Tuesday, August 23, 2016

Options Limited for Health Insurance in 2017

If you buy individual health insurance (especially via healthcare.gov), your options WILL be limited this upcoming year.

Right now DuPage County (IL) has 4 options. Aetna, BCBS of IL, Coventry, and United Healthcare. BCBS and Coventry have PPO networks. In 2017, you will have BCBS and Cigna only as Aetna, Coventry, and United Healthcare pull out. Cigna will be an HMO. This means the ONLY PPO network available will be the Blue Choice PPO network via BCBS of IL (assuming they continue this plan, which I think they will). If you need a variety of specialists who are not in the same medical group, you will either have to pay out of pocket or change doctors.

Cook County won't be much better. You have 7 options, but 3 will be going away (see above). Harken Health (who currently has the best PPO network) will be changing the network to either a smaller PPO network or HMO (they haven't told me yet). In 2017, you will probably have Ambetter, BCBS of IL, Harken Health, Humana, and newcomer Cigna. The only two that would possibly have a PPO is BCBS of IL and Harken Health (see above).

Downstate will at least have Health Alliance (as of my writing this article) who offers a POS plan (less restrictive than an HMO, but not quite as flexible as a PPO) in addition to BCBS of IL.

BTW, I didn’t mention the premiums. Go to https://ratereview.healthcare.gov/ if you want to see how bad it is going to be.

To help people who can’t afford the cost, I have a new plan that is NOT insurance but is a cost sharing ministry that will be available to those who just can’t afford the new premiums. It avoids the penalty and has some holes, but something is better than going with nothing. If you want more information on this, contact me. The good news is that you can sign up at any time, but it does NOT cover any pre-existing conditions or medications other than generics. View this as a “last resort” plan.

http://www.bloomberg.com/news/articles/2016-08-19/choices-may-be-limited-for-obamacare-shoppers-avalere-says

Thursday, August 4, 2016

IRS Issues Draft Instructions for Forms 1094-C and 1095-C for 2016

IRS Issues Draft Instructions for Forms 1094-C and 1095-C for 2016   

August 4, 2016

By Larry Grudzien, larrygrudzien.com, 708-717-9683

On August 1, 2016, IRS released draft instructions for Forms 1094-C and 1095-C for 2016. The following is an overview of important changes to the forms:

Form 1094-C

On line 22, box B is designated "Reserved." The Qualifying Offer Method Transition Relief is not applicable for 2016.

In Part III, column (b), "Section 4980H" was inserted before "Full-Time Employee Count for ALE Member" to remind filers that the Code Section 4980H definition of "full-time employee" applies for purposes of this column, not any other definition that an ALE Member may use for other purposes.

Form 1095-C:

The language "Do not attach to your tax return. Keep for your records." was inserted under the title of the form to inform the recipient that Form 1095-C should not be submitted with the return.
Changes to codes. Code 1I for line 14, and Code 2I for line 16, are no longer applicable and have been reserved.

New codes 1J and 1K have been added for line 14. These codes are used to reflect conditional offers of coverage to an employee's spouse. A conditional offer is an offer of coverage that is subject to one or more reasonable, objective conditions (for example, an offer to cover an employee's spouse only if the spouse is not eligible for coverage under a group health plan sponsored by another employer.

Multiemployer Plan  Interim Rule Relief:  The use Code 2E for line 14 has been extended to 2016.

Form 1094-C and Form 1095-C:


Transition relief. Several forms of transition relief were available to employers for 2015 under Code Sections 4980H and 6056, but only limited transition relief continues to apply in 2016. References to transition relief that applied only in calendar year 2015 have been removed. Descriptions of the remaining forms of transition relief have been amended to clarify for which months in 2016 the transition relief applies.

New Definition: The term "Employee Required Contribution" has been added.  This  term refers to the employee's share of the monthly cost for the lowest cost self-only minimum essential coverage providing minimum value that is offered to the employee by the ALE Member.

For a copy of the instructions, please click on the link below:



Tuesday, July 5, 2016

Employer Notices From the Marketplace - What to do

Many employers received notices last week about employees who are receiving subsidies on the individual exchange. This matters if you are classified as an ALE "Applicable Large Employer" as penalties may be assessed.


