HR Focus

HUMAN CAPITAL PRACTICE
HRFocus
August 2015
www.willis.com
HR CORNER
EEO-1 REPORTING DEADLINE
APPROACHING…ARE YOU READY?
By Marina A. Galatro, PHR-CA, SHRM-CP
Sr. HR Consultant, HR Partner
Willis Human Capital Practice
EEOC and OFCCP regulators pay close attention to
the Employer Information Report, also known as the
EEO-1 Report, and use it to identify patterns of workplace
discrimination. These reports, required of every employer
with 100 or more employees and smaller employers who are
federal contractors, must be prepared annually and include
employee demographics throughout an organization. This is
not voluntary – it is a legal obligation to provide the required
data. Any employer failing or refusing to file the EEO-1 Report
may be compelled to file by order of a U.S. District Court.
Employers often misunderstand how to file the report.
Incorrect reporting may open the door to legal liability and
discrimination claims from regulators and private parties.
With the upcoming filing deadline of September 30, 2015 fast
approaching, understanding the data gathering and reporting
requirements is key to staying in compliance. Employers may
find information on how to file the report on the EEOC website.
I’ve highlighted some of the reporting information below.
WHAT IS THE EEO-1 REPORT?
The EEO-1 Report is a compliance survey mandated by
federal statute and regulations. The survey requires company
employment data to be categorized by race/ethnicity, gender
and job category. The EEO-1 instruction booklet and a sample
copy of the EEO-1 form are available HERE.
WHO MUST FILE?
The Standard Form 100 (EEO-1) must be filed by:
A. All private employers who are:
1. Subject to Title VII of the Civil Rights Act of 1964
(as amended by the Equal Employment Opportunity
Act of 1972) with 100 or more employees EXCLUDING
state and local governments, primary and secondary
school systems, institutions of higher education, Indian
tribes and tax-exempt private membership clubs other
than labor organizations
Continued on page 2
HR CORNER
EEO-1 Reporting Deadline Approaching…Are You Ready?........ 1
HEALTH OUTCOMES
Weighing in on Workplace Weight Management Programs.......3
LEGAL AND COMPLIANCE
IRS Issues Interim Guidance on Expatriate Plans.....................5
SINCE YOU ASKED
What Are PPACA’S 2016 Out-of-Pocket Limits?.........................6
WEBCASTS......................................................................7
CONTACTS�� 8
Willis North America | August 2015
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HR Corner – continued from page 1
OR
2. Subject to Title VII who have fewer than 100 employees if the company is owned or affiliated with another
company, or there is centralized ownership, control or management (such as central control of personnel
policies and labor relations) so that the group legally constitutes a single enterprise, and the entire enterprise
employs a total of 100 or more employees
B. All federal contractors (private employers), who:
1. Are not exempt as provided for by 41 CFR 60-1.5
2. Have 50 or more employees, and
A. Are prime contractors or first-tier subcontractors, and have a contract, subcontract, or purchase order
amounting to $50,000 or more, or
B. Serve as a depository of government funds in any amount, or
C. Is a financial institution which is an issuing and paying agent for U.S. Savings Bonds and Notes
Only those establishments located in the District of Columbia and the 50 states are required to submit Standard
Form 100. No reports should be filed for establishments in Puerto Rico, the Virgin Islands or other American
protectorates.
HOW TO FILE?
The preferred method for completing the EEO-1 report is the web-based online filing system. Data is transferred over
the internet using encryption, assuring company’s privacy.
All single-establishment employers, i.e., employers doing business at only one establishment in one location,
must complete a single Standard Form 100, or use one of the alternate filing methods.
All multi-establishment employers, i.e. employers doing business at more than one establishment, must file:
1. A report covering the principal or headquarters office
2. A separate report for each establishment employing 50 or more persons
3. A consolidated report that MUST include ALL employees by race, sex and job category in establishments
with 50 or more employees as well as establishments with fewer than 50 employees
AND
4. A list, showing the name, address, total employment and major activity for each establishment employing
fewer than 50 persons, must accompany the consolidated report
WHEN TO FILE?
This annual report must be filed with the Joint Reporting Committee not later than September 30 of each year.
The 2014 EEO-1 Survey is now open.
It is important to note that for security reasons, passwords have been reset since the 2013 filing period.
New passwords will be sent by mail no later than the end of July 2015. If you cannot locate your Login ID and/or
Password, contact the EEO-1 Joint Reporting Committee at [email protected].
Need an extension? To request an extension submit an e-mail to the following address before September 30:
[email protected]. In the e-mail include Company Name, Company Number, Address, and the contact
information for the person responsible for the report.
More information on the EEO-1 Report can be found on the EEOC website. An updated FAQ can be found HERE.
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Willis North America | August 2015
HEALTH OUTCOMES
WEIGHING IN ON WORKPLACE
WEIGHT MANAGEMENT PROGRAMS
Megan Sowa, MPH
Senior Health Outcomes Consultant
Willis Human Capital Practice
Medical costs continue to increase and more employers
are looking for condition-specific interventions to
reduce this trend. Given the prevalence of obesity
among employees across industries and regions, weight
management and nutrition programs are a topic of
conversation and consideration for employers.
Willis clients continue to see high blood pressure, high
cholesterol and diabetes in their top chronic conditions.
In recent years, employers have seen “obesity” as a
diagnostic condition on their list of high cost claimants.1
The costs to cover employees with obesity and related
comorbidities, such as high blood pressure, cholesterol
and diabetes, can be over $4,000 more per year than
employees without these modifiable conditions.2
Research continues to grow, but early analysis suggests
that employer-sponsored weight loss and nutrition
programs can lead to improvements in activity, diet, and
result in weight loss for employees1. Successful weight
loss programs include the following characteristics3:
Behavioral intervention component (using behavior
change theories)
Periodic communications with health tips to
improve diet and exercise
Managerial support
Employee interest
6–12 month duration

