Reserve National - Redacted Bates HWM

7/27/2019 Reserve National - Redacted Bates HWM

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rom: Conrad, Kyle [[email protected]]ent: Thursday, September 23, 2010 2:50 PM

To: HHS HealthInsurance (HHS)Cc: Botwinick, Alexandra (HHS/OCIIO)

ubject: Waiver; Restricted Annual Limits; Reserve National Insurance Company; Policy Form PS-1

ollow Up Flag: Follow uplag Status: Red

Attachments: Reserve National Actuarial Dem Ann Lim Waiver.pdf; Reserve National PS-1 Rates Oklahoma.pdf;Reserve National President's Certification.pdf

ince 1987, Reserve National Insurance Company has issued coverage referred to as individual scheduled benefit hosmedical and surgical expense insurance. This coverage is underwritten on an individual basis, and complies with all applictate-law requirements. It is not major medical coverage under applicable state law, and is specifically marketed as not b

major medical coverage. It is a lower-cost alternative to major medical coverage. Our market niche is generally individuals in reas who do not have the availability of employer-provided health coverage and/or who cannot afford major medical coverahis coverage is considered to be non-comprehensive coverage, and we have consistently reported it as such to the applic

egulatory authorities.

With one minor exception noted below with respect to an optional rider for outpatient benefits, this policy does not have any anmits. Benefits are not based on a calendar year or policy year. Instead, the limits of this policy are based on each inju

ckness. This policy does not have a lifetime limit on benefits.

ince 2007, we have marketed and are continuing to market the current version of this policy, which is Scheduled Benefit HosMedical and Surgical Expense Policy Form PS-1. A similar previous version of this policy has been marketed since 1999.

s noted above, Policy Form PS-1 is individual, not group, coverage.

oreach injury or sickness, Policy Form PS-1 provides the following benefits:

1. First, a deductible selected by the applicant at the time of application must be satisfied by a covered person in his/her lifetime foreach injury or sickness before any benefits (except the Benefit for Mammogram, BenefPap Smears and Bene or D Visits) are payable for that particular injury or sickness. The avadeductibles range from $ to $ .

2. Then, for each injury or sickness, this policy provides the following benefits that are calculated by multiplyingby the expense incurred but limited to the following maximum benefit amounts foreach injury or sickness:

A. ly Hospital Room and Board Ben $ . On an optional basis, this benefit may be increas$ increments up to a maximum of $ p ay.

B. Mis s Hospital Inpatient Benefit - $ . On an optional basis, benefit maxim

and $ are available. Additionally, we r began offering a benefit maximum of $

C. Surgical Operations Benefit - As scheduled in olicy for each type of surgical operation re aresurgical schedules available: one with a $ maximum benefit and one with an $ maxibenefit.

D. The following additional benefits, with stated benefit limits for each injury or sickness:

i. Inpatient Diagnostic Radiology Benefit $

ii. Inpatient Pathology Benefit $ .

iii. Anesthesia Benefit % of the applicable surgical benefit.

iv. Mammogram Benefit $ This benefit is not subject to the deductible.

v. Pap Smear Benefit $ This benefit is not subject to the deductible.

vi. Doctor Visits Benefit - % o e expense incurred for doctoroffice visits, in excess a $ copayment for each visit, not to exceed a maximum benefit oper visit, limited to one visit day, and not to exceed two visits in each policy year. This beis not subject to the deductible.

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Document obtained by CompleteColorado.com


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3. If, for any one injury or sickness, a covered person reaches the maximum amount for one of the foregbenefits, then that benefit is not payable for that injury or sickness until 12 months have expired.