  1. If the employee is receiving a subsidy because you did not offer them coverage, then there is nothing you need to do.
  2. If the employee is receiving a subsidy because you did not offer a plan that met minimum essential coverage or affordability, then there is nothing you need to do.
  3. If you did offer coverage that was affordable and met minimum essential coverage, then you have 90 days within which to appeal.


Here is a link to that form: https://www.healthcare.gov/downloads/marketplace-employer-appeal-form.pdf

If you are an ALE and don't know what I am talking about in the above 3 points, then you ABSOLUTELY need to talk to me, your current broker, or your Employment Attorney.

Below is a newsletter about this from a very good Employment Attorney (if you need one). Larry Grudzien (larry@larrygrudzien.com, 708-717-9638).

From the Desk of Larry Grudzien

What's up with the Notice from the Marketplace?        

July 3, 2016
Last week, many employers received notice from the Marketplace indicating one of their employees was qualified for advance premium tax credits. Many are asking what  is this notice and how should deal with it. The following explains what the notice is and what steps an employer should take.

What is this Notice?

Under Section 1411(e)(4) of the Affordable Care Act, a Marketplace must notify an employer if any of its employees is determined to be eligible for a premium assistance credit (or the cost-sharing subsidy) because the employer does not provide minimal essential coverage through an employer-sponsored plan, or the employer does offer such coverage but it is not affordable.

Under 45 CFR Section 155.310(h), the notice must:

  • identify the employee, providing the minimum necessary personally identifiable information;
  • state that the employee has been determined eligible for advance payments of the premium tax credit, listing the potential reasons for the determination (instead of the actual reason) and without providing tax return information;
  • indicate that, if the employer has 50 or more full-time employees, the employer may be liable under the employer responsibility rules of Code Section 4980H; and
  • notify the employer of its right to appeal the determination.


Under Section 1411(e)(4)(B)(iii) of the Affordable Care Act, a Marketplace must provide this notice regardless of the size of the employer even though the employer mandate penalties only apply to applicable large employers (ALEs).

In addition to the above notice, a Marketplace may also contact the employer to determine whether its employees are enrolled in or are eligible for affordable, minimum value coverage under an eligible employer-sponsored plan, as provided in 45 CFR Section 155.320(d)(3)(iii)(D).

What should an employer do after it receives this notice?

The employer may appeal a determination that an employee is eligible for advance payments of the premium tax credit based in part on a finding that the employer did not offer qualifying coverage to the employee, as provided in 45 CFR Section 155.310(h). While a Marketplace's determination does not itself trigger the employer mandate penalties (those penalties are assessed by the IRS), employers offering coverage that should not result in the receipt of advance payment of premium tax credits may wish to use the appeals process to ensure, as much as possible, that their employees are not mistakenly receiving such payments.

The appeal may be conducted by either a Marketplace or by HHS if a Marketplace has not established an appeals process.

A Marketplace must allow employers to request an appeal within 90 days from the date of the notice from the Marketplace and permit employers to submit relevant evidence to support the appeal, as provided in 45 CFR Section 155.555(c). An employer may request an appeal by completing an appeal request form. Click on link below to obtain a copy of the request form:


An employer may mail or fax an appeal request.

Under 45 CFR Section 155.555, this appeals process must give employers the opportunity to:
  • present information to a Marketplace for review of the determination, including evidence of the employer-sponsored plan and employer contributions to the plan; and
  • have access to the data used to make the determination to the extent allowable by law.

Under 45 CFR Section 155.555(d), once a Marketplace receives a valid appeal request, it must:
  • timely acknowledge the receipt of the request,
  • provide an explanation of the appeals process,
  • inform the employee of the appeal, and
  • provide the employee with instructions for submitting any additional evidence for consideration by the appeals,


Under 45 CFR Section 155.555(i)(3), the standard of this review is a de novo review. A de novo review means a review of an appeal without deference to prior decisions in the matter.

Under 45 CFR Section 155.555(g), as part of the review process, the employer must be given the opportunity to:

  • provide relevant evidence for review of the determination of the employee's eligibility for advance payments of the premium tax credit or cost-sharing reductions;
  • review the information identifying the employee, information regarding whether the employee's income is above or below the threshold by which the affordability of employer-sponsored minimum essential coverage is measured, and other data used to make the determination, to the extent allowable by law.