�Two-thirds of all Americans are

overweight/obese.

� Obese employees with diabetes, high blood

pressure or high cholesterol cost employers

more in short-term disability and workers’

compensation than obese employees without

comorbidities.

� A morbidly obese employee costs an employer over

$4,000 more per year in health care and related

costs than an employee who is of normal weight.

Continued on page 4
Studies continue to evaluate the effectiveness of
financial incentives on weight loss and tailored
messaging on behavior change. Overall, incentives and
tailored messaging can produce a modest influence
on both weight loss and behavior modification, but
not significantly more than programs without these
characteristics. This is not to say that increasing a
financial reward for weight loss wouldn’t result in
a more successful program.3
Research on financial incentives indicates that
segmenting populations can help employers determine
the right amount needed to maximize participation
and outcomes. For example, employers with highly
educated, highly compensated workers may want to
offer a more sizable financial incentive to encourage
more weight loss in their population.3
Any employer offering or considering a weight loss
program should develop a method for evaluation that
involves more than just total weight lost. Tracking
communication efforts, employee participation in
various program components, periodic surveys to
assess employee behaviors and attitudes can all help
to determine program effectiveness. Comprehensive
health promotion programs that are evaluated regularly
have the best chance of demonstrating a return on
investment (ROI).2
Willis North America | August 2015
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Health Outcome– continued from page 3
Willis consultants are here to help strategize and implement a successful workplace weight management
program. Another great resource to help get you started can be found by visiting the American Institute
for Preventive Medicine.
SOURCES:
1.Review of Willis client data accessed using 2014 WillisMed Health Outcomes reporting through
Verisk Health platform.
2.Kahn, K. Obese Employees Cost Employers Thousands in Extra Medical Costs. Health Behavior News Service,
part of the Center for Advancing Health. Release date: May, 13 2014. http://www.cfah.org/hbns/2014/obeseemployees-cost-employers-thousands-in-extra-medical-costs.
3.Almeida FA, You W, Harden SM, et al. Effectiveness of a worksite-based weight loss randomized controlled trial:
The worksite study. Obesity (Silver Spring) 2015; 23:737–45. http://www.turner-white.com/pdf/jcom_jun15_
weight.pdf
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Willis North America | August 2015
LEGAL AND COMPLIANCE
IRS ISSUES INTERIM GUIDANCE ON
EXPATRIATE PLANS
In Notice 2015-43, the Internal Revenue Service (IRS), with
the support of the Departments of Labor (DOL) and Health
and Human Services (HHS), released interim guidance on
the application of certain provisions of the Patient Protection
and Affordable Care Act (PPACA) to expatriate health plans
under the Expatriate Health Coverage and Clarification
Act of 2014 (EHCCA). The interim guidance provides
applicable plans, employers and insurers with additional
time to modify their expatriate health plans and policies
to meet the exemption requirements under the EHCAA.
The interim guidance also clarifies the application of the
Patient Centered Outcomes Research Institute funding
fee (the PCORI fee) to expatriate health plans. The notice
applies to polices that are issued or renewed on or after
July 1, 2015 and plan years that start on or after July 1, 2015.
BACKGROUND
As Willis previously reported in HR Focus, February 2015, “Certain Expatriate Plans Exempt from Many Health
Care Reform Requirements,” the EHCCA exempts expatriate health plans from certain provisions of PPACA. The
exemptions under the EHCCA apply to expatriate health plans issued or renewed on or after July 1, 2015. In order to
meet the definition of an expatriate health plan under the EHCCA, the plan must be a group health plan (which includes
a self-funded plan) or health insurance coverage in which substantially all primary enrollees are “qualified expatriates.”
Under the EHCCA, qualified expatriates are (1) certain foreign employees transferred or assigned to the U.S. for a
