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  • 7/27/2019 Nexion - Redacted HWM

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    //T|/CCIIO%20Waivers%20-%20Torres/DFOI%20Processing%20Team/Mike/Nexion%20Health/Waiver%20Application%20.txt[11/01/2011 5:25:48 PM

    rom: [email protected]: Tuesday, October 19, 2010 5:27 PMo: HHS HealthInsurance (HHS)

    Cc: [email protected]; [email protected]: Waiver Application

    Attachments: Waiver Application from Nexion.pdf

    Dear Sir/Madam:Attached please find a Waiver Application on behalf of Nexion Health.hould you have any questions, please contact Miki Kolton at02-331-3134 or by email at [email protected]

    hanks,

    Helen Wicecarveregal Secretary

    Greenberg Traurig LLP | 2101 L Street N.W. | Washington, D.C. 20037el 202-533-2315

    [email protected] | www.gtlaw.com

    -------------------------------------------------------------------------ax Advice Disclosure: To ensure compliance with requirements imposed by the IRS under Circular 230, we informou that any U.S. federal tax advice contained in this communication (including any attachments), unless otherwisepecifically stated, was not intended or written to be used, and cannot be used, for the purpose of (1) avoidingenalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any mattddressed herein.he information contained in this transmission may contain privileged and confidential information. It is intended o

    or the use of the person(s) named above. If you are not the intended recipient, you are hereby notified that any reviissemination, distribution or duplication of this communication is strictly prohibited. If you are not the intended

    ecipient, please contact the sender by reply email and destroy all copies of the original message. To reply to our emdministrator directly, please send an email to mailto:postmaster@gtlaw.com.-------------------------------------------------------------------------

    ttp://www.gtlaw.com/

    NEXION:000001

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    NEXION:000002

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    NEXION:000003

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    NEXION:000004

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    Pages 5 through 85 redacted for the following reasons:- - - - - - - - - - - - - - - - - - - - - - - - - - - -Exemption 4

    NEXION:000005

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    //T|/...%20-%20Torres/DFOI%20Processing%20Team/Mike/Nexion%20Health/Request%20for%20Additional%20Info%2011.3.10.htm[11/01/2011 5:25

    rom: Campbell, Lisa (HHS/OCIIO)ent: Wednesday, November 03, 2010 1:45 PM

    To: '[email protected]'Cc: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application from Nexion

    ear Applicant:

    hank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section

    711. In order to complete your application, please provide the following information:

    Please provide the current monthly premium rates and the projected monthly premium rates applica

    to the plan or policy forms if the plan were to comply with the restricted annual benefits. In other

    words, we would like a chart that reflects the following information:

    2010 JanuaryPremium (currentlevel)

    2011 JanuaryPremium (renewal)

    2011 JanuaryPremium (if $750,000annual limit wasapplied)

    EEEE + Child (ifapplicable or otherappropriate tier)

    EE + Spouse (ifapplicable or otherappropriate tier)

    Family (if applicableor other appropriatetier)

    n order to complete your application, please provide this information by 5:00 pm, November 3, 2010. We

    ook forward to receiving your completed application. Thank you.

    isa Campbell

    epartment of Health and Human Services

    ffice of Consumer Information and Insurance Oversight

    301) 492-4159

    NEXION:000006

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    //T|/...es/DFOI%20Processing%20Team/Mike/Nexion%20Health/Request%20for%20Additional%20Info%20Response%2011.3.10.htm[11/01/2011 5:25

    rom: Campbell, Lisa (HHS/OCIIO)ent: Wednesday, November 03, 2010 1:54 PM

    To: '[email protected]'Cc: Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application from Nexionear Miki,

    omorrow will be fine.

    hank you for your prompt response.

    sa Campbell

    rom: [email protected] [mailto:[email protected]]ent: Wednesday, November 03, 2010 1:49 PMo: Campbell, Lisa (HHS/OCIIO)ubject: RE: Waiver Application from Nexion

    Thank you for your e-mail, which was sent at 1:45PM today. In the email you ask for return

    he requested information by 5PM today. We will certainly try to comply with that request, bu

    would tomorrow also be acceptable?Thank you,

    Miki Kolton

    Tax Advice Disclosure: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that a

    U.S. federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was no

    ntended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code o

    romoting, marketing or recommending to another party any matters addressed herein.