The Marketplace's decision is required to be provided to both the employer and employee generally within 90 days of the date the appeal request is received, as provided in 45 CFR Section 155.555(k).
If the employer's appeal is successful, a Marketplace will send a notice to the employee encouraging the employee to update his or her Marketplace application to reflect that the employee has access to or is enrolled in other coverage. Under 15 CFR Section 155.555(k), the employee has the right to appeal the decision.

This appeal decision does not foreclose any future appeal rights the employer may have under the Internal Revenue Code for excise tax liabilities. While an appeal of a notice by the Exchange may be beneficial, employers are not necessarily required to make this appeal to preserve their rights against the later potential assessment of Code Section 4980H liability, as provided under 45 CFR Section 155.555(k)(1)(ii).

For a copy of the employer appeals process regulations, please click on the link below:




Thursday, June 16, 2016

Expect More From Your Broker

In today's world, handing a spreadsheet of options to a client misses the key pieces that employers need. Employers need the following along with an "easy button."
1. Help with making sure the benefits strategy fits with your overall business strategy. Let's face it, benefits are expensive. If you are offering benefits to employees (i.e. health, life, dental, vision, retirement plan, telemedicine, voluntary, short term disability, long term disability, and or wellness), you want a return on your investment. Better recruiting, better retention, and happier and healthier employees. Make sure whatever you do can be communicated in a positive way to your employees via either the broker or positive communications. The conversation with your broker should START with where your benefits strategy fits into your overall business strategy.
2. Assistance with the myriad of regulations the government has imposed on your business and definitely help with compliance with the affordable care act. We offer a full HR library up to and including an HR person to answer an employer's most pressing questions. The library is available day or night via computer or phone and is regularly updated and includes sample policies and procedures. We also offer ACA reporting for the 1094 and 1095 forms along with a Wrap Summary Plan Description.
3. Creative strategies to keep the cost of insurance down while still serving the needs of your employees. This includes determining whether your benefits are better or worse than similar companies. It could mean looking at level or self funding options or health reimbursement arrangements on the medical side. Implementing a wellness program in a cost effective way (we have one that will save you money - we can actually put the numbers to it for you). If you are a large self insured company, offering claims data analysis to see where you can save money. We can even offer actuarial support on your benefits plans for larger companies.
4. Ongoing support as needed. A responsive staff to take care of the little stuff and access to your broker for the big stuff. Employee adds, drops, COBRA, etc. can be handled via your broker or the systems they set up for you.
5. Ongoing reviews. Touching base at least quarterly to make sure we are serving you the best that we can.
6. Taking care of your employees like they are our own. We can come in (or provide webinars) and do financial lunch and learns, arrange talks from the American Cancer Society or American Diabetes Association, and other organizations as it fits the needs of your population.
In short, expect more from your broker. You will thank yourself for it.

Monday, October 12, 2015

Predicting Health Insurance Rates for 2016 in Illinois

Predicting Health Insurance Rates for 2016 in Illinois

By Robert Slayton

One good thing that came out of the Affordable Care Act is that any insurance company that is going to raise premiums more than 10 percent for individual or small group medical plans is required to file with the Federal Government. This information is made public so we can review it.
Unlike other states, Illinois has no authority to prevent the increases from being implemented as requested (this isn’t necessarily a bad thing, but just the way it is in Illinois). Based upon those rate increase requests, we have a pretty good idea of who will be the competitive players in the market for 2016.

BCBS of IL has requested increases from 12.83% to 38.24% for ACA plans. As a result, BCBS of IL is eliminating the Blue PPO (large PPO network) option in 2016 for ACA plans. All members on this plan will be migrated to the smaller Blue Choice network (which has about 40% of the doctors/hospitals as the larger network). This will impact approximately 173,000 people. Also expect BCBS to eliminate other plans that have been unprofitable.

If you are on a transitional plan, (plans written after 3/23/2010 to 12/31/2014) you may see increases of over 46%.

Coventry, Humana, and Health Alliance have also requested increases. If you look at the table below, it shows, generally, which increase impacts which plan. If you are on a subsidized plan, you will not see as dramatic of an increase if your income has stayed the same. Subsidies are based upon the second lowest silver plan. The assumption is that this plan will be more expensive in 2016 therefore providing you with a bigger subsidy. For everyone else, it will be a choice of paying the increase or keeping cable.