specific and temporary employment purpose or assignment, (2) individuals working outside the U.S. for at least 180
days in a 12-month period, and (3) individuals who are members of a group of similarly situated individuals formed for
the purpose of traveling or relocating internationally for nonprofit work, such as students or religious missionaries.
The plan or policy must also meet certain coverage standards, including, among other requirements, coverage for
inpatient hospital services, outpatient facility services, physician services and emergency services.
Expatriate health plans meeting the EHCCA requirements, are deemed to meet the requirements under the employer
pay or play mandate and the individual mandate (i.e. deemed minimum essential coverage) and are exempt from
complying with many of the PPACA mandates, including prohibition on annual and lifetime dollar limits on essential
health benefits, prohibition on excessive waiting periods, out-of-pocket maximums, preventive services without
participant cost sharing, PPACA’s internal claim and appeal and external review requirements, preexisting condition
exclusions, prohibition on rescission (retroactive termination of coverage except in cases of fraud), and distribution
of summaries of benefits and coverage (SBCs) and uniform glossaries.
CONCLUSION
Until the issuance of further guidance, the interim guidance in Notice 2015-43 allows plan sponsors and
insurance issuers to apply the requirements of the EHCCA using a reasonable good faith interpretation of the
EHCCA Specifically, plan sponsors and insurance issuers may rely on the Affordable Care Act Implementation
FAQs Part XIII, Q&A-1, and FAQs XVIII, Q&A-6 and Q&A-7, for purposes of interpreting the requirements of the
EHCCA in good faith. However, employers may not rely on the good faith rules with respect to the application of
PCORI fees to expatriate health plans. The interim guidance specifically provides that for insurance policies issued
or renewed on or after July 1, 2015, or for plan years starting on or after July 1, 2015 (for self-insured plans), issuers
and plan sponsors may determine the PCORI fee by excluding lives covered under a specified plan if the facts and
circumstances demonstrate that the plan or policy covers qualified expatriates, as defined under the EHCCA.
Continued on page 6
Willis North America | August 2015
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SINCE YOU
ASKED
WHAT ARE PPACA’S 2016
OUT-OF-POCKET LIMITS?
The National Legal and Research Group (NLRG)
was recently asked what were the 2016 out-of-pocket
(OOP) limits for non-grandfathered group health plans.
The Patient Protection and Affordable Care Act
(PPACA) includes among its coverage reform
provisions a section that disallows cost sharing that
exceeds certain thresholds on essential health benefits
(EHB) under a non-grandfathered group health plan.
(An overall limit on cost sharing is referred to as an
OOP maximum.) This provision and the specified
dollar limits on OOP maximums were effective
for plan years starting on or after January 1, 2014.
HHS announced that the 2016 PPACA OOP maximum
limit will be $6,850 for self-only coverage and $13,700
for other than self-only coverage. See Willis Human
Capital Practice Alert, June 2015, “CMS Releases
Final 2016 Benefit and Payment Parameters.”
Another important change for 2016 includes the
requirement that the annual limitation on cost sharing
for self-only coverage apply to all individuals regardless
of whether the individual is covered by a self-only plan
or a plan that is other than self-only. An individual’s
cost sharing for EHBs may never exceed the self-only
annual limitation on cost sharing. Not allowing health
plans to impose cost sharing limits greater than the
individual amount for any one person covered by the
plan, even if the plan generally uses an “aggregate” cost
sharing limit for family coverage, effectively embeds an
individual out-of-pocket limit in all family group health
plans with a higher family deductible.
FAQs issued by the Departments of Labor, Treasury
and Health and Human Services confirm that this
new requirement applies:
To all non-grandfathered group health plans,
including non-grandfathered self-insured and
large group health plans
To non-grandfathered high deductible health
plans (HDHP)
To plan or policy years that begin in or after 2016
Example: Assume that a family of four individuals is
