc.org'; Sheer, Jennifer (HHS/OCIIO)
Subject: Uniformed Forefighters Association of New York, Waiver Application
Attachments: Waiver Application Form.xls
Dear Mr. Straub:
Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act
(PHS Act) Section 2711. In order to expedite your application, please provide the following information:
I. Please complete the entire annual limits spreadsheet, [attached to the email] [and available at:
http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html]. Please return the completed spreadsheet to this
email address as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell
should contain the information requested). If a cell on the spreadsheet does not pertain to your plan, please write
None, and/or provide an explanation regarding why you are unable to complete that particular cell in a separate
document.
II. In addition, please provide the following information:
UFireA:000052
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Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?
Confirm whether the plan was created pursuant to the Taft-Hartley Act.
In order to complete your application, please provide this information by 5:00 pm, December 10, 2010. Once this
information is received and the application is complete, it will be processed by the Department of Health and Human
Services (HHS). As stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30
days of receiving a complete application. You will receive an e-mail from HHS notifying you of the waiver decision.
Thank you.
Veronica W. Morales, J.D.
U.S. Department of Health & Human Services
Office of Consumer Information & Insurance Oversight
Office of Consumer Support
Phone# (301) 492-4249
Email: veronica.morales@hhs.gov<mailto:veronica.morales@hhs.gov>
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and confidential. It is for internal government
use only and must not be disseminated, distributed, or copied to persons not authorized to receive the information.
Unauthorized disclosure may result in prosecution to the full extent of the law.
STATEMENT OF CONFIDENTIALITY
The information contained in this electronic message and any attachments to this message are intended for the
exclusive use of the addressee(s) and may contain confidential or privileged information. If you are not the intended
recipient, please notify us immediately by e-mail reply to sender or by telephone to Uniformed Firefighters Association
at (212) 683-4832, and destroy all copies of this message and any attachments. Please note that any views or opinions
presented in this email are solely those of the author and do not necessarily represent those of the Uniformed
Firefighters Association.
Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts
no liability for any damage caused by any virus transmitted by this email.
UFireA:000053
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file:///C|/...t%20Fund%20of%20the%20Uniformed%20Firefighters%20Assoc%20of%20New%20York%20City/Approval%201.31.11.htm[08/15/2011 11:10:53 AM]
From: Botwinick, Alexandra (HHS/OCIIO)
Sent: Monday, January 31, 2011 10:53 AM
To: 'bstraub@ufanyc.org'
Cc: Habit, Sandra (HHS/OCIIO)
Subject: Security Benefit Fund of the Uniformed Firefighters Association of New York City Waiver of the Annual
Limits Requirements 1-31-2011
Importance: High
Attachments: July 1 .pdf
Good Morning,

Thank you for submitting an application for a Waiver of the Annual Limits Requirements of the PHS Act
Section 2711 for Security Benefit Fund of the Uniformed Firefighters Association of New York City. HHS has
reviewed your application and made its determination. Please see the attached letter.

Please confirm receipt of this letter by replying to this e-mail.

Please let me know if I can be of further assistance.

Alexandra Botwinick

Office of Oversight
HHS/OCIIO
alexandra.botwinick@hhs.gov




UFireA:000054
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file:///C|/...%20of%20the%20Uniformed%20Firefighters%20Assoc%20of%20New%20York%20City/Approval%20receipt%202.1.11.htm[08/15/2011 11:10:53 AM]
From: Carapella,Theresa [tcarapella@ufanyc.org]
Sent: Tuesday, February 01, 2011 9:33 AM
To: Habit, Sandra (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of New York, Waiver Application
Good Morning Sandra:

This will acknowledge receipt of your e-mail.



Theresa Carapella
Benefits Administrator
Uniformed Firefighters Association
Security Benefit Fund

(212) 545-6960
STATEMENT OF CONFIDENTIALITY: The information contained in this electronic message and any attachments to this message are intended for the exclusive use of
the addressee(s) and may contain confidential or privileged information. If you are not the intended recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4723, and destroy all copies of this message and any attachments.