4. Optio Subject to a separate outpatient deductible that must be satisfied each p

year [$ , as selected by the applicant a tion], this rider pays o e atient physician visits [limited to visits per policy yea$ per visit], (b) emergenc y yea boratory tests and X[l ted in the aggregate to $ per policy year as selected by the applicant atime of application].

ur records show that as of August 31, 2010, we had just over individuals nationwide covered under Policy Form PS-1

ince our Policy Form PS-1 does not contain annual limits (instead our limits are based on each injury or sickness), it seems o us that it is not subject to the restriction on annual limits set forth in Section 2711 of the Public Health Service Act as addehe Patient Protection and Affordable Care Act (PPACA). However, notwithstanding the fact that our policy does not actontain annual limits, to the extent that your office would nevertheless consider the per injury or sickness limits to be annual lior purposes of the PPACA, we hereby apply for a waiver of the restricted annual limits set forth in the interim final regulaublished on June 28, 2010 (codified at 26 CFR 54.9815-2719T; 29 CFR 2590.715-2719; and 45 CFR 147.126, as mapplicable to Policy Form PS-1). This request for a waiver is made pursuant to OCIIO Sub-Regulatory Guidance (OCIIO 2010

We request that the waiver be effective for policy years beginning between September 23, 2010, and September 23, 2011.

the foregoing per injury or sickness limits were increased to the restricted annual limits of $750,000, which will be applicor policy years beginning on or after September 23, 2010, but before September 23, 2011, it would result in a significant incr premiums paid by our policyholders as shown by the attached actuarial demonstration. Based on the demographics o

olicyholders, we believe this would impose a severe hardship on our policyholders and result in many of them either reducing overage or dropping it completely.

he current rates for Policy Form PS-1 are attached. A certification signed by the president of Reserve National Insurompany, in accordance with the requirements of OCIIO Sub-Regulatory Guidance (OCIIO 2010-1), is also attached.

hank you for your consideration. Please contact me if there are any questions.

Kyle D. Conradenior Vice President

nd Associate Corporate Counsel

Reserve National Insurance Company

01 East Britton Road

Oklahoma City, OK 73114

elephone: (405) 848-7931 or (800) 874-1431

Attachments:

ctuarial Demonstrationepresentative Rates for Policy Form PS-1residents Certification

CONFIDENTIALITY NOTICE: The information contained in this e-mail and attached document(s) may containonfidential information that is intended only for the addressee(s). If you are not the intended recipient, you are herdvised that any disclosure, copying, distribution or the taking of any action in reliance upon the information isrohibited. If you have received this e-mail in error, please immediately notify the sender and delete it from yourystem.

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Pages 4 through 25 redacted for the following reasons:- - - - - - - - - - - - - - - - - - - - - - - - - - - -Exemption 4

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rom: Conrad, Kyle [[email protected]]ent: Thursday, September 23, 2010 3:55 PM

To: Botwinick, Alexandra (HHS/OCIIO)ubject: RE: Waiver; Restricted Annual Limits; Reserve National Insurance Company; Policy Form PS-1

Ms. Botwinick:

ur waiver request relates to individual coverage. We have thousands of policies in force, all with various effective dates. Ouaiver request relates to policies with policy years beginning on or after September 23, 2010.

lease let me know if there are any further questions.






elephone: (405) 848-7931 or (800) 874-1431

rom: Botwinick, Alexandra (HHS/OCIIO) [mailto:[email protected]]ent: Thursday, September 23, 2010 2:43 PM

o: Conrad, Kyleubject: RE: Waiver; Restricted Annual Limits; Reserve National Insurance Company; Policy Form PS-1mportance: High

Mr. Conrad,

apologize, my question was not clear.

What is the effective date of your policy?

hanks you,

Alexandra Botwinick

ffice of Oversight

HHS/[email protected]

rom: Conrad, Kyle [mailto:[email protected]]ent: Thursday, September 23, 2010 3:24 PMo: Botwinick, Alexandra (HHS/OCIIO)ubject: RE: Waiver; Restricted Annual Limits; Reserve National Insurance Company; Policy Form PS-1

Ms. Botwinick:

hank you for your reply. We are requesting that the waiver be effective for policy years beginning on or after September 23,010, and before September 23, 2011.


