Benefits Analysis PART I: Exposure Matrix PART II: Inventory of Benefits PART III: Benefits Plan Design Analysis

DREW SCHLOSSER & DAKOTA PLOURDE 912080225 & 912167259 RMI 3501 Dr. Drennan Fall 2011

Page |1

Part I - Benefits Matrix

Exposure Analysis for Kloter Farms Loss Exposure Provided Coverage/Benefits Provided

Loss of Income: Medical Expenses Overall Medical Expenses Dental Vision Prescription Long Term Care Retiree Health Care Loss of Income: Death Non-Accidental & NonOccupational Accidental Occupational Loss of Income: Unemployment Unemployment Loss of Income: Disability Non-Occupational: Short-Term Non-Occupational: Long-Term Yes Yes OASDI, Sick Time OASDI Yes Unemployment Insurance Yes Yes Yes OASDI, The Hartford: Basic Life OASDI, The Hartford: Basic Life, AD&D OASDI, The Hartford: Basic Life, AD&D Yes No No Yes No Yes Aetna: POS, Health Care FSA Coming 2012 N/A Aetna: POS (included drug plan), Health Care FSA N/A COBRA, Medicare

Page |2

Occupational: Short-Term Occupational: Long-Term Loss of Income: Retirement Retirement Other Exposures Educational Assistance Work/Life Exposures Dependent Care Property-Liability Legal Expenses

Yes Yes

OASDI, Workers Compensation OASDI, Workers Compensation

Yes

401(k), Profit Sharing, OASDI

Yes Yes Yes No No

Tuition Reimbursement Employee Discount, Paid Holidays, Paid Vacation Dependent Day Care FSA N/A N/A

Part II: Inventory of Benefits

Medical Expenses Point-of-Service Plan (POS) Kloter Farms offers a quality-point-of-service (QPOS) HMO plan to its full-time, active employees through Aetna Insurance Company. According to the employee handbook distributed by Kloter Farms, full-time employees are defined as those who work 2,000 or more hours in a calendar year. In order for these full-time employees to be considered active, eligible participants, each employee must incur a 30-day waiting period upon employment; additionally, employees will not receive coverage until the first day of the following month after the completion of the 30-day waiting period. For

Page |3

example, if an employee is hired on the fifth of March, and chooses to participate in Kloter Farms QPOS HMO, that individual will not begin to receive benefits until the first of May. Dependents of these full-time, active employees are eligible for Aetnas medical QPOS HMO plan as well, and are defined as:

o o o

Legally married spouse Domestic partner Children (married or unmarried) residing with the employee up to age 19

Including adopted children Including stepchildren Including children who are legally specified as under the care of the employee (example: godchildren)

Unmarried children under age 25 who are enrolled full time at universities or specified institutions of higher learning

Kloter Farms offers two types of this QPOS HMO that are compatible with a health savings account (HSA) to their employees: (1) a basic option of the HMO through Aetna, and (2) advanced option of the HMO through Aetna. Aetna of Connecticut has received an AM Best rating of A (excellent). Kloter Farms contributes 95% of the cost of the basic health plan. If an employee desires one of the richer plans, he or she must cover the additional cost. Both QPOS HMOs are very similar, except for the amount of coverage each policy pays out. A key difference between the two is the amount covered in the deductible. The basic plan is more affordable regarding total premium costs, however it comes with a larger deductible. For both the basic and advanced

Page |4

POS plans, different deductibles are assessed based on in-network and out-of-network utilization. The plans are open-network plans, but assess a higher deductible for out of network use as a minor penalty. Listed below are the differentials in deductibles amongst each option: AETNA POS HMO Basic QPOS HMO Participating Providers Individual: $4,500 Family: $9,000 Advanced QPOS HMO Individual: $2,500 Family: $5,000 Non-Participating Providers Individual: $6,000 Family: $12,000 Individual: $5,000 Family: $10,000

Point-of-Service Plan without HSA Kloter Farms also offers a similar QPOS HMO without a HSA that has a lower deductible than previous options. The plan is insured and administered by Aetna which has an AM Best rating of A (excellent). All full-time salaried employees and their dependents are eligible. Dependents are defined as spouses, domestic partners, and children up to the age of 19 (25 if full-time student). It is available on a contributory basis where Kloter Farm pays 95% of the base medical plan and the employee pays the remainder. As previously stated, the deductible for this plan is significantly lower: $2,000 Individual, $4,000 Family (if a Participating Provider is used).