From: Habit, Sandra (HHS/OCIIO) [mailto:Sandra.Habit@hhs.gov]
Sent: Tuesday, February 01, 2011 9:32 AM
To: Carapella,Theresa
Subject: RE: Uniformed Firefighters Association of New York, Waiver Application


From: Botwinick, Alexandra (HHS/OCIIO)
Sent: Monday, January 31, 2011 10:53 AM
To: 'bstraub@ufanyc.org'
Cc: Habit, Sandra (HHS/OCIIO)
Subject: Security Benefit Fund of the Uniformed Firefighters Association of New York City Waiver of the Annual
Limits Requirements 1-31-2011
Importance: High
Attachments: July 1 .pdf
Good Morning,

Thank you for submitting an application for a Waiver of the Annual Limits Requirements of the PHS Act
Section 2711 for Security Benefit Fund of the Uniformed Firefighters Association of New York City. HHS has
reviewed your application and made its determination. Please see the attached letter.

Please confirm receipt of this letter by replying to this e-mail.

Please let me know if I can be of further assistance.

Alexandra Botwinick

Office of Oversight
HHS/OCIIO
UFireA:000055
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alexandra.botwinick@hhs.gov

From: Carapella,Theresa [mailto:tcarapella@ufanyc.org]
Sent: Monday, J anuary 24, 2011 9:24 AM
To: Sheer, J ennifer (HHS/OCIIO)
Cc: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of New York, Waiver Application

Good Morning Jennifer:

I have not heard anything with regard to the status of the Waiver Application. Please advise.

Thank you.

Theresa Carapella
Benefits Administrator
Uniformed Firefighters Association
Security Benefit Fund

(212) 545-6960
STATEMENT OF CONFIDENTIALITY: The information contained in this electronic message and any attachments to this message are intended for the exclusive use of
the addressee(s) and may contain confidential or privileged information. If you are not the intended recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4723, and destroy all copies of this message and any attachments.

From: Sheer, J ennifer (HHS/OCIIO) [mailto:J ennifer.Sheer@hhs.gov]
Sent: Tuesday, J anuary 11, 2011 11:39 AM
To: Carapella,Theresa
Cc: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO); Morales, Veronica (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of New York, Waiver Application

Hi Theresa

I have checked with my colleagues and we did receive your spreadsheet and the supplemental information submitted on Jan.
6, 2011 (the number of individuals in each tier). At this time, we do not require additional information; however, further
information may be requested during the processing of your application.

Someone from this office should be in touch with you next week.

Good luck with the snowstorm.

----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight
U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov
301-492-4487



UFireA:000056
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file:///C|/...%20of%20the%20Uniformed%20Firefighters%20Assoc%20of%20New%20York%20City/Approval%20receipt%202.1.11.htm[08/15/2011 11:10:53 AM]
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:

This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be
disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution
to the full extent of the law.

From: Sheer, Jennifer (HHS/OCIIO)
Sent: Monday, January 10, 2011 4:27 PM
To: 'bstraub@ufanyc.org'
Cc: 'tcarapella@ufanyc.org'
Subject: Uniformed Firefighters Association of New York, Waiver Application

Hello

On Dec. 9, 2010, my colleague Veronica Morales sent you the email below (please see below my signature for the original
message). We have not yet received a reply regarding this information request. Without your reply, we are unable to process
your application for an annual limit waiver. Please provide the requested information by 5pm Tuesday, January 11, 2011.
Please feel free to email or call me if you have any questions.

Thank you.

----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight
U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov
301-492-4487


[ORINGAL MESSAGE]

From: Morales, Veronica (HHS/OCIIO)
Sent: Thursday, December 09, 2010 3:02 PM
To: 'bstraub@ufanyc.org'
Cc: 'Tcarapella@ufanyc.org'; Sheer, Jennifer (HHS/OCIIO)
Subject: Uniformed Forefighters Association of New York, Waiver Application
Attachments: Waiver Application Form.xls

Dear Mr. Straub:

Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act)
Section 2711. In order to expedite your application, please provide the following information:

I. Please complete the entire annual limits spreadsheet, [attached to the email] [and available at:
http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html]. Please return the completed spreadsheet to this email address
as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the
information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an
UFireA:000057
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file:///C|/...%20of%20the%20Uniformed%20Firefighters%20Assoc%20of%20New%20York%20City/Approval%20receipt%202.1.11.htm[08/15/2011 11:10:53 AM]
explanation regarding why you are unable to complete that particular cell in a separate document.

II. In addition, please provide the following information:

Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?

Confirm whether the plan was created pursuant to the Taft-Hartley Act.