Aetna (who owns Coventry), Land of Lincoln Health, and IlliniCare are not listed as requesting a rate increase even though I’ve heard rumblings that some have. If we go with the assumption that they will increase rates less than 10%, then these will be some of the players who will win business away from BCBS.

One unknown is Land of Lincoln Health. I’ve had conversations with a board member who says the financials look good (doesn’t mean that they made a profit as it is difficult for any start up to make a profit in the first several years). If they continue to perform as they have, I’d say they will be the company most move to.

Expect all insurance companies to modify the plans they offer. We probably won’t know what these will look like until open enrollment begins on 11/1.

Below are the rates increase requests for ACA compliant plans.




For Transitional plans, here’s the rate table.


Monday, August 10, 2015

IRS Issues Draft Instructions for Forms 1094-C and 1095-C for 2015

IRS Issues Draft Instructions for Forms 1094-C and 1095-C for 2015

Below was written by Larry Grudzien. In my opinion, it is best to have someone help with these filings for this year. Most payroll companies will do it (if you sign up by September/October timeframe). There are also a number of companies who will help (I have 5 on my desk that will do it). If you want help, let me know and I can direct you to an appropriate service. You can also rely on Larry's expertise in this matter.


By Larry Grudzien, Attorney-At-Law
708-717-9638, larry [at] larrygruidzien [dot] com                  
August 9, 2015
On August 6, 2015, IRS released draft instructions for Forms 1094-C and 1095-C for 2015. The following is an overview of important provisions to consider in the completion of the forms:

 1. Who Must File:

 If an employer is offering health coverage to employees other than under a self-insured plan, such as through an insured health plan or a multiemployer health plan, the issuer of the insurance or the sponsor of the plan providing the coverage is required to furnish the information about their health coverage to any enrolled employees, and the employer should not complete Form 1095-C, Part III for those employees.

 2. One Form 1095-C for Each Employee of Each Employer:

 For each full-time employee of an employer, there must be only one Form 1095-C filed for employment with that employer. For example, if an employer separately reports for each of its two divisions, the employer must combine the offer and coverage information for any employee who worked at both divisions during the calendar year so that a single Form 1095-C is filed for the calendar year for that employee which reports information for all twelve months of the calendar year from that employer.
 In contrast, a full-time employee who works for more than one employer that is a member of the same Aggregated ALE Group (that is, works for two separate ALE Members) must receive a separate Form 1095-C from each employer, unless the ALE Member is not treated as the employer for any calendar month in the calendar year as described later.
 For any calendar month in which a full-time employee works for more than one ALE Member of an Aggregated ALE Group, only one ALE Member is treated as the employer and only that ALE Member reports for that employee for that calendar month (and the other ALE Member is not required to report for that employee for that calendar month). If under these rules, an ALE member is not required to report for an employee for any month in the calendar year, the employer is not required to report for that full-time employee for that calendar year.

 3.   Form 1094-C, Column (c) Total Employee Count for ALE member:

 An employer must choose to use one of the following days of the month to determine the number of employees per month and must use that day for all months of the year: (1) the first day of each month; (2) the last day of each month; (3) the first day of the first payroll period that starts during each month; or (4) the last day of the first payroll period that starts during each month (provided that for each month that last day falls within the calendar month in which the payroll period starts). If the total number of employees was the same for every month of the entire calendar year, enter that number in line 23, column (c) "All 12 Months" or in the boxes for each month of the calendar year. If the number of employees for any month is zero, enter 0.

 4.  Form 1095-C,  line 14:

 An employer offers health coverage for a month only if it offers health coverage that would provide coverage for every day of that calendar month. Thus, if an employee terminates  coverage before the last day of the month, the employee does not actually have an offer of coverage for that month. See Line 16, code 2B later for how the employer may complete  Line 16 in the event an employee terminates coverage before the last day of the month.

 5.   Form 1095-C, line 14:

 For reporting offers of coverage for 2015, an employer relying on the multiemployer arrangement interim guidance should enter code 1H on line 14 for any month for which the employer enters code 2E on line 16 (indicating that the employer was required to contribute to a multiemployer plan on behalf of the employee for that month and therefore is eligible for multiemployer interim rule relief). For reporting for 2015, Code 1H may be entered without regard to whether the employee was eligible to enroll in coverage under the multiemployer plan. For 2016 and future years, reporting for offers of coverage made through a multiemployer plan may be reported in a different manner.