Flexible Spending Account (FSA) Kloter Farms self-insures two types of FSAs: Health Care and Dependent Day

Page |5

Care. All full-time employees are eligible to enroll in FSAs which go into effect January 1st of the year following employment. Both FSAs are self-funded and administered using MyBenny. They are funded up front by Kloter and implemented through weekly, pre-tax payroll deductions. The maximum amount employees contribute to a FSA for 2011 is $5,000. The Health Care FSA can be used for payment of deductibles, copayments, prescriptions, etc. It cannot be used for over the counter medicine. The Dependent Day Care FSA can be used to pay for day care services for full-time employees dependent children.

Prescription Drug Plan A prescription drug plan is included in all of the overall medical plans offered by Kloter Farms. As previously noted, all of these plans are provided by Aetna which receives an AM Best rating of A (excellent). All three options are closed panel plans regarding pharmacy and prescription drug coverage, meaning they offer no coverage for out-of-network services. In other words, there are no indemnity benefits for the employee, since the plan is not open panel. The point-of-service option without a HSA includes no deductible for in-network utilization; however, there is a 3-tier fixed copayment system based on quality level of coverage. By pricing each co-payment required by the participating employee at different levels (for different levels of coverage), steerage is implemented by the insurer. In the case of the three plans offered by Aetna, steerage is invoked in each plans co-pay. This co-payment system also encourages the Hesitation Effect, which is great for the insurer when dealing with cost containment. The Hesitation Effect involves prescriptions not being filled due to

Page |6

tiers of cost options; for example, some employees covered under this plan may opt for a cheaper, generic brand of the same prescription, or even a smaller quantity. Since all three plan options do not offer coverage for out-of-network service, the co-payment system is only used for participating pharmacies in-network: 1. POS without HSA Benefit Type Participating NonParticipating Generic Formulary Brand Name Formulary Generic and Brand Name NonFormulary Lifestyle Prescription Drugs 20% of Total Cost copay Not Covered $10 co-pay $25 co-pay $40 co-pay Not Covered Not Covered Not Covered

For both the basic and advanced POS HMO (with a HSA) prescription drug coverages, the same co-pays are assessed regarding price; however, the key difference from the POS without an HSA is the existence of a deductible. In addition to the co-pay, the overall aggregate deductible (listed in the deductible chart above) must be exhausted before coverage begins.

Page |7

Loss of Income: Death Life Insurance Kloter Farms Inc. offers its employees a life insurance policy through The Hartford Life and Accident Insurance Company. The schedule of insurance for Kloter Farms employees includes two parts: (1) basic life insurance coverage, and (2) basic AD&D benefits. The purpose of the schedule specified in the plan controls three aspects:

1. Benefit amounts and maximum limits 2. Eligibility and effective date requirements 3. Additional schedule amounts and limits

These schedule specifications apply to all employees covered by the policy, and are presented to each individual covered. Eligible participants (employees as well as their dependents) are expected to pay a monthly premium on the first of each month; if an employee fails to pay the premium, a 31-day grace period is implemented by The Hartford Insurance Company, as specified. If an employee fails to pay the premium on the thirty second day past due, the policy automatically terminates and coverage is suspended. Premium rates are set for all eligible employees at an equal rate in order to pass discrimination testing required by insurance regulation. The premium for Kloter Farms basic life insurance policy is $0.20 per month per $1,000 dollars of coverage for each individual. For the basic AD&D benefits coverage, a $0.02 charge per employee per month is assessed per $1,000 of coverage. Additionally, every Kloter Farms employee that has health insurance through the company receives an automatic

Page |8

$10,000 in life insurance coverage, non-optional. This coverage costs two dollars a month per employee, which is paid for by Kloter Farms; therefore, it is essentially free to each employee and contains a minimal cost for Kloter Farms.

Retirement Kloter Farms contribution to employees 401(k) plans is based on profit sharing. It becomes available to employees on January 1st or July 1st of their second year of full-time employment. The employee must then maintain 1,000 hours of service yearly to sustain eligibility. All employee contributions to their personal 401(k) are 100% vested. Kloters contributions are vested after six years of service to the company and vary from year to year. The past three years it has contributed 10% of the employees pay. The previous fourteen years Kloter had contributed the maximum 15%. The amount an employee can contribute is based on the amount Kloter contributes via profit sharing and the maximum set by the IRS. In 2011, the limit is $16,500 and in 2012 it will be raised to $17,000 (irs.gov).