    The information contained in this transmission may contain privileged and confidential information. It is intended only for th

    se of the person(s) named above. If you are not the intended recipient, you are hereby notified that any review, dissemination,

    istribution or duplication of this communication is strictly prohibited. If you are not the intended recipient, please contact the

    ender by reply email and destroy all copies of the original message. To reply to our email administrator directly, please send an

    mail to [email protected].

    rom: Campbell, Lisa (HHS/OCIIO) [mailto:[email protected]]ent: Wednesday, November 03, 2010 1:45 PMo: Kolton, Miki (OfCnsl-DC-HC)c: Habit, Sandra (HHS/OCIIO)

    ubject: Waiver Application from Nexion

    ear Applicant:

    hank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section

    711. In order to complete your application, please provide the following information:

    Please provide the current monthly premium rates and the projected monthly premium rates applica

    to the plan or policy forms if the plan were to comply with the restricted annual benefits. In other

    words, we would like a chart that reflects the following information:

    NEXION:000007

    mailto:[email protected]:[email protected]:[email protected]
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    //T|/...es/DFOI%20Processing%20Team/Mike/Nexion%20Health/Request%20for%20Additional%20Info%20Response%2011.3.10.htm[11/01/2011 5:25

    2010 JanuaryPremium (currentlevel)

    2011 JanuaryPremium (renewal)

    2011 JanuaryPremium (if $750,000annual limit wasapplied)

    EE

    EE + Child (ifapplicable or otherappropriate tier)

    EE + Spouse (ifapplicable or otherappropriate tier)

    Family (if applicableor other appropriatetier)

    n order to complete your application, please provide this information by 5:00 pm, November 3, 2010. We

    ook forward to receiving your completed application. Thank you.

    isa Campbell

    epartment of Health and Human Services

    ffice of Consumer Information and Insurance Oversight

    301) 492-4159

    NEXION:000008

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    //T|/...Torres/DFOI%20Processing%20Team/Mike/Nexion%20Health/2nd%20Request%20for%20Additional%20Info%2011.33.10.htm[11/01/2011 5:25

    rom: Campbell, Lisa (HHS/OCIIO)ent: Wednesday, November 03, 2010 5:17 PM

    To: '[email protected]'Cc: [email protected]; Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application from Nexionear Miki,

    hanks for getting back to me so quickly. In addition to the employee's share of the premium, could you also provide the

    mployer's share, if any?

    hank you.

    isa Campbell

    epartment of Health and Human Services

    ffice of Consumer Information and Insurance Oversight

    301) 492-4159

    rom: [email protected] [mailto:[email protected]]ent: Wednesday, November 03, 2010 4:36 PMo: Campbell, Lisa (HHS/OCIIO)c: [email protected]: RE: Waiver Application from Nexion

    1. Lisa: Here are the numbers from Nexion in response to your request. Please let me or Nancy Taylor

    know if you need additional Information of if you need the information in a different format.

    2.

    3. Regards,

    4. Miki Kolton

    5. 202-331-3134

    6.7.

    Please provide the current monthly premium rates and the projected monthly premium rates applicable he plan or policy forms if the plan were to comply with the restricted annual benefits. In other words, we

    would like a chart that reflects the following information:

    2010 JanuaryPremium (currentlevel)

    employee

    contribution

    premium bi-weekly

    premium

    2011 JanuaryPremium (renewal)

    with waiver

    employee bi-

    weekly premium

    2011 JanuaryPremium (if $750,000annual limit was

    applied) bi-weekly

    employee premium.

    These estimated

    values reflect

    premium costs ifannual limit

    requirements were

    applied and they

    exceed costs that

    our employees canEE EE + Child orChildren (if applicable

    NEXION:000009

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    //T|/...Torres/DFOI%20Processing%20Team/Mike/Nexion%20Health/2nd%20Request%20for%20Additional%20Info%2011.33.10.htm[11/01/2011 5:25

    or other appropriatetier)

    EE + Spouse (ifapplicable or otherappropriate tier)

    Family (if applicableor other appropriatetier)

    Tax Advice Disclosure: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that a

    U.S. federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was no

    ntended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code o

    romoting, marketing or recommending to another party any matters addressed herein.

    The information contained in this transmission may contain privileged and confidential information. It is intended only for th

    se of the person(s) named above. If you are not the intended recipient, you are hereby notified that any review, dissemination,

    istribution or duplication of this communication is strictly prohibited. If you are not the intended recipient, please contact the

    ender by reply email and destroy all copies of the original message. To reply to our email administrator directly, please send an

    mail to [email protected].

    rom: Campbell, Lisa (HHS/OCIIO) [mailto:[email protected]]ent: Wednesday, November 03, 2010 1:45 PMo: Kolton, Miki (OfCnsl-DC-HC)c: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application from Nexion

    ear Applicant:

    hank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section711. In order to complete your application, please provide the following information:

    Please provide the current monthly premium rates and the projected monthly premium rates applica

    to the plan or policy forms if the plan were to comply with the restricted annual benefits. In other

    words, we would like a chart that reflects the following information:

    2010 JanuaryPremium (currentlevel)

    2011 JanuaryPremium (renewal)

    2011 JanuaryPremium (if $750,000annual limit was

    applied)EE

    EE + Child (ifapplicable or otherappropriate tier)

    EE + Spouse (ifapplicable or otherappropriate tier)

    Family (if applicableor other appropriatetier)

    NEXION:000010

    mailto:[email protected]:[email protected]:[email protected]
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    //T|/...Torres/DFOI%20Processing%20Team/Mike/Nexion%20Health/2nd%20Request%20for%20Additional%20Info%2011.33.10.htm[11/01/2011 5:25

    n order to complete your application, please provide this information by 5:00 pm, November 3, 2010. We

    ook forward to receiving your completed application. Thank you.

    isa Campbell

    epartment of Health and Human Services

    ffice of Consumer Information and Insurance Oversight

    301) 492-4159

    NEXION:000011

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    //T|/...ocessing%20Team/Mike/Nexion%20Health/2nd%20Request%20for%20Additional%20INfo%20Correspondence%2011.4.10.htm[11/01/2011 5:25

    rom: Campbell, Lisa (HHS/OCIIO)ent: Thursday, November 04, 2010 2:24 PM

    To: '[email protected]'Cc: [email protected]; Habit, Sandra (HHS/OCIIO); [email protected]: RE: Waiver Application from Nexion Healthhank you for your prompt response.

    sa Campbell

    rom: [email protected] [mailto:[email protected]]ent: Thursday, November 04, 2010 2:21 PMo: Campbell, Lisa (HHS/OCIIO)c: [email protected]; Habit, Sandra (HHS/OCIIO); [email protected]: RE: Waiver Application from Nexion Health

    Dear Lisa: Here is the table with the information that you requested from Nexion Health. W

    sed total annual premiums and show the split between employer and employee. Please

    et Nancy Taylor (202-331-3133) or me (202-331-3134) know if you have any questions.

    Regards, Miki Kolton

    Nexion Health2010 JanuaryPremium (currentlevel) Annual

    2011 JanuaryPremium (renewal)with waiver Annual

    2011 JanuaryPremium (if $750,000annual limit wasapplied) Theseestimated valuesreflect premium costsif annual limitrequirements wereapplied and theyexceed costs that our

    employees can afford.EE

    Employee share: Employee share:

    remium:Employee share:

    loyer share:EE + Children (ifapplicable or otherappropriate tier)

    Total Premium:Employee share:Employer share:

    Total Premium:Employee share:Employer share:

    Total Premium:Employee share:Employer share:

    EE + Spouse (ifapplicable or otherappropriate tier)