Kyle D. Conrad

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mailto:[email protected]:[email protected]


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enior Vice President





elephone: (405) 848-7931 or (800) 874-1431

rom: Botwinick, Alexandra (HHS/OCIIO) [mailto:[email protected]]ent: Thursday, September 23, 2010 2:05 PMo: Conrad, Kyle

ubject: RE: Waiver; Restricted Annual Limits; Reserve National Insurance Company; Policy Form PS-1mportance: High

Mr. Conrad,

hank you for your submission. I have not had the opportunity to review the application. Could you please

me whether you are submitting this application for plan or policy years beginning before November 2, 201

incerely,

Alexandra Botwinick

ffice of Oversight


rom: Conrad, Kyle [mailto:[email protected]]ent: Thursday, September 23, 2010 2:50 PMo: HHS HealthInsurance (HHS)c: Botwinick, Alexandra (HHS/OCIIO)ubject: Waiver; Restricted Annual Limits; Reserve National Insurance Company; Policy Form PS-1




With one minor exception noted below with respect to an optional rider for outpatient benefits, this policy does not have any anmits. Benefits are not based on a calendar year or policy year. Instead, the limits of this policy are based on each inju

ickness. This policy does not have a lifetime limit on benefits.




1. First, a deductible selected by the applicant at the time of application must be satisfied by a covered person in his/her lifetime foreach injury or sickness before any benefits (except the Benefit for Mammogram, BenefPap Smears and Bene or D Visits) are payable for that particular injury or sickness. The avadeductibles range from $ to $ .

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2. Then, for each injury or sickness, this policy provides the following benefits that are calculated by multiplying

by the expense incurred but limited to the following maximum benefit amounts foreach injury or sickness:

A. Daily Hospital Room and Board Ben $ On an optional basis, this benefit may be increase$100 increments up to a maximum of $ pe y.

B. Mis us Hospital Inpatient Benefit - $ . On an optional basis, benefit maxim


C. Surgical Operations Benefit - As scheduled in olicy for each type of surgical operation re aresurgical schedules available: one with a $ maximum benefit and one with an $ maxi

benefit.D. The following additional benefits, with stated benefit limits for each injury or sickness:


ii. Inpatient Pathology Benefit $



v. Pap Smear Benefit $ . This benefit is not subject to the deductible.

vi. Doctor Visits Benefit - % o e expense incurred for doctor

office visits, in excess a $ copayment for each visit, not to exceed a maximum benefit oper visit, limited to one visit p day, and not to exceed two visits in each policy year. This beis not subject to the deductible.


4. Opti Subject to a separate outpatient deductible that must be satisfied each p

year as selected by the applicant a tion], this rider pays o he tient physici isits [limited to visits per policy yea$ per visit], (b) emergen cy ye boratory tests and X[l ted in the aggregate to per policy year as selected by the applicant atime of application].




the foregoing per injury or sickness limits were increased to the restricted annual limits of $750,000, which will be applicor policy years beginning on or after September 23, 2010, but before September 23, 2011, it would result in a significant incr premiums paid by our policyholders as shown by the attached actuarial demonstration. Based on the demographics oolicyholders, we believe this would impose a severe hardship on our policyholders and result in many of them either reducing

overage or dropping it completely.







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elephone: (405) 848-7931 or (800) 874-1431

Attachments:




CONFIDENTIALITY NOTICE: The information contained in this e-mail and attached document(s) may contain

onfidential information that is intended only for the addressee(s). If you are not the intended recipient, you are herdvised that any disclosure, copying, distribution or the taking of any action in reliance upon the information isrohibited. If you have received this e-mail in error, please immediately notify the sender and delete it from yourystem.

ResNatl:000008



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//C|/...02/Reserve%20National%20Insurance%20Company/Commincation%20regarding%20status%20of%20waiver%2010-6-2010.htm[08/17/2011 2:52

rom: Botwinick, Alexandra (HHS/OCIIO)ent: Wednesday, October 06, 2010 5:03 PM

To: 'Conrad, Kyle'ubject: RE: Waiver; Restricted Annual Limits; Reserve National Insurance Company; Policy Form PS-1

Mr. Conrad,

We received your application on September 23rd, per the September 3, 2010 OCIIO Sub-Regulatory Guidan

OCIIO 2010-1), HHS will process complete waiver applications within 30 days of receipt. We are reviewin

pplications on a rolling basis, taking into account each plans effective date. We will inform you of our

ecision within 30 days. We appreciate your patience in this matter.

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

incerely,

lexandra Botwinick

ffice of Oversight


rom: Conrad, Kyle [mailto:[email protected]]ent: Monday, October 04, 2010 9:13 AMo: Botwinick, Alexandra (HHS/OCIIO)ubject: FW: Waiver; Restricted Annual Limits; Reserve National Insurance Company; Policy Form PS-1

Ms. Botwinick:

We noted that Director Angoff stated in his news release dated September 30, 2010, that your office has approved dozens ofaiver requests filed by mini-med plans and that applications were generally processed within 48 hours. Would you be able tve me an indication of when we can expect to hear something on our waiver request set forth below?

hank you for your assistance and consideration.





Oklahoma City, OK 73114elephone: (405) 848-7931 or (800) 874-1431

rom: Conrad, Kyleent: Thursday, September 23, 2010 2:55 PMo: 'Botwinick, Alexandra (HHS/OCIIO)'ubject: RE: Waiver; Restricted Annual Limits; Reserve National Insurance Company; Policy Form PS-1

Ms. Botwinick:

ur waiver request relates to individual coverage. We have thousands of policies in force, all with various effective dates. Ouaiver request relates to policies with policy years beginning on or after September 23, 2010.

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elephone: (405) 848-7931 or (800) 874-1431

rom: Botwinick, Alexandra (HHS/OCIIO) [mailto:[email protected]]ent: Thursday, September 23, 2010 2:43 PMo: Conrad, Kyleubject: RE: Waiver; Restricted Annual Limits; Reserve National Insurance Company; Policy Form PS-1mportance: High

Mr. Conrad,

apologize, my question was not clear.

What is the effective date of your policy?

hanks you,

lexandra Botwinick

ffice of Oversight


rom: Conrad, Kyle [mailto:[email protected]]ent: Thursday, September 23, 2010 3:24 PMo: Botwinick, Alexandra (HHS/OCIIO)ubject: RE: Waiver; Restricted Annual Limits; Reserve National Insurance Company; Policy Form PS-1

Ms. Botwinick:

hank you for your reply. We are requesting that the waiver be effective for policy years beginning on or after September 23,010, and before September 23, 2011.







elephone: (405) 848-7931 or (800) 874-1431

rom: Botwinick, Alexandra (HHS/OCIIO) [mailto:[email protected]]ent: Thursday, September 23, 2010 2:05 PMo: Conrad, Kyle

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ubject: RE: Waiver; Restricted Annual Limits; Reserve National Insurance Company; Policy Form PS-1mportance: High

Mr. Conrad,

hank you for your submission. I have not had the opportunity to review the application. Could you please

me whether you are submitting this application for plan or policy years beginning before November 2, 201

incerely,

lexandra Botwinick

ffice of Oversight


rom: Conrad, Kyle [mailto:[email protected]]ent: Thursday, September 23, 2010 2:50 PMo: HHS HealthInsurance (HHS)c: Botwinick, Alexandra (HHS/OCIIO)ubject: Waiver; Restricted Annual Limits; Reserve National Insurance Company; Policy Form PS-1




With one minor exception noted below with respect to an optional rider for outpatient benefits, this policy does not have any anmits. Benefits are not based on a calendar year or policy year. Instead, the limits of this policy are based on each injuickness. This policy does not have a lifetime limit on benefits.




1. First, a deductible selected by the applicant at the time of application must be satisfied by a covered person

in his/her lifetime foreach injury or sickness before any benefits (except the Benefit for Mammogram, BenefPap Smears and Bene or D Visits) are payable for that particular injury or sickness. The avadeductibles range from $ to $ .

2. Then, for each injury or sickness, this policy provides the following benefits that are calculated by multiplyingby the expense incurred but limited to the following maximum benefit amounts foreach injury or sickness:

A. ly Hospital Room and Board Bene On an optional basis, this benefit may be increase$ increments up to a maximum of $ p y.

B. Mis s Hospital Inpatient Benefit - $ . On an optional basis, benefit maxim


C. Surgical Operations Benefit - As scheduled in olicy for each type of surgical operation re aresurgical schedules available: one with a $ maximum benefit and one with an $ maxibenefit.

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D. The following additional benefits, with stated benefit limits for each injury or sickness:


ii. Inpatient Pathology Benefit $



v. Pap Smear Benefit $ This benefit is not subject to the deductible.

vi. Doctor Visits Benefit - % o e expense incurred for doctoroffice visits, in excess a $ copayment for each visit, not to exceed a maximum benefit oper visit, limited to one visit day, and not to exceed two visits in each policy year. This beis not subject to the deductible.


4. Optio Subject to a separate outpatient deductible that must be satisfied each p

year [$ , as selected by the applicant a tion], this rider pays o e tient physician visits [limited to visits per policy yea$ per visit], (b) emergenc y yea boratory tests and X[ ted in the aggregate to $ per policy year as selected by the applicant atime of application].




the foregoing per injury or sickness limits were increased to the restricted annual limits of $750,000, which will be applicor policy years beginning on or after September 23, 2010, but before September 23, 2011, it would result in a significant incr premiums paid by our policyholders as shown by the attached actuarial demonstration. Based on the demographics oolicyholders, we believe this would impose a severe hardship on our policyholders and result in many of them either reducing overage or dropping it completely.







Oklahoma City, OK 73114elephone: (405) 848-7931 or (800) 874-1431

Attachments:


CONFIDENTIALITY NOTICE: The information contained in this e-mail and attached document(s) may containonfidential information that is intended only for the addressee(s). If you are not the intended recipient, you are herdvised that any disclosure, copying, distribution or the taking of any action in reliance upon the information isrohibited. If you have received this e-mail in error, please immediately notify the sender and delete it from your

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ystem.


CONFIDENTIALITY NOTICE: The information contained in this e-mail and attached document(s) may contain

onfidential information that is intended only for the addressee(s). If you are not the intended recipient, you are herdvised that any disclosure, copying, distribution or the taking of any action in reliance upon the information isrohibited. If you have received this e-mail in error, please immediately notify the sender and delete it from yourystem.

ResNatl:000013



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//C|/...20Round/Disc%202/Reserve%20National%20Insurance%20Company/Request%20for%20Additional%20Info%2010.25.10.htm[08/17/2011 2:52:

rom: Pham, Erica (HHS/OCIIO)ent: Monday, October 25, 2010 6:23 PM

To: '[email protected]'Cc: Habit, Sandra (HHS/OCIIO)ubject: Reserve America - Request for Additional information

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:

We received your premiu for Reserves premium rates in Oklahoma. We understand you anticipat

the claims to increase by %, however, please provide us with the projected monthly premium rates

applicable to the plan or icy forms if the plan were to comply with the restricted annual benefits.

hank you and we look forward to receiving your completed application.

Kind Regards,

rica Phamivision of Enforcement

ffice of Oversight

CIIO/HHS

01-492-4108

[email protected]

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//C|/...sc%202/Reserve%20National%20Insurance%20Company/Request%20for%20Additional%20Info%20Response%2010.26.10.htm[08/17/2011 2:52

rom: Conrad, Kyle [[email protected]]ent: Tuesday, October 26, 2010 11:09 AM

To: Pham, Erica (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO)ubject: RE: Reserve America - Request for Additional information; Waiver; Restricted Annual Limits; Reserve

National Insurance Company; Policy Form PS-1

Attachments: Reserve National Projected PS-1 Rates Oklahoma With 750k Annual Limit.pdfear Ms. Pham:

hank you for your e-mail concerning our request for a waiver of the restricted annual limits of PHS Act Section 2711.

s you requested, we are providing you with a schedule of projected monthly premiums that would be applicable to our Policy FS-1 if the existing limits of that policy were increased to the restricted annual limits of $750,000 for policy years begi ng onfter September 23, 2010, but before September 23, 2011. These projected monthly premiums reflect an increase of % abour current monthly premiums for this policy. This would be a significant increase in premiums, which we believe would imposevere hardship on our policyholders and result in many of them either reducing their coverage or dropping it completely.

lease note that the name of our company is Reserve National rather than Reserve America.

We understand our application is now complete.







elephone: (405) 848-7931 or (800) 874-1431

rom: Pham, Erica (HHS/OCIIO) [mailto:[email protected]]

ent: Monday, October 25, 2010 5:23 PMo: Conrad, Kylec: Habit, Sandra (HHS/OCIIO)ubject: Reserve America - Request for Additional information

ear Applicant:




the claims to increase by %, however, please provide us with the projected monthly premium ratesapplicable to the plan or icy forms if the plan were to comply with the restricted annual benefits.