Other Exposures Tuition Reimbursement Tuition and professional training reimbursement is offered by Kloter Farms on a case-by-case basis. The company is willing to fully reimburse any educational expenses of an employee as long as it pertains directly to the employees position with the company and is applicable. Kloter self-insures this benefit and the qualifications are determined by the owners as they see fit.

Page |9

Employee Discount Employee discounts on Kloter Farms products are based on the number of years the employee has been with the company. The discounts are as follows:

0-1 years of service 25% 2-5 years of service 30% 6-10 years of service 35% 11+ years of service 40%

This discount is extended to the employees spouse and other immediate family members of employees receive a discount of 25%. The discount cannot apply to gift certificates and there is a maximum discount of 25% on all sheds and gazebos.

Paid Holidays All full-time and half-time employees (1,000-1,999 hours per year) receive seven paid holidays per year. Holiday pay is defined as eight hours for full-time employees and six hours for half-time employees and is a self-funded benefit provided by Kloter. If the holiday occurs on a non-working day salaried employees receive a floating paid day off. Salaried employees will also receive an additional paid day off if they work on a paid holiday (e.g. Labor Day). Hourly-employees that work on a paid holiday are compensated for their time and also receive holiday pay. The holidays are: New Years Day, Memorial Day, Christmas Day, Thanksgiving Day, Fourth of July, Labor Day, and the June Company Picnic (if attending).

P a g e | 10

Sick Time Kloter Farms provides five sick days per year to all full-time and half-time employees. Sick days can be utilized for an employees personal injury/illness or to tend to illness/injury of a family member. The sick pay is self-funded by Kloter and is accrued by calendar year. Sick time that is not used during the calendar year can be carried forwarded to the next year, up to a maximum of 20 sick days. It should be noted that Kloter Farms reserves the right to require medical documentation when an employee uses sick time.

Vacation Time Paid vacation time is granted to all full-time and part-time employees and is selffunded by Kloter Farms. All vacation time is accrued by calendar year and any unused time is forfeited on the January 1st when the balance is renewed. Vacation time must be taken in increments of four hours and any employee with more than one year of service with the company will be paid for any unused vacation time when their employment ends. A new, full-time employee who is employed with Kloter after January 1st receives vacation time on a pro-rated schedule indicated below: Schedule for first partial calendar year: Length of Service 90 days 150 days 210 days Number of hours

8 hours 16 hours 24 hours

P a g e | 11

270 days 330 days

32 hours 40 hours

The following years are scheduled as such: Length of Service First full calendar year 3 to 5 years 6 to 10 years 11+ years Number of hours 40 hours

80 hours 120 hours 160 hours

Half-time employees do not receive vacation time until their second year of employment. Vacation time is then calculated by dividing the total number of hours worked in the previous calendar year by 50. After five years of service, vacation benefits are doubled.

Part III - Decision Making and Benefits Plan Design Analysis

Introduction Kloter Farms is located in Ellington, Connecticut and has been in business since 1980. It sells and maintains sheds, gazebos, and home furnishing that are handmade by the Amish of Pennsylvania. There are currently twenty-seven employees enrolled in Kloters benefits plan with forty-nine dependents, totaling seventy-six covered lives.

P a g e | 12

Our primary contact and interviewee was Peter Welti, who has been president of Kloter Farms for one year. Mr. Welti works directly with the companys benefits consultant, John Zawadski of Health Consultants Group, and is in charge of making a majority of the benefits decisions. In order to better understand the design and goals of Kloter Farms employee benefits package, we opened our interview with Mr. Welti by asking him why Kloter Farms provides an employee benefits package. His response was as we expected to attract and retain valuable and capable employees.

Overall Design Considerations of Employee Benefits Goals When implementing a benefits plan, the decision maker must establish criteria in order to offer an effective package that satisfies the employee and appeals to the employer. Peter Welti cites three key goals when determining benefit implementations or alterations:

1. Overall cost to Kloter Farms 2. Overall cost to employees 3. Overall benefits provided

The overall cost to Kloter Farms is an important factor in regards to benefit planning because overspending can lead to issues surrounding financial business capacity and overall firm solvency. Recent modifications to the health care plan has allowed Kloter Farms to continue financing a majority of the base plan it offers its employees; otherwise, Kloter Farms would not have been able to bear the rising costs of its former plan. When considering costs to employees, factors such as co-payments, cost sharing, deductibles,

P a g e | 13

and employee contributions must all be taken in to account. At the same time, the quality and reliability of the benefits plan must be addressed. A balance encompassing these three conditions will result in an affective and sustainable benefits plan.

