Upload
others
View
4
Download
0
Embed Size (px)
Citation preview
TRANSOCEAN RETIREE
HEALTH REIMBURSEMENT ACCOUNT (HRA)
PLAN
Plan and Summary Plan Description
Effective January 1, 2016
TABLE OF CONTENTS
ABOUT THE HRA PLAN .............................................................................................................................. 1
DEFINITIONS USED IN THIS SPD .............................................................................................................. 2
Company ................................................................................................................................................ 2
Eligible Medical Expense ....................................................................................................................... 2
Eligible Medical Plan .............................................................................................................................. 2
Health Reimbursement Arrangement (HRA) ......................................................................................... 2
HRA Plan ............................................................................................................................................... 2
Participant .............................................................................................................................................. 2
Transocean ............................................................................................................................................ 2
HRA PLAN HIGHLIGHTS ............................................................................................................................ 3
ELIGIBILITY AND COVERAGE UNDER THE PLAN .................................................................................. 4
You ............................................................................................................................................................ 4
Your Dependents ....................................................................................................................................... 5
Dependent Verification and Notice Requirements ................................................................................. 6
ENROLLMENT PROCESS ........................................................................................................................... 7
Introduction ................................................................................................................................................ 7
Outreach by OneExchange ....................................................................................................................... 7
Your Enrollment Appointment ................................................................................................................... 7
Other Resources and Ongoing Assistance ............................................................................................... 7
HRA ACCOUNT DETAILS ........................................................................................................................... 8
How the HRA Works .................................................................................................................................. 8
OneExchange Establishes Your HRA Account ..................................................................................... 8
HRA Subsidies ....................................................................................................................................... 8
You Submit Claims for Reimbursement from the HRA .......................................................................... 9
Your HRA Account Balance is Adjusted ................................................................................................ 9
What Happens if You Divorce ................................................................................................................ 9
What Happens on Your Death ............................................................................................................... 9
What Happens if You Lose Coverage ................................................................................................... 9
ELIGIBLE MEDICAL EXPENSES UNDER THE HRA ............................................................................... 11
CLAIMS PROCEDURES FOR HRA REIMBURSEMENTS ....................................................................... 13
Submitting HRA Claims ........................................................................................................................... 13
Authorized Representatives .................................................................................................................... 13
Claims Deadlines ..................................................................................................................................... 13
Claims Processing Details ....................................................................................................................... 14
Claims Decision Deadline .................................................................................................................... 14
Denials of Claims ................................................................................................................................. 14
Appealing a Denied Claim ................................................................................................................... 14
Denials of Appeals ............................................................................................................................... 15
Authority of the Claims Administrator .................................................................................................. 16
Requirements Before Filing Suit .......................................................................................................... 16
Offsets for Overpaid Claims ................................................................................................................. 16
WHEN PARTICIPATION ENDS UNDER THE HRA PLAN ....................................................................... 17
Participation Termination Events ............................................................................................................. 17
COBRA Continuation Coverage .............................................................................................................. 17
HRA PLAN ADMINISTRATIVE AND ERISA INFORMATION .................................................................. 18
Plan Name ........................................................................................................................................... 18
Plan Sponsor and Other Employers Participating in Plan ................................................................... 18
Employer Identification Number ........................................................................................................... 18
ERISA Plan Number ............................................................................................................................ 18
Type of Plan ......................................................................................................................................... 18
Plan Administrator/Agent for Legal Process ........................................................................................ 18
Claims Administrator ............................................................................................................................ 19
Plan Funding ........................................................................................................................................ 19
Right to Change or Terminate Plan ..................................................................................................... 19
Agent for Service of Legal Process ..................................................................................................... 20
Plan Year ............................................................................................................................................. 20
Contact for Questions .......................................................................................................................... 20
YOUR ERISA RIGHTS UNDER THE HRA PLAN ..................................................................................... 21
Receive Information about Your Plan and Benefits ............................................................................. 21
Prudent Actions by Plan Fiduciaries .................................................................................................... 21
Enforce Your Rights ............................................................................................................................. 21
Assistance with Your Questions .......................................................................................................... 22
1
ABOUT THE HRA PLAN
Effective January 1, 2016, eligible employees and their eligible dependents, upon retirement from
Transocean, may receive subsidies to a health reimbursement account (HRA) through the Transocean
Retiree Health Reimbursement Account (HRA) Plan (the “Plan”). The Plan is administered by the
Transocean Administrative Committee (the “Plan Administrator”), members of which are appointed by the
Board of Directors of Transocean Inc.