 6.  Form 1095-C, Line 14:

 An offer of COBRA continuation coverage that is made to a former employee upon termination of employment is reported as an offer of coverage using the appropriate indicator code on line 14 only if the former employee enrolls in the coverage. If the former employee does not enroll in the coverage (even if a spouse or dependent of the former employee independently enrolls in the coverage), code 1H (No offer of coverage) should be entered for any month for which the offer of COBRA continuation coverage applies.
 An offer of COBRA continuation coverage that is made to an active employee (for instance, an offer of COBRA continuation coverage that is made due to a reduction in the employee's  hours that resulted in the employee no longer being eligible for coverage under a plan) is reported in the same manner and using the same code as an offer of that type of coverage to any other active employee.

 7.   Form 1095-C, Line 16:

 If an employee is in an initial measurement period, enter code 2D (employee in a section 4980H(b) Limited Non-Assessment Period) for the month, and not code 2B (employee not a full-time employee). For an employee in a section 4980H(b) Limited Non-Assessment Period for whom the employer is also eligible for the multiemployer interim rule relief for the month code 2E, enter code 2E (multiemployer interim rule relief) and not code 2D (employee in a Limited Non Assessment period.

 8.   Form 1095-C, Line 16:

 Enter code 2E for any month for which the multiemployer interim guidance applies for that employee. Under the interim guidance regarding multiemployer arrangements,  an employer is treated as offering health coverage to an employee if the employer is required by a collective bargaining agreement or related participation agreement to make contributions for that employee to a multiemployer plan that offers, to individuals who satisfy the plan's eligibility conditions, health coverage that is affordable and provides minimum value, and that also offers health coverage to those individuals' dependents or is eligible for the section 4980H transition relief regarding offers of coverage to dependents.
 Codes 2F through 2H: Although employers may use the section 4980H affordability safe harbors to determine affordability for purposes of the multiemployer interim guidance, an employer eligible for the relief provided in the multiemployer interim guidance for a month for an employee should enter code 2E (multiemployer interim rule relief), and not a code for the section 4980H affordability safe harbors (codes 2F, 2G, or 2H).

 9.   Form 1095-C, Part III:

 If two or more employees employed by the same employer are spouses or employee and dependent, and one employee enrolled in a coverage option under the plan that also covered the other employee(s) (for example, one employee spouse enrolled in family coverage that provided coverage to the other employee spouse and their employee dependent child), the enrollment information should be reflected only on the Form 1095-C for the employee who enrolled in the coverage (but would report the other employee family members as covered individuals.

 10.  Form 1095-C, Part III:

 This part may be completed by an employer offering self-insured health coverage for any other individual who enrolled in the coverage under the plan for one or more calendar months of the year but was not an employee for any calendar month of the year, such as a non-employee director, a retired employee who retired in a previous year, a terminated employee receiving COBRA continuation coverage who terminated employment during a previous year, and a non-employee COBRA beneficiary (but not including an individual who obtained coverage through the employee's enrollment, such as a spouse or dependent obtaining coverage when an employee elects COBRA continuation coverage that is family coverage). If the Form 1095-C is used with respect to an individual who was not an employee for any month of the calendar year, Part II must be completed by using Code 1G in the "All 12 Months" box or the box for each month of the calendar year

 11.    Employee, Definition:

 For this purpose, an employee is an individual who is an employee under the common-law standard for determining employer-employee relationships. An employee does not include a sole proprietor, a partner in a partnership, an S corporation shareholder who owns at least 2-percent of the S corporation, a leased employee within the meaning of section 414(n) of the Code, or a worker that is a qualified real estate agent or direct seller. If an employee is an employee of more than one employer of the same Aggregated ALE Group during a calendar month, the employee is treated as an employee of the employer for whom the employee has the greatest number of hours of service for that calendar month; if the employee has an equal number of hours of service for two or more employers of the same Aggregated ALE Group for the calendar month, those employers must treat one of the employers as the employer of that employee for that calendar month.