Demographics Being an extremely family oriented company, Kloter Farm considers dependent coverage a top priority. Previously, the company considered the implementation of a dental plan for covered employees and dependents; however, due to the high cost considerations and limited number of children covered as dependents, Kloter Farms rejected adding this coverage. In our initial analysis of Kloter Farms benefits package, we observed that a majority of the plans benefits pertained only to full-time employees. Prior to our interview with Mr. Welti, we assumed that this was intentionally done to discourage part-time employment; contrarily, Mr. Welti informed us that this was done to reduce the total number of employees covered under the benefits plan. Additionally, part-time employees at Kloter Farms receive a higher hourly rate to compensate the lack of available benefits.

Funding and Financing Decisions Kloter Farms is selective in choosing which areas of benefits to self-fund, and which areas to finance through a third party. It chooses to fully insure any risk that can lead to a catastrophic loss for employees, such as health care, life insurance, and accidental death and dismemberment (AD&D) coverage. All of these areas represent risk that Kloter Farms could not possibly self-insure because of the potential they have to incur astronomical

P a g e | 14

losses. For a company of its size, these losses could undoubtedly threaten Kloters solvency. On the other hand, like most companies, Kloter Farms self-insures a majority of its benefits that are low risk or have set nominal costs. The company elects to self-insure: sick time, vacation, holidays, tuition reimbursement, and 401(k) contributions. All of these benefits are either low risk or set amounts which Kloter Farms can easily plan for in advance. In the case of 401(k) contributions, which are offered on a profit sharing basis, the amount Kloter contributes is adjustable yearly. In this regard, 401(k) contributions can never directly threaten the companys financial standing.

Issues and Considerations in the Design of Health Benefits History For the majority of Kloter Farms existence, the firm provided its employees with plans that offered first dollar coverage. These cash benefits required no deductible and had a minor co-pay of ten dollars for doctor visits and fifteen dollars for prescription drugs. According to Peter Welti, most employees were satisfied with these health benefits provided by the company; however, by 2006, premiums for these plans were increasing extremely rapidly. Kloter Farms opted instead to offer its employees and their dependents a choice of POS HMO plans through Aetna. This decision was based on the recommendation of Kloters benefits consultant at the time. These POS HMO plans are consumer directed health plans (CDHP) that have high deductibles and are compatible with a health savings account (HSA). The two specific reasons Kloter Farms president and insurance broker chose to offer these health options are: (1) Kloter Farms former heath care plan became too costly and (2) the POS HMO options will remain steadily containable

P a g e | 15

and cost efficient for both employees and Kloter Farms over time (Welti). Mr. Welti explained that, without switching to a CDHP, Kloter Farms would not be able to continue contributing 95% of the cost for the employees base health plan. If they had not changed coverage, the previous plan would now cost double what it did in 2006 (Welti).

Cost Containment Marginal cost versus marginal benefits is a very important factor when selecting a cost-efficient health care plan. Mr. Welti stresses the significance of overall cost to Kloter Farms employees and their dependents as well as the marginal cost to the firm. Three methods Kloter Farms plan practices in order to reduce costs are offering employees a high deductible plan option, using coinsurance, and requiring employees to make co-payments for service benefits. These methods force employees to act as responsible consumers when utilizing health care because they are forced to weigh the benefits they receive against the true cost (NBGH). The base POS HMO option with a HSA includes a high deductible of $4,500-$6,000 for individual plans and $9,000-$12,000 for family plans depending on in network or out of network utilization. This large deductible offers employees a lower annual premium, but does not offer coverage until the deductible is met. A second cost saving method exercised by Kloter Farms is coinsurance for out of network care by employees; in network treatment requires no coinsurance paid by the employee, but out of network utilization comes with a 30% co-insurance stipulation. The new CDHP also attempts to contain cost by requiring higher co-payments than the previous plan. The co-payments can range from $10-$150 depending on services required and network utilization. Co-payments, high deductibles, and coinsurance all help subsidize Kloter Farms overall costs for health benefits.

P a g e | 16

One would expect these changes would create some animosity from employees towards the company but Mr. Welti assured us that this was not the case. He went on to clarify that the bulk of Kloters covered employees simply choose the plan that costs them the least. The fact that the company was able to continue providing a contribution of 95% was enough to keep the majority of covered employees content. He also noted that he does not believe a majority of employees truly understand their health plan until it becomes needed. This indicates that communication of all benefits could use serious improvement.

Dental In the upcoming year, Kloter Farms plans to add dental to its health benefits plan. We previously indicated that the company had rejected the idea in the past but due to increased demand by employees, Kloter has decided to begin offering the coverage. Although the company will not be able to make any contributions to this coverage, dental will be available on an employee-pay-all basis beginning in 2012.

Issues and Considerations in the Design of Non-Health Benefits Communication As previously expressed, Kloter Farms communication could use improvement. Mr. Welti noted that a majority of the companys employees do not fully understand their benefits plan until they personally need it. Kloters communication is outsourced through the companys benefits consultant, John Zawadski. Mr. Zawadski works for the firm, Health Consultants Group, and handles the majority of Kloter Farms benefits communication and assists in the design. Kloter Farms does not have a Summary Plan Description (SPD) or similar communication devise. Instead, Mr. Zawadski meets with the employees annually

P a g e | 17

during the companys enrollment period. He convenes one-on-one with each employee and discusses their options thoroughly to find the best set of benefits particular to their individual needs. He also addresses any questions or concerns they may have. Although Kloter Farms has had very few issues or complaints regarding the companys benefits package, Mr. Zawadski is available year round to handle any problems that may arise. The few complications Kloter Farms employees have had were in regard to co-payments. The issue was absolved by Mr. Zawadski who contacted the insurance company and clarified the misunderstanding between the two parties.

Short-Term and Long-Term Disability In addition to the dental plan previously mentioned, Kloter Farms is also installing short-term and long-term disability coverage in its benefits offering for the coming year. These disability options will be accessible on an employee-pay-all basis via weekly payroll deductions. Kloter is providing five or six different plans for its employees to choose from, depending on their unique needs and desires. The decision to begin offering disability and dental was a result of an employee survey conducted by Kloter Farms. The survey asked employees which areas of their benefits plan they would like improved and if there were any desired coverages not being provided. They found that dental and disability coverage were the two areas most requested. Although Kloter does not currently have the ability to contribute to these coverages, it is able to make both available to all of its employees.

P a g e | 18

Regulatory Compliance ERISA Fiduciary responsibility, discrimination testing, and plan communication are all requirements Kloter Farms must address under ERISA (Cogan). Discrimination is easily handled by only contributing a set amount 95% of the base health plans cost. If an employee wished to have a richer health plan, they are required to cover the additional cost on their own. This design means that Kloter Farms does not discriminate by offering the same amount of contribution to all employees for any plan. It also offers a set amount of life insurance ($10,000) to all covered employees. By offering an HMO POS plan, Kloter Farms takes care of its fiduciary responsibility. Although it has switched to a CDHP, employees still have the freedom to choose any provider they wish by deciding to stay in network or go out of network. The communication of the plan is handled by holding an annual meeting with Koters employees as well as one-on-one meetings with the companys consultant.

PPACA Under PPACA, Kloter Farms misses eligibility for the small business health insurance tax credit by only two covered lives. In order to qualify for the tax credit, the employer must have fewer than twenty-five covered employees, pay at least 50% of employees health insurance cost, and have an average salary of less than $50,000 (Peterson). Kloter Farms fulfills all of these except for having twenty-seven covered employees. The tax credit would be equal to 35% of the employers contribution to health insurance (Peterson). Kloter Farms FSAs will be affected by PPACA in the coming years. Starting in 2013, the maximum amount an employee can deposit in an FSA will be reduced to

P a g e | 19

$2,500. Currently, the maximum is set at $5,000.

Future Recommendations Kloter Farms offers its employees and their dependents a broad, comprehensive spectrum of coverage and benefits. Although they offer a variety of benefits ranging from necessary coverage options (health care) to life cycle benefits such as HSA options and paid time off, there are a few gaps that Kloter Farms can address to further improve the system that is already in place. The two areas of improvement encompass plan communication and staff adjustments.