In order to complete your application, please provide this information by 5:00 pm, December 10, 2010. Once this information
is received and the application is complete, it will be processed by the Department of Health and Human Services (HHS). As
stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30 days of receiving a complete
application. You will receive an e-mail from HHS notifying you of the waiver decision.

Thank you.

Veronica W. Morales, J.D.
U.S. Department of Health & Human Services
Office of Consumer Information & Insurance Oversight
Office of Consumer Support
Phone# (301) 492-4249
Email: veronica.morales@hhs.gov



INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:

This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be
disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution
to the full extent of the law.

STATEMENT OF CONFIDENTIALITY

The information contained in this electronic message and any attachments to
this message are intended for the exclusive use of the addressee(s) and may
contain confidential or privileged information. If you are not the intended
recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4832, and destroy
all copies of this message and any attachments. Please note that any views or
opinions presented in this email are solely those of the author and do not
necessarily represent those of the Uniformed Firefighters Association.
Finally, the recipient should check this email and any attachments for the
presence of viruses. The company accepts no liability for any damage caused by
any virus transmitted by this email.
STATEMENT OF CONFIDENTIALITY

The information contained in this electronic message and any attachments to
this message are intended for the exclusive use of the addressee(s) and may
contain confidential or privileged information. If you are not the intended
recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4832, and destroy
all copies of this message and any attachments. Please note that any views or
opinions presented in this email are solely those of the author and do not
necessarily represent those of the Uniformed Firefighters Association.
Finally, the recipient should check this email and any attachments for the
presence of viruses. The company accepts no liability for any damage caused by
any virus transmitted by this email.
UFireA:000058
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file:///C|/...0of%20the%20Uniformed%20Firefighters%20Assoc%20of%20New%20York%20City/Forwarded%20message%202.1.11.htm[08/15/2011 11:10:54 AM]
From: Habit, Sandra (HHS/OCIIO)
Sent: Tuesday, February 01, 2011 9:32 AM
To: 'Carapella,Theresa'
Subject: RE: Uniformed Firefighters Association of New York, Waiver Application
Attachments: July 1 .pdf

From: Botwinick, Alexandra (HHS/OCIIO)
Sent: Monday, January 31, 2011 10:53 AM
To: 'bstraub@ufanyc.org'
Cc: Habit, Sandra (HHS/OCIIO)
Subject: Security Benefit Fund of the Uniformed Firefighters Association of New York City Waiver of the Annual
Limits Requirements 1-31-2011
Importance: High
Attachments: July 1 .pdf
Good Morning,

Thank you for submitting an application for a Waiver of the Annual Limits Requirements of the PHS Act
Section 2711 for Security Benefit Fund of the Uniformed Firefighters Association of New York City. HHS has
reviewed your application and made its determination. Please see the attached letter.

Please confirm receipt of this letter by replying to this e-mail.

Please let me know if I can be of further assistance.

Alexandra Botwinick

Office of Oversight
HHS/OCIIO
alexandra.botwinick@hhs.gov

From: Carapella,Theresa [mailto:tcarapella@ufanyc.org]
Sent: Monday, J anuary 24, 2011 9:24 AM
To: Sheer, J ennifer (HHS/OCIIO)
Cc: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of New York, Waiver Application

Good Morning Jennifer:

I have not heard anything with regard to the status of the Waiver Application. Please advise.

Thank you.

Theresa Carapella
Benefits Administrator
Uniformed Firefighters Association
Security Benefit Fund

(212) 545-6960
STATEMENT OF CONFIDENTIALITY: The information contained in this electronic message and any attachments to this message are intended for the exclusive use of
UFireA:000059
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file:///C|/...0of%20the%20Uniformed%20Firefighters%20Assoc%20of%20New%20York%20City/Forwarded%20message%202.1.11.htm[08/15/2011 11:10:54 AM]
the addressee(s) and may contain confidential or privileged information. If you are not the intended recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4723, and destroy all copies of this message and any attachments.

From: Sheer, J ennifer (HHS/OCIIO) [mailto:J ennifer.Sheer@hhs.gov]
Sent: Tuesday, J anuary 11, 2011 11:39 AM
To: Carapella,Theresa
Cc: Moultrie, Cam (HHS/OCIIO); Habit, Sandra (HHS/OCIIO); Morales, Veronica (HHS/OCIIO)
Subject: RE: Uniformed Firefighters Association of New York, Waiver Application

Hi Theresa

I have checked with my colleagues and we did receive your spreadsheet and the supplemental information submitted on Jan.
6, 2011 (the number of individuals in each tier). At this time, we do not require additional information; however, further
information may be requested during the processing of your application.

Someone from this office should be in touch with you next week.

Good luck with the snowstorm.

----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight
U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov
301-492-4487



INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:

This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be
disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution
to the full extent of the law.

From: Sheer, Jennifer (HHS/OCIIO)
Sent: Monday, January 10, 2011 4:27 PM
To: 'bstraub@ufanyc.org'
Cc: 'tcarapella@ufanyc.org'
Subject: Uniformed Firefighters Association of New York, Waiver Application

Hello

On Dec. 9, 2010, my colleague Veronica Morales sent you the email below (please see below my signature for the original
message). We have not yet received a reply regarding this information request. Without your reply, we are unable to process
your application for an annual limit waiver. Please provide the requested information by 5pm Tuesday, January 11, 2011.
Please feel free to email or call me if you have any questions.

Thank you.
UFireA:000060
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----------------------------------
Jennifer L. O. Sheer
Office of Consumer Support
Office of Consumer Information and Insurance Oversight
U.S. Department of Health and Human Services

jennifer.sheer@hhs.gov
301-492-4487


[ORINGAL MESSAGE]

From: Morales, Veronica (HHS/OCIIO)
Sent: Thursday, December 09, 2010 3:02 PM
To: 'bstraub@ufanyc.org'
Cc: 'Tcarapella@ufanyc.org'; Sheer, Jennifer (HHS/OCIIO)
Subject: Uniformed Forefighters Association of New York, Waiver Application
Attachments: Waiver Application Form.xls

Dear Mr. Straub:

Thank you for your application for the Waiver of the Annual Limits Requirements of the Public Health Service Act (PHS Act)
Section 2711. In order to expedite your application, please provide the following information:

I. Please complete the entire annual limits spreadsheet, [attached to the email] [and available at:
http://www.hhs.gov/ociio/regulations/annual_limit_waivers.html]. Please return the completed spreadsheet to this email address
as an attachment. We will only be able to process spreadsheets that are fully complete (i.e., every cell should contain the
information requested). If a cell on the spreadsheet does not pertain to your plan, please write None, and/or provide an
explanation regarding why you are unable to complete that particular cell in a separate document.

II. In addition, please provide the following information:

Confirm whether the plan was in existence prior to March 23, 2010. If so, is the plan in compliance with
grandfathering provisions, pursuant to 45 CFR 147.140?

Confirm whether the plan was created pursuant to the Taft-Hartley Act.


In order to complete your application, please provide this information by 5:00 pm, December 10, 2010. Once this information
is received and the application is complete, it will be processed by the Department of Health and Human Services (HHS). As
stated in our September 3, 2010 Sub-Regulatory Guidance, HHS will issue a decision within 30 days of receiving a complete
application. You will receive an e-mail from HHS notifying you of the waiver decision.

Thank you.

Veronica W. Morales, J.D.
U.S. Department of Health & Human Services
Office of Consumer Information & Insurance Oversight
Office of Consumer Support
UFireA:000061
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file:///C|/...0of%20the%20Uniformed%20Firefighters%20Assoc%20of%20New%20York%20City/Forwarded%20message%202.1.11.htm[08/15/2011 11:10:54 AM]
Phone# (301) 492-4249
Email: veronica.morales@hhs.gov



INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:

This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be
disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution
to the full extent of the law.

STATEMENT OF CONFIDENTIALITY

The information contained in this electronic message and any attachments to
this message are intended for the exclusive use of the addressee(s) and may
contain confidential or privileged information. If you are not the intended
recipient, please notify us immediately by e-mail reply to sender or by
telephone to Uniformed Firefighters Association at (212) 683-4832, and destroy
all copies of this message and any attachments. Please note that any views or
opinions presented in this email are solely those of the author and do not
necessarily represent those of the Uniformed Firefighters Association.
Finally, the recipient should check this email and any attachments for the
presence of viruses. The company accepts no liability for any damage caused by
any virus transmitted by this email.
UFireA:000062
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