This document is both the plan document and the Summary Plan Description, or “SPD” for the Plan.
As with all the plans it provides, Transocean reserves the right to modify or terminate the Plan at any
time.
2
DEFINITIONS USED IN THIS SPD
Some terms that are used frequently in this SPD are capitalized, because they have specific meanings.
Those terms are defined below.
Company. The “Company” is Transocean Inc.
Eligible Medical Expense. An “Eligible Medical Expense” is an expense that you or your
dependent who is a participant in the HRA Plan incur for medical care which is not reimbursed by any
other plan. (Medical care is defined in Section 213(d) of the Internal Revenue Code. The Eligible Medical
Expenses section of this SPD provides additional information.)
Eligible Medical Plan. For a Participant who is not eligible for Medicare, an Eligible Medical Plan
will be a medical plan that provides minimum essential coverage for purposes of the Patient Protection
and Affordable Care Act of 2010. The Participant who is not eligible for Medicare may enroll in an Eligible
Medical Plan other than through OneExchange but must provide proof of enrollment to OneExchange in
order to receive an HRA Subsidy. For a Participant who is eligible for Medicare, an Eligible Medical Plan
will be a Medicare Advantage Plan or Medicare Supplemental Insurance Plan (also known as a Medigap
plan); provided that if a Participant has Medicaid coverage that would be jeopardized by enrollment in a
Medicare Advantage Plan or Medicare Supplemental Insurance (Medigap) Plan, a Medicare Part D that
the Participant enrolls in through OneExchange will be treated as an Eligible Medical Plan. The Medicare-
eligible Participant must enroll in this coverage through OneExchange.
Health Reimbursement Arrangement (HRA). A Health Reimbursement Arrangement (HRA) is
a bookkeeping account established by OneExchange for a Participant when they begin participating in
the HRA Plan.
HRA Plan. The HRA Plan is the plan described in this SPD.
Participant. A Participant is a retiree or dependent who is eligible for and covered under the HRA Plan
as described in the Eligibility and Coverage section of this SPD.
Transocean. Transocean is the Company and all affiliates and subsidiaries.
3
HRA PLAN HIGHLIGHTS
The Company established the HRA Plan effective January 1, 2016 as part of its healthcare coverage for
its eligible retirees and their eligible dependents.
Instead of employer-sponsored retiree medical coverage, you will have a choice of individual
medical, prescription drug, dental and vision plans through OneExchange.
If you are eligible for an HRA subsidy, OneExchange will establish an HRA account for you
when you become eligible to participate in the HRA Plan. Subsidy contributions to your
HRA account will assist you with the purchase of coverage through OneExchange or, if you
are not yet eligible for Medicare, through another exchange.
You (and your dependents) must be covered under an Eligible Medical Plan to participate in
the HRA Plan. For each year you maintain the required Eligible Medical Plan coverage,
properly notify OneExchange of such required coverage, and remain eligible for an HRA
subsidy, your HRA account will be credited annually with a tax-free contribution from
Transocean that may be used to pay for certain medical expenses for you and your eligible
dependents. If you and your spouse both qualify for a subsidy, an annual contribution will
be made for each of you and placed in a joint account, the balance of which can be used by
both you and your spouse. Only Transocean can contribute to the HRA account.
HRA funds can be used to pay for healthcare coverage (like premiums for Medicare Part B
coverage and/or medical, prescription drug, dental and vision plan premiums) or to
reimburse other eligible healthcare expenses.
For information and assistance on the Transocean partnership with OneExchange, you can call the
OneExchange team:
For Participants who are Medicare-eligible: 1-844-570-2791
For Participants who not Medicare-eligible: 1-844-570-2792
For Participants outside the U.S. who are Medicare-eligible: 801-994-9805
For Participants outside the U.S. who are not Medicare-eligible: 801-994-9806
Benefit Advisors are available from 7 am to 8 pm CT Monday through Friday.
Or, visit: http://Medicare.OneExchange.com/Transocean or http://OneExchange.com/Transocean.
More Important Details
The only benefit provided under the HRA Plan is the HRA account.