Communication Improvements One advantage to administering a benefit plan to a smaller firm is the ease of administrative burden. For example, communicating a plan to a company with twenty employees will be significantly less difficult for administration than a company that has over a thousand employees. Kloter Farms does a great job communicating plan enrollment periods, changes to the benefits package, and options employees and their dependents have; they even hold a mandatory annual meeting to make sure every employee knows exactly what options they have in order to eliminate any discrepancies. Since Kloter has just twenty-seven employees (and forty-nine dependents), it is not detrimental to the companys output to hold this annual meeting during work, and saves the administration time. Additionally, Kloter Farms personal consultant, John Zawadski (Penn Field Consultants), sits down with each individual employee, one-on-one, who opts for coverage. This is very effective, but to even further improve efficiency and overall plan effectiveness, Kloter Farms should consider drafting a written summary plan description

P a g e | 20

(SPD), so employees can receive a copy of the plan offerings in writing. This SPD should be distributed at work to each employee, as well as made available online for employees to view at any time. This way, employees can always access information regarding enrollment period dates and see exactly what Kloter Farms offers in terms of coverage and benefits. Along with offering a SPD, it is important for the companys broker and plan administrators to notify all employees of any changes to the SPD, whether employees are covered or not. By giving each employee a copy of the SPD in addition to the annual communications meeting, plan participation may increase, and at the very least employees will be better informed of what Kloter Farms offers its employees in terms of coverage and benefits.

Administration Suggestions In addition to distributing a Summary Plan Description to employees, Kloter Farms can further benefit its organization and benefits administration by hiring a risk manager. When we spoke with Peter Welti initially, he told us he would contact the companys broker for additional information we were seeking. After three days, the broker had still not responded with the requested information; furthermore, Mr. Welti was initially uncertain of how his own benefits worked until he actually needed them, even though he makes the majority of the decisions regarding what benefits Kloter Farms offers employees. Adding a risk manager to partner with Peter Welti would improve plan organization, and bolster the team of individuals that decides what benefits to offer. This risk manager could also assess risk within the organization, and suggest ways to prevent future perils and shortcomings within the plan design. If the company is not open to hiring a new employee at the executive position, they could alternatively choose to pass the

P a g e | 21

administration aspects of the plan off to a third party administrator, or an insurer who performs administrative services only. Implementing either of these two options would improve plan communication and ease the burden of performing duties that comply with ERISA (fiduciary responsibilities, communication requirements, reporting requirements such as Form 5500, etc.).

Conclusion In Kloter Farms thirty one years of existence, its benefit options have changed drastically. After using first dollar coverage with no deductible for the majority of its time as an entity, Kloter Farms changed its health benefit options to CDHP products five years ago due to exponential cost increases. Decision makers who administer these benefits to employees and their dependents continue to improve coverage gaps, and plan to add dental coverage in the next calendar year. In addition to health and life insurance benefits, the firm offers extensive benefits such as- AD&D, short and long term disability, paid time off for holidays, sick days, tuition reimbursement, and 401(k) profit sharing. Offering employees these benefits will retain valuable, capable personnel within the firm and keep them happy. Improving these coverage options and offering competitive benefits will also attract top talent to Kloter Farms, further improving the quality of the staff, which in turn improves the company name. Constant revision and analysis of the current plan will continue to strengthen the total package offered by Kloter Farms, and improve overall employee satisfaction. Kloter Farms begins with the individuals who work within the organization. Attracting and retaining valuable, capable employees will yield future success for years to come.

P a g e | 22 Work Cited

Cogan, Pamela, and Mary Piasta. "Perils and Pitfalls of ERISA Summary Plan Descriptions." Employee Benefit News. 16 June 2006. Web. 3 Dec. 2011. <https://blackboard.temple.edu/webapps/blackboard/content/contentWrapper.jsp?content_id =_2334919_1&displayName=Perils+and+Pitfalls+of+ERISA+Summary+Plan+Descriptions+-+First+of+Two+Articles&course_id=_4310_1&navItem=content&href=http%3A%2F%2Febn.ben efitnews.com%2Fnews%2Fperils-pitfalls-erisa-summary-plan-descriptions-39328-1.html>.

"Consumer-Directed Health Care: The Employer Perspective." National Business Group on Health (2011): 1-10. Apr. 2011. Web. 4 Dec. 2011.

Peterson, Chris L., and Hinda Chaikind. "Summary of Small Business Health Insurance Tax Credit Under PPACA (P.L. 111-148)." Congressional Research Service. 4 Apr. 2010. Web. 9 Dec. 2011. <http://www.ncsl.org/documents/health/SBtaxCredits.pdf>.

Welti, Peter. Personal interview. 6 December, 2011.