enrolled in family coverage under a group health plan
in 2016 with an aggregate annual limitation on cost
sharing for all four enrollees of $13,000. Assume that
individual #1 incurs claims associated with $10,000
in cost sharing, and that individuals #2, #3 and #4
each incur $3,000 in expenses subject to cost sharing.
Because the self-only maximum annual limitation
on cost sharing ($6,850 in 2016) applies to each
individual, cost sharing for individual #1 for 2016 is
limited to $6,850, and the plan is required to bear the
difference between the $10,000 in cost sharing for
individual #1 and the maximum annual limitation for
that individual, or $3,150. With respect to cost sharing
incurred by all four individuals under the policy, the
aggregate $15,850 ($6,850 + $3,000 + $3,000 + $3,000)
in cost sharing that would otherwise be incurred by
the four individuals together is limited to $13,000, the
annual aggregate limitation under the plan, and the
plan must bear the difference between the $15,850
and the $13,000 annual limitation, or $2,850.
While the agencies confirmed that non-grandfathered
HDHPs are subject to PPACA’s OOP limits, HDHPs
intended to be compatible with health savings accounts
(HSA) are already subject to specific OOP limits.
For 2016, the IRS announced that the HDHP OOP limit
is $6,550 for self-only coverage and $13,100 for other
coverage. This means that non-grandfathered HDHPs
are essentially subject to two OOP limits. While it
would appear that an HDHP would comply with both
limits if it complies with the lower OOP maximum, the
two limits may not apply to all of the same expenses
(i.e., PPACA’s cost-sharing limits apply only to EHBs).
As such, some plans may need to track and implement
both limits. Further, given the recent HHS guidance on
the self-only maximum limit, the lower limit for HDHP
family coverage might actually be PPACA’s self-only
annual limit when it comes to the expenses of specific
family members.
Willis North America | August 2015
6
WEBCASTS
GLOBAL WELL-BEING: HOW TO NAVIGATE
THE NEW FRONTIER
TUESDAY, AUGUST 18, 2015 2 PM EASTERN
Presented by:
Thomas J. Dolan, Senior Vice President
Human Capital & Benefits Multinational Practice
Ron Leopold, MD, MBA, MPH, Practice Leader
Health Outcomes, Human Capital Practice
The business value of a healthier workforce is increasingly
recognized around the globe as foundational to international
business operations. So many companies have adopted
wellness program – which help employees understand their
health status and improve and maintain their state of wellbeing – that we now see a groundswell of interest in taking
wellness “global.” This is the new frontier.
Multinational corporations recognize how vital these
propositions are in helping employees manage stress, be
more productive, better educated and committed to their
well-being. While the basics of well-being are universal,
the global landscape presents challenges such as cultural
nuances and sensitivities, data privacy and discrimination.
Navigating these global environs is tricky. Given the potential
impact on cost management, talent management and the
overall employee value proposition, the effort is worth it.
There is no “one size fits all” approach. How do you go
about configuring a global framework that can adapt
to different needs, wants and desires? What strategies
position companies for success? What vendors are
positioned to be strong partners?
During this session, participants will learn how to transition
to a pooled paid time off program:
U.S.-centric approaches will not work for all markets.
The full business value of success in workforce health and
wellness.
Well-being and workforce issues vary by country
and region.
Local country markets are already applying
well-being programs.
To RSVP, click here.
NOTE: Advance RSVP is required to participate in this
call. Registration ends 1 hour prior to the call start time.
UNDERSTANDING THE IMPACT OF PHARMACY
COST – AND HOW TO CUSHION THE BLOW
TUESDAY, SEPTEMBER 15, 2015 2 PM EASTERN
Presented by:
Anthony Root, Senior Consultant, Reporting & Analytics
Human Capital Practice
As medical science advances toward innovative
treatments for various diseases, the cost of developing
those treatments, especially in the pharmaceutical
industry, are escalating dramatically. New drugs in
the biologic and biosimilar categories are the new
cutting edge treatments for diseases such as cancer,
rheumatoid arthritis, multiple sclerosis, and Crohn’s.
And while they are improving the lives of those
with these diseases, the associated costs are often
significant. For some employers (those who pay a
significant portion of that cost), the increasing cost is
often unexpected.
Since the cost of treating diseases is directly linked to
the health of a population, data and clinical analysis
are critical to identifying potential risk, levels of
appropriate care and drivers of cost. Data analytics are
used to review components of cost and identify the
drivers or outliers that are impacting the overall cost.
This session will take a look at the current
pharmaceutical climate, specifically as it relates to
the impact pharmacy has on an employer’s overall
health care cost. We will review a wide range of topics,
including identifying the pharmacy cost drivers and
strategies for managing pharmacy cost.
During this session, participants will learn:
What’s driving the increasing cost of pharmacy
About health risk and disease burden
How to identify specific cost drivers using
analytics
An overview of specialty drugs
What impact biosimilar drugs have on cost
How to measure the success of implemented
strategies
To RSVP, click here.
NOTE: Advance RSVP is required to participate in
this call. Registration ends 1 hour prior to the call
start time.
Each of the above programs has been approved for 1 recertification hour toward PHR, SPHR and GPHR
recertification through the Human Resource Certification Institute (HRCI). For more information about
certification or recertification, please visit the HRCI homepage at www.hrci.org.
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Willis North America | August 2015
KEY CONTACTS
U.S. HUMAN CAPITAL PRACTICE OFFICE LOCATIONS
NEW ENGLAND
ATLANTIC
Auburn, ME
207 783 2211
Baltimore, MD
410 584 7528
Bangor, ME
207 942 4671
Knoxville, TN
865 588 8101
Boston, MA
617 437 6900
Memphis, TN
901 248 3103
Burlington, VT
802 264 9536
Metro, DC
301 581 4262
Hartford, CT
860 756 7365
Nashville, TN
615 872 3716
Manchester, NH
603 627 9583
Norfolk, VA
757 628 2303
Portland, ME
207 553 2131
Reston, VA
703 435 7078
Shelton, CT
203 924 2994
Richmond, VA
804 527 2343
NORTHEAST
Rockville, MD
301 692 3025
Buffalo, NY
716 856 1100
SOUTHEAST
Morristown, NJ
973 539 1923
Atlanta, GA
404 224 5000
Mt. Laurel, NJ
856 914 4600
Birmingham, AL
205 871 3300
New York, NY
212 915 8802
Charlotte, NC
704 344 4856
Stamford, CT
203 653 2430
Gainesville, FL
352 378 2511
Radnor, PA
610 254 7289
Greenville, SC
864 232 9999
Wilmington, DE
302 397 0171
Jacksonville, FL
904 562 5552
Marietta, GA
770 425 6700
Miami, FL
305 421 6208
Mobile, AL
251 544 0212
Orlando, FL
407 562 2493
Raleigh, NC
704 344 4856
Savannah, GA
912 239 9047
Tallahassee, FL
850 385 3636
Tampa, FL
813 281 2095
Vero Beach, FL
772 469 2843
MIDWEST
Appleton, WI
800 236 3311
Chicago, IL
312 288 7700
Cleveland, OH
216 861 9100
Columbus, OH
614 326 4722
Detroit, MI
248 539 6600
Grand Rapids, MI
616 957 2020
Willis North America | August 2015
8
Milwaukee, WI
262 780 3476
Minneapolis, MN
763 302 7131
763 302 7209
Houston, TX
713 625 1017
713 625 1082
Los Angeles, CA
213 607 6300
McAllen, TX
956 682 9423
Phoenix, AZ
602 787 6235
602 787 6078
Moline, IL
309 764 9666
Mills, WY
307 266 6568
Portland, OR
503 274 6224
Overland Park, KS
913 339 0800
New Orleans, LA
504 581 6151
Pittsburgh, PA
412 645 8506
Oklahoma City, OK
405 232 0651
Schaumburg, IL
847 517 3469
San Antonio, TX
210 979 7470
SOUTH CENTRAL
Wichita, KS
316 263 3211
Irvine, CA
949 885 1200
San Diego, CA
858 678 2000
858 678 2132
San Francisco, CA
415 291 1567
Amarillo, TX
806 376 4761
WESTERN
San Jose, CA
408 436 7000
Austin, TX
512 651 1660
Fresno, CA
559 256 6212
Seattle, WA
800 456 1415
Dallas, TX
972 715 2194
972 715 6272
Irvine, CA
949 885 1200
Denver, CO
303 765 1564
303 773 1373
Las Vegas, NV
602 787 6235
602 787 6078
The information contained in this publication is not intended to represent legal or tax advice and has been prepared solely for
educational purposes. You may wish to consult your attorney or tax adviser regarding issues raised in this publication.
Willis North America Inc.
Brookfield Place
200 Liberty Street, 7th Floor
New York, New York 10281-1003
United States
Tel: +1 212 915 8888
www.willis.com
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Willis North America | August 2015
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