    Total Premium:Employee share:Employer share:

    Total Premium:Employee share:Employer share:

    Total Premium:Employee share:Employer share:

    Family (if applicableor other appropriate

    Total Premium:Employee share:

    Total Premium: Total Premium:NEXION:000012

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    //T|/...ocessing%20Team/Mike/Nexion%20Health/2nd%20Request%20for%20Additional%20INfo%20Correspondence%2011.4.10.htm[11/01/2011 5:25

    tier) Employer share:

    loyee share:loyer share:

    Employee share:Employer share:

    iki Kolton, MSN, JDf Counselreenberg Traurig LLP01 L Street N.W. | Washington, D.C. 20037

    el 202.331.3134 | Fax [email protected]| www.gtlaw.com

    rom: Campbell, Lisa (HHS/OCIIO) [mailto:[email protected]]ent: Wednesday, November 03, 2010 5:17 PM

    o: Kolton, Miki (OfCnsl-DC-HC)c: Taylor, Nancy (Shld-DC-HC); Habit, Sandra (HHS/OCIIO)ubject: RE: Waiver Application from Nexion

    ear Miki,

    hanks for getting back to me so quickly. In addition to the employee's share of the premium, could you also provide the

    mployer's share, if any?

    hank you.

    isa Campbell

    epartment of Health and Human Services

    ffice of Consumer Information and Insurance Oversight

    301) 492-4159

    rom: [email protected] [mailto:[email protected]]ent: Wednesday, November 03, 2010 4:36 PMo: Campbell, Lisa (HHS/OCIIO)c: [email protected]: RE: Waiver Application from Nexion

    1. Lisa: Here are the numbers from Nexion in response to your request. Please let me or Nancy Taylor

    know if you need additional Information of if you need the information in a different format.

    2.3. Regards,

    4. Miki Kolton

    5. 202-331-3134

    6.7.

    Please provide the current monthly premium rates and the projected monthly premium rates applicable

    he plan or policy forms if the plan were to comply with the restricted annual benefits. In other words, we

    would like a chart that reflects the following information:

    NEXION:000013

    mailto:[email protected]://www.gtlaw.com/mailto:[email protected]:[email protected]://www.gtlaw.com/http://www.gtlaw.com/mailto:[email protected]
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    //T|/...ocessing%20Team/Mike/Nexion%20Health/2nd%20Request%20for%20Additional%20INfo%20Correspondence%2011.4.10.htm[11/01/2011 5:25

    2010 JanuaryPremium (currentlevel)

    employee

    contribution

    premium bi-weekly

    premium

    2011 JanuaryPremium (renewal)

    with waiver

    employee bi-

    weekly premium

    2011 JanuaryPremium (if $750,000annual limit was

    applied) bi-weekly

    employee premium.

    These estimated

    values reflect

    premium costs if

    annual limit

    requirements were

    applied and they

    exceed costs that

    our employees canEE EE + Child orChildren (if applicableor other appropriatetier)

    EE + Spouse (ifapplicable or otherappropriate tier)

    Family (if applicableor other appropriatetier)

    Tax Advice Disclosure: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that a

    U.S. federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was no

    ntended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code o

    romoting, marketing or recommending to another party any matters addressed herein.

    The information contained in this transmission may contain privileged and confidential information. It is intended only for th

    se of the person(s) named above. If you are not the intended recipient, you are hereby notified that any review, dissemination,

    istribution or duplication of this communication is strictly prohibited. If you are not the intended recipient, please contact the

    ender by reply email and destroy all copies of the original message. To reply to our email administrator directly, please send an

    mail to [email protected].

    rom: Campbell, Lisa (HHS/OCIIO) [mailto:[email protected]]

    ent: Wednesday, November 03, 2010 1:45 PMo: Kolton, Miki (OfCnsl-DC-HC)c: Habit, Sandra (HHS/OCIIO)ubject: Waiver Application from Nexion

    ear Applicant:

    hank you for your application for the Waiver of the Annual Limits Requirements of the PHS Act Section

    711. In order to complete your application, please provide the following information:

    NEXION:000014

    mailto:[email protected]:[email protected]:[email protected]
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    //T|/...ocessing%20Team/Mike/Nexion%20Health/2nd%20Request%20for%20Additional%20INfo%20Correspondence%2011.4.10.htm[11/01/2011 5:25

    Please provide the current monthly premium rates and the projected monthly premium rates applica

    to the plan or policy forms if the plan were to comply with the restricted annual benefits. In other

    words, we would like a chart that reflects the following information:

    2010 JanuaryPremium (currentlevel)

    2011 JanuaryPremium (renewal)

    2011 JanuaryPremium (if $750,000annual limit wasapplied)

    EEEE + Child (ifapplicable or otherappropriate tier)

    EE + Spouse (ifapplicable or otherappropriate tier)

    Family (if applicableor other appropriatetier)

    n order to complete your application, please provide this information by 5:00 pm, November 3, 2010. We

    ook forward to receiving your completed application. Thank you.

    isa Campbell

    epartment of Health and Human Services

    ffice of Consumer Information and Insurance Oversight

    301) 492-4159

    NEXION:000015

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    //T|/...aivers%20-%20Torres/DFOI%20Processing%20Team/Mike/Nexion%20Health/Approval%20Letter%20Sent%2011-15-2010.htm[11/01/2011 5:25

    rom: Botwinick, Alexandra (HHS/OCIIO)ent: Monday, November 15, 2010 9:58 AM

    To: '[email protected]'ubject: Waiver of the Annual Limits Requirements of PHS Act Section 2711

    mportance: High

    Attachments: November Approval Letter .pdf

    ood Morning,

    hank you for submitting an application for a Waiver of the Annual Limits Requirements of the PHS Act

    ection for Nexion. HHS has reviewed your application and made its determination. Please see the attached

    etter.

    lease confirm receipt of this letter by replying to this e-mail address with a copy to [email protected]

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

    incerely,

    Alexandra Botwinick

    ffice of Oversight

    HHS/[email protected]

    NEXION:000016

    mailto:[email protected]:[email protected]
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    NEXION:000017

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    NEXION:000018

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    //T|/...%20Processing%20Team/Mike/Nexion%20Health/Confirmation%20of%20Approval%20letter%2011-15-2010.htm[11/01/2011 5:2

    rom: [email protected]: Monday, November 15, 2010 10:04 AMo: Botwinick, Alexandra (HHS/OCIIO)

    Cc: OCIIO OversightSubject: RE: Waiver of the Annual Limits Requirements of PHS Act Section 2711

    Dear Ms. Botwinick: Per your request, we are acknowledging receipt of your office's approva

    Nexion Health's waiver application.

    Regards,

    Miki Kolton

    Tax Advice Disclosure: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that a

    U.S. federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was no

    ntended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code o

    romoting, marketing or recommending to another party any matters addressed herein.

    The information contained in this transmission may contain privileged and confidential information. It is intended only for th

    se of the person(s) named above. If you are not the intended recipient, you are hereby notified that any review, dissemination,istribution or duplication of this communication is strictly prohibited. If you are not the intended recipient, please contact the

    ender by reply email and destroy all copies of the original message. To reply to our email administrator directly, please send an

    mail to [email protected].

    rom: Botwinick, Alexandra (HHS/OCIIO) [mailto:[email protected]]ent: Monday, November 15, 2010 9:58 AMo: Kolton, Miki (OfCnsl-DC-HC)ubject: Waiver of the Annual Limits Requirements of PHS Act Section 2711mportance: High

    ood Morning,

    hank you for submitting an application for a Waiver of the Annual Limits Requirements of the PHS Act

    ection for Nexion. HHS has reviewed your application and made its determination. Please see the attached

    etter.

    lease confirm receipt of this letter by replying to this e-mail address with a copy to [email protected]

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

    incerely,

    Alexandra Botwinick

    ffice of Oversight

    HHS/[email protected]

    NEXION:000019

    mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]
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