 12.    Limited Non-Assessment Period, Definition:

 A Limited Non-Assessment Period generally refers to a period during which an ALE Member  will not be subject to an assessable payment under section 4980H(a), and in certain cases section 4980H(b), for a full-time employee, regardless of whether that employee is offered health coverage during that period.
 The first five periods described below are Limited Non-Assessment Periods only if the employee is offered health coverage by the first day of the first month following the end of the period, and are Limited Non-Assessment Periods for section 4980H(b) only if the health coverage that is offered at the end of the period provides minimum value.
 First Year as ALE Period. January through March of the first calendar year in which an employer is an ALE, but only for an employee who was not offered health coverage by the employer at any point during the prior calendar year. For this purpose, 2015 is not the first year an employer is an ALE, if that employer was an ALE in 2014 (notwithstanding that transition relief provides that no employer shared responsibility payments under section 4980H will apply for 2014 for any employer).
 Waiting Period under the Monthly Measurement Method. If an employer is using the monthly measurement method to determine whether an employee is a full-time employee, the period beginning with the first full calendar month in which the employee is first otherwise (but for completion of the waiting period) eligible for an offer of health coverage and ending no later than two full calendar months after the end of that first calendar month.
 Waiting Period under the Look-Back Measurement Method. If an employer is using the look-back measurement method to determine whether an employee is a full-time employee and the employee is reasonably expected to be a full-time employee at his or her start date, the period beginning on the employee's start date and ending not later than the end of the employee's third full calendar month of employment.
 Initial Measurement Period and Associated Administrative Period under the Look-Back Measurement Method. If an employer is using the look-back measurement method to determine whether a new employee is a full-time employee, and the employee is a variable hour employee, seasonal employee or part-time employee, the initial measurement period for that employee and the administrative period immediately following the end of that initial measurement period.
 Period Following Change in Status that Occurs During Initial Measurement Period Under the Look-Back Measurement Method. If an employer is using the look-back measurement method to determine whether a new employee is a full-time employee, and, as of the employee's start date, the employee is a variable hour employee, seasonal employee or part-time employee, but, during the initial measurement period, the employee has a change in employment status such that, if the employee had begun employment in the new position or status, the employee would have reasonably been expected to be a full-time employee, the period beginning on the date of the employee's change in employment status and ending not later than the end of the third full calendar month following the change in employment status. If the employee is a full-time employee based on the initial measurement period and the associated stability period starts sooner than the end of the third full calendar month following the change in employment status, this Limited Non-Assessment Period ends on the day before the first day of that associated stability period.
 First Calendar Month of Employment. If the employee's first day of employment is a day other than the first day of the calendar month, then the employee's first calendar month of employment is a Limited Non-Assessment Period.

 13.   Offer of Health Coverage, Definition

 An employer makes an offer of coverage to an employee if it provides the employee an effective opportunity to enroll in the health coverage (or to decline that coverage) at least once for each plan year. An employer makes an offer of health coverage to an employee for the plan year if it continues the employee's election of coverage from a prior year but provides the employee an effective opportunity to opt out of the health coverage. If an employer provides health coverage to an employee but does not provide the employee an effective opportunity to decline the coverage, the employer is treated as having made an offer of health coverage to the employee only if that health coverage provides minimum value and does not require an employee contribution for the coverage for any calendar month of more than 9.5 percent of a monthly amount determined as the mainland federal poverty line for a single individual for the applicable calendar year, divided by 12.
 For purposes of reporting, an offer to a spouse includes an offer to a spouse that is subject to a reasonable, objective condition, regardless of whether the spouse meets the reasonable, objective condition. For example, an offer of coverage that is available to a spouse only if the spouse certifies that the spouse does not have access to health coverage from another employer is treated as an offer of coverage to the spouse for reporting purposes. Note that this treatment is for reporting purposes only, and generally will not affect the spouse's eligibility for the premium tax credit if the spouse did not meet the condition and therefore did not have an actual offer of coverage.
 An employer offers health coverage for a month only if it offers health coverage that would provide coverage for every day of that calendar month. For reporting purposes, this means that an offer of coverage does not occur for a month if an employee's employment terminates before the last day of a calendar month and the health coverage also ends before the last day of that calendar month (or for an employee who did not enroll in coverage, the coverage would have ended if the employee had enrolled in coverage).
 An employer offers health coverage to an employee if it, or another employer in the Aggregated ALE Group, or a third party such as a multiemployer or single employer Taft-Hartley plan, a multiple employer welfare arrangement (MEWA), or, in certain cases, a staffing firm, offers health coverage on behalf of the employer.
 For a copy of the instructions, please click on the link below: