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保险业协会HR分析报告
Agenda
The Environment
The Catch-22
Paths Away from Traditionion Drugs
If made into law, will have major impact on retiree benefits and strategies
Initial confusion aside, should have positive impact on retiree plans
Expect cost shifting to negatively impact active plans
EEOC Proposed changes in ADEA regulations
Cline vs. General Dynamics
Wells Fargo case
Appears to allow pre-funding (and tax-deductibility) of entire retiree liability
an ILP approach
won’t be exactly same number as FAS liability
funding in years 2+ would be limited to service cost
IRS weighing its options
Proposals to Increase Coverage Among Early Retirees Few government programs except for financially indigent
COBRA extensions and/or Medicare buy-ins
Prohibitions on post-retirement benefit reductions
Expanded pre-funding for retiree medical
Still few viable products for pre-65 in individual market that overcome access and affordability issues.
ADEA Issues Impact on retiree medical coverage
Age Discrimination in Employment Act (ADEA) prohibits discrimination against persons age 40 or older in terms and conditions of employment
Age-based distinctions in employee benefit plans are permissible only if:
A specific statutory exception applies, or
Equal benefit/equal cost test is satisfied
Plan must provide equal benefits for older and younger workers, or
Plan must incur equal costs for older and younger workers
Third and Sixth Circuit Courts reach different conclusions
EEOC reviewing ADEA regulations
Marketplace Changes Consolidation of Major Health Care Carriers Employer options are greatly reduced, carriers have more clout
United Healthcare
HealthSource
Provident
CIGNA
Equicor
Metrahealth
US Healthcare
Aetna
TakeCare
FHP
PacifiCare
HealthSource
CIGNA
Aetna US Healthcare
NYLCare
Prudential HealthCare
FHP
PacifiCare
Provident
Transamerica
Equitable
HCA
Metropolitan
Partners
Aetna
GSDHP
Lincoln National HPs
Tak