Kind Regards,

rica Phamivision of Enforcementffice of OversightCIIO/HHS

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[email protected]


ystem.

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//C|/...c%202/Reserve%20National%20Insurance%20Company/2nd%20Request%20Additional%20Info%20Response%2010.27.10.htm[08/17/2011 2:52

rom: Conrad, Kyle [[email protected]]ent: Wednesday, October 27, 2010 4:56 PM

To: Pham, Erica (HHS/OCIIO)Cc: Habit, Sandra (HHS/OCIIO)ubject: RE: Reserve National - Request for Additional information; Waiver; Restricted Annual Limits; Reserve

National Insurance Company; Policy Form PS-1ear Ms. Pham:

hank you for your follow-up e-mail.

nder our Policy Form PS-1, each benefit provision contains a dollar limit on the amount payable for a particular type of treatmhospital room and board, miscellaneous hospital expenses, surgery, etc.). The dollar limit in each benefit provision applies jury or sickness. For example, if an insured is diagnosed with skin cancer, after the deductible, Policy Form PS-1 will pay

he expense incurred for treatment of that skin cancer, up to the dollar limit in each benefit provision. If the maximum is paid uparticular benefit provision for that skin cancer, then no further amount will be payable under that benefit provision for that sk

ancer until 12 months has expired. Further, if the maximum were paid for that skin cancer and later the insured has a heartttack, then Policy Form PS-1 would pay benefits for the heart attack until the maximum is paid for that heart attack.

or surgery, Policy Form PS-1 has a schedule that lists particular surgical procedures and the dollar limit of the benefit payableach procedure. Each dollar limit applies to each injury or sickness. If, for a particular injury or sickness, the maximum is rea

or a particular surgical procedure, then no further amount would be payable for that procedure for that same injury or sickness

2 months has expired.

s outlined above, you are correct that once a particular benefit is exhausted for a particular injury or sickness, the insured woave to wait 12 months before that benefit would be payable for that same injury or sickness.

s I stated in our original application dated September 23, 2010, since our Policy Form PS-1 does not actually contain annualmits (with the exception of the limited outpatient rider described in our original application), it seems clear to us that this policyot subject to the restriction on annual limits set forth in PHS Act Section 2711. Our request for a waiver of the restricted annmits set forth in the interim regulations published on June 28, 2010, is being made to the extent your office were to consider per injury or sickness limits to be annual limits for purposes of the PPACA. If your office determines that the per injury orckness limits of Policy Form PS-1 are not considered to be annual limits for purposes of the PPACA, we request that you ns to that effect so that we would be assured from a compliance standpoint.

We appreciate your consideration. Please do not hesitate to call me if you would like to discuss this matter.






elephone: (405) 848-7931 or (800) 874-1431

rom: Pham, Erica (HHS/OCIIO) [mailto:[email protected]]ent: Wednesday, October 27, 2010 1:14 PM

o: Conrad, Kylec: Habit, Sandra (HHS/OCIIO)ubject: RE: Reserve National - Request for Additional information; Waiver; Restricted Annual Limits; Reserve National Insurancompany; Policy Form PS-1

hank you for your email. In your prior emails youve expressed that the limitations are limited to per injury or sickness. Justonfirm, for any particular chronic illness (i.e. cancer), is the participant limited by the maximum benefit? For example, you pro

urgical Operations Be As scheduled in the policy for each f surgical operation. There are two surgical schedulesvailable: one with a $ maximum benefit and one with an $ maximum benefit.

this maximum on a per surgical operation basis? Would this limitation renew with each new operation? And is this consiste

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ith all the plan benefits detailed in the application (i.e. each benefit is on a occurrence/per illness maximum).

n addition, you state:

f, for any one injury or sickness, a covered person reaches the maximum amount for one of the foregoing benefits, then thatenefit is not payable for that injury or sickness until 12 months have expired.

Would that mean for each injury or sickness, does that mean, once the benefit is exhausted, the policyholder has to wait andditional 12 months until they may receive benefits?

hank you for the clarification,rica

rom: Conrad, Kyle [mailto:[email protected]]ent: Tuesday, October 26, 2010 11:09 AMo: Pham, Erica (HHS/OCIIO)c: Habit, Sandra (HHS/OCIIO)ubject: RE: Reserve America - Request for Additional information; Waiver; Restricted Annual Limits; Reserve National Insuranompany; Policy Form PS-1

ear Ms. Pham:


s you requested, we are providing you with a schedule of projected monthly premiums that would be applicable to our Policy FS-1 if the existing limits of that policy were increased to the restricted annual limits of $750,000 for policy years begi ng onfter September 23, 2010, but before September 23, 2011. These projected monthly premiums reflect an increase of % abour current monthly premiums for this policy. This would be a significant increase in premiums, which we believe wou mposeevere hardship on our policyholders and result in many of them either reducing their coverage or dropping it completely.









elephone: (405) 848-7931 or (800) 874-1431

rom: Pham, Erica (HHS/OCIIO) [mailto:[email protected]]ent: Monday, October 25, 2010 5:23 PM

o: Conrad, Kylec: Habit, Sandra (HHS/OCIIO)ubject: Reserve America - Request for Additional information

ear Applicant:



We received your premiums for Reserves premium rates in Oklahoma. We understand you anticipat

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Kind Regards,

rica Phamivision of Enforcementffice of OversightCIIO/[email protected]


ystem.


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//C|/...nd/Disc%202/Reserve%20National%20Insurance%20Company/2nd%20Request%20for%20additional%20info%2010.27.10.htm[08/17/2011 2:52

rom: Pham, Erica (HHS/OCIIO)ent: Wednesday, October 27, 2010 2:14 PM

To: 'Conrad, Kyle'Cc: Habit, Sandra (HHS/OCIIO)ubject: RE: Reserve National - Request for Additional information; Waiver; Restricted Annual Limits; Reserve

National Insurance Company; Policy Form PS-1hank you for your email. In your prior emails youve expressed that the limitations are limited to per injury or sickness. Justonfirm, for any particular chronic illness (i.e. cancer), is the participant limited by the maximum benefit? For example, you pro

urgical Operations Benefit - As scheduled in the policy for each f surgical operation. There are two surgical schedulesvailable: one with a $ maximum benefit and one with an $ maximum benefit.

this maximum on a per surgical operation basis? Would this limitation renew with each new operation? And is this consisteith all the plan benefits detailed in the application (i.e. each benefit is on a occurrence/per illness maximum).

n addition, you state:

f, for any one injury or sickness, a covered person reaches the maximum amount for one of the foregoing benefits, then thatenefit is not payable for that injury or sickness until 12 months have expired.

Would that mean for each injury or sickness, does that mean, once the benefit is exhausted, the policyholder has to wait andditional 12 months until they may receive benefits?

hank you for the clarification,rica

rom: Conrad, Kyle [mailto:[email protected]]ent: Tuesday, October 26, 2010 11:09 AMo: Pham, Erica (HHS/OCIIO)c: Habit, Sandra (HHS/OCIIO)ubject: RE: Reserve America - Request for Additional information; Waiver; Restricted Annual Limits; Reserve National Insuranompany; Policy Form PS-1

ear Ms. Pham:


s you requested, we are providing you with a schedule of projected monthly premiums that would be applicable to our Policy FS-1 if the existing limits of that policy were increased to the restricted annual limits of $750,000 for policy years beginning on fter September 23, 2010, but before September 23, 2011. These projected monthly premiums reflect an increase of % abour current monthly premiums for this policy. This would be a significant increase in premiums, which we believe wou mposeevere hardship on our policyholders and result in many of them either reducing their coverage or dropping it completely.









elephone: (405) 848-7931 or (800) 874-1431

rom: Pham, Erica (HHS/OCIIO) [mailto:[email protected]]

ResNatl:000020



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ent: Monday, October 25, 2010 5:23 PMo: Conrad, Kylec: Habit, Sandra (HHS/OCIIO)ubject: Reserve America - Request for Additional information

ear Applicant:







Kind Regards,

rica Pham

ivision of Enforcementffice of OversightCIIO/[email protected]


ystem.


Documents

Reserve National - Redacted Bates HWM