This SPD only describes that HRA benefit. It doesn’t describe the individual healthcare plans offered through One Exchange.
This section of the SPD only describes the highlights of the HRA benefit. You must read the rest of this SPD for other important details that apply to the HRA.
4
ELIGIBILITY AND COVERAGE UNDER THE PLAN
You and/or your dependents may receive an HRA Subsidy if you meet the criteria below AND you are
informed by OneExchange that you and/or your dependents are entitled to an HRA Subsidy based on
your service with Transocean. If you and/or your dependents are entitled to an HRA Subsidy, you will be
notified by OneExchange shortly after you retire from Transocean.
You You may be eligible to receive an HRA Subsidy (to the extent you are entitled to such HRA Subsidy due
to your service with Transocean) if, on the date immediately preceding your termination from Transocean
you were:
at least age 55 and have completed at least 10 years of eligible service
enrolled in a Company-sponsored medical plan
paid in U.S. dollars
classified as a:
o National Resident;
o National Commuter;
o Expatriate Resident;
o Expatriate Commuter (who resides in the U.S. following your termination of employment,
or resides outside the U.S. and is classified by Transocean as part of a grandfathered
population for purposes of this Plan);
Note: Provided you meet the above eligibility requirements, you may be eligible to receive an
HRA Subsidy even if you have not elected to retire under a Company-sponsored retirement
plan.
Your eligibility for, and the amount of, any HRA Subsidy is based on factors including your years of
service with Transocean, your age at the time of your retirement, and whether you provided service to the
legacy GlobalSantaFe company.
For the avoidance of doubt, no HRA Subsidy will be provided to a retiree (or his dependents) who is not
classified as a “Legacy Transocean” retiree or a “Legacy GlobalSantaFe” retiree once that retiree reaches
age 65. (Note that only whole years of service will count towards qualification as a “legacy” retiree.)
In order to receive any HRA Subsidy to which you may be entitled:
(1) You must have coverage under an Eligible Medical Plan and have provided proof of such
coverage to OneExchange;
(2) You must not be participating in any Transocean-sponsored health care coverage (for example,
COBRA continuation coverage offered by Transocean after your retirement); and
(3) You must have completed the OneExchange HRA enrollment procedures, including “opting-in” to
the HRA Plan if you are not yet eligible for Medicare.
5
However, if you or your dependent resides outside of the United States, your or such dependent may
receive any HRA Subsidy to which you may be entitled without purchasing coverage under an Eligible
Medical Plan.
When you retire, AonHewitt will determine whether you are eligible for an HRA Subsidy and the amount
of any such HRA Subsidy. You will then receive a personalized notice from OneExchange detailing any
HRA Subsidy to which you are entitled.
You (and your dependents) are not eligible to receive an HRA Subsidy for a calendar year if:
You fail to enroll in an Eligible Medical Plan and complete the HRA Plan enrollment
procedures with OneExchange by the annual deadlines described by OneExchange;
Elect only Medicare prescription drug coverage (Medicare Part D) without also enrolling in a
Medicare medical plan through OneExchange; or
Receive a health tax credit or subsidy from the U.S. government to assist you with the
purchase of coverage on a public health exchange for that calendar year.
In addition, an election of retiree coverage through OneExchange will be considered a rejection of
COBRA continuation coverage for all persons who make such an election.
Once you become eligible for Medicare, you (and your dependents) cease to be eligible to receive
an HRA Subsidy if:
You fail to enroll in an Eligible Medical Plan and complete the HRA Plan enrollment
procedures with OneExchange by the deadlines described by OneExchange;
You fail to maintain continuous coverage under an Eligible Medical Plan for the calendar
year;
Elect only Medicare prescription drug coverage (Medicare Part D) without also enrolling in a
Medicare medical plan through OneExchange; or
Receive a health tax credit or subsidy from the U.S. government to assist you with the
purchase of coverage on a public health exchange for that calendar year.
Once you become eligible for Medicare, you will forever forfeit the right to participate in the Plan if
you don’t enroll with OneExchange by the deadline set by OneExchange.
Your Dependents Provided they were covered under your medical coverage on your date of termination, the following
dependents may be eligible to receive an HRA Subsidy to the extent they are entitled to such HRA
Subsidy due to your service with Transocean:
Your legal spouse or domestic partner;
Your children under age 26 who are:
o your biological children;
o your stepchildren; or
6
o children for whom you have legal guardianship, are legally adopted by you or placed
with you for adoption;
Your children over age 26 who otherwise meet the definition of children above and are:
o severely disabled by prolonged physical or mental incapacity;
o were disabled at the time their coverage would have otherwise terminated; and
o remain unmarried and principally dependent on you for support because they’re unable
to independently earn a living.
You may not “add” any additional dependents for purposes of the HRA Plan at any time after your initial
enrollment.
Dependent Verification and Notice Requirements
If you have a disabled dependent you wish to cover beyond the date his or her eligibility would otherwise
end, you must provide proof of disability within 60 days of the date your dependent would otherwise lose
coverage.
If a dependent loses his or her status as an eligible dependent, you must notify the Benefits Center in
writing within 60 days of the loss of status.
7
ENROLLMENT PROCESS
Introduction
This section of the SPD briefly describes the main steps in the Plan enrollment process with respect to
the HRA Subsidy. Detailed information regarding the process in effect when it’s your time to enroll will be
provided to you directly by OneExchange.
You must enroll under the HRA Plan with OneExchange and be covered by an Eligible Medical Plan by the deadline communicated by OneExchange in order to receive any HRA Subsidy for which you may be eligible. You won’t automatically be enrolled in any Eligible Medical Plan. Once you become eligible for Medicare, you will forever forfeit the right to participate in the Plan if you don’t enroll with OneExchange by the deadline.
Outreach by OneExchange
OneExchange will send you information about the steps you’ll need to take to enroll in the HRA Plan and an Eligible Medical Plan when you retire from Transocean.
Your Enrollment Appointment
After receiving the information that OneExchange mails to you, you’ll call OneExchange to schedule an
enrollment appointment. During your scheduled enrollment appointment, you’ll talk with an experienced
representative who’ll provide these services:
Unbiased education about the types of individual Eligible Medical Plans available to you, how
much they cost, and how your eligible expenses will be covered under those plans.
Advice and decision-making support for your plan selection, based on your current coverage and
future needs.
Help enrolling in the plans you select.
Review of premium costs and payment options so you can select a payment option that works
best for you (because you’ll make payments for your coverage directly to the insurance carrier(s)
of the plan(s) you elect).
OneExchange can assist you with dental, vision and prescription drug plans, in addition to medical plans.
Other Resources and Ongoing Assistance
You’ll also have access to online decision-making tools and other resources anytime you need them through the OneExchange website. Visit OneExchange at http://Medicare.OneExchange.com/Transocean or http://OneExchange.com/Transocean.
If you are enrolled in an Eligible Medical Plan through OneExchange, OneExchange can provide ongoing advocacy and support, including answering your questions on coverage, claims, provider networks, and premiums under your Eligible Medical Plan in addition to questions on HRA reimbursements.
8
HRA ACCOUNT DETAILS
How the HRA Works
OneExchange Establishes Your HRA Account
OneExchange will automatically establish an HRA in your name if you qualify to receive an HRA Subsidy
under the HRA Plan and you complete the HRA enrollment process with OneExchange. (The account
may be established in your spouse’s name if your spouse enrolls before you.) If you and your spouse
enroll at the same time, OneExchange will establish a joint HRA in both of your names. Except as
provided in the box below, you and your dependents who are HRA Plan participants will always have a
single, combined HRA.
If you and your spouse are each eligible to participate in the HRA Plan as a Transocean retiree, OneExchange will establish a separate HRA for each of you when you enroll. You may request that these accounts be combined within 30 days following the date you receive an HRA Funding Kit from OneExchange. You must contact OneExchange to request a joint HRA account. Requests made following the 30 day deadline will not be honored. Please request a joint account. If you don’t have a joint account when you die or otherwise lose eligibility, your account balance will be forfeited once the claims submission deadline of 6 months past the date of loss of eligibility has passed.
HRA Subsidies
If you qualify to receive an HRA Subsidy, Transocean will make a contribution to your HRA at the
beginning of each year, as long as you remain a Participant. A contribution will also be made for each of
your eligible dependents who are Participants and who also qualify for an HRA Subsidy.
After you retire from Transocean, you will receive a notice from OneExchange detailing any HRA Subsidy
for which you are eligible. Contact OneExchange with any questions regarding your eligibility for an HRA
Subsidy.
Pro-ration. A Participant’s initial HRA Subsidy will be prorated based on the number of months the person will be a Participant in the initial year of coverage. However, proration will not apply to retirees and dependents who become Participants on January 1, 2016.
9
You Submit Claims for Reimbursement from the HRA
You can use amounts credited to your HRA for tax-free reimbursement of Eligible Medical Expenses that
you or your dependents who are also HRA Plan participants incur. These Eligible Medical Expenses
include Medicare Part B premiums and premiums for your medical, dental, vision and prescription drug
coverage.
You must first pay your premiums and other healthcare expenses, then submit claims to receive
reimbursements. However, OneExchange offers an auto-reimbursement option for many plans’ premiums
for Participants who are Medicare-eligible. Details on how to submit claims are in the Claims Procedure
section of this SPD.
You may be reimbursed for up to the full amount credited to your HRA at any time.
Tax Considerations. Any expenses reimbursed under an HRA cannot be claimed as deductions or used for tax credits on federal income taxes. You are ultimately responsible for correctly reporting your tax information to the IRS and for correctly using your HRA.
Your HRA Account Balance is Adjusted
When Transocean makes its annual contribution, OneExchange credits the full amount of the contribution
to your HRA account. When you’re reimbursed for expenses, OneExchange reduces the amount
credited to your account. Any money remaining credited to your account at the end of each year will
automatically roll over to the next year.
What Happens if You Divorce
If you have a joint HRA account with your spouse and you divorce, you must notify OneExchange. Your
spouse may be eligible to continue to access a portion of the HRA account balance if he or she elects
continuation coverage under COBRA and pays any applicable premiums. Otherwise, your spouse will
have 180 days to file for reimbursement of any claims incurred prior to the date of the divorce, subject to
the remaining balance in the joint HRA account.
What Happens on Your Death
If you die and you have a joint HRA account with a spouse or dependent child, the joint account will
continue as your dependent’s account. Your dependents may submit Eligible Medical Expenses you
incurred for 180 days following your death.
If you die without a joint HRA account, your account will be forfeited. This is true even if you have a spouse
who is an HRA Plan participant with a separate HRA account (because you were both eligible Transocean
employees and you did not choose to combine your accounts). However, your dependents, estate or
representatives may submit claims for Eligible Medical Expenses you incurred for 180 days following your
death.
What Happens if You Lose Coverage
If you lose HRA Plan coverage and you have a joint HRA account with a spouse or dependent child who
continues to be a Participant, your HRA account will continue even though you may no longer receive
10
HRA Subsidies. (This could happen, for example, if you are no longer enrolled in Eligible Medical
Coverage but your spouse continues to have the required coverage.) You may submit Eligible Medical
Expenses you incurred while you were a Participant for up to 180 days following your loss of coverage.
If you lose coverage and you don’t have a joint HRA account with a dependent who continues as a
Participant, your HRA account will be forfeited. However, you may submit claims for Eligible Medical
Expenses you incurred for 180 days following your loss of coverage.
11
ELIGIBLE MEDICAL EXPENSES UNDER THE HRA
The HRA can only be used to reimburse Eligible Medical Expenses.
An Eligible Medical Expense is an expense you or your dependent who is an HRA Plan Participant incurs for medical care, as that term is defined in Internal Revenue Code Section 213(d), which is not reimbursed by any other plan.
These generally are expenses related to the diagnosis, care, mitigation, treatment or prevention of disease. Some common examples of Eligible Medical Expenses include:
Medications prescribed by a doctor;
Insulin;
Dental expenses;
Dermatology;
Physical therapy;
Contact lenses or glasses used to correct a vision impairment;
Birth control pills;
Chiropractor treatments;
Hearing aids;
Wheelchairs; and
Premiums for medical, prescription drug, dental, vision or long-term care insurance.
Some examples of common items that are not Eligible Medical Expenses include:
Baby-sitting and child care;
Long-term care services;
Cosmetic surgery or similar procedures (unless the surgery is necessary to correct a deformity
arising from a congenital abnormality, accident or disfiguring disease);
Funeral and burial expenses;
Household and domestic help;
Massage therapy;
Custodial care;
Health club or fitness program dues; and
Cosmetics, toiletries, toothpaste, etc.
You can find more information about what items are and are not Eligible Medical Expenses in IRS Publication 502, “Medical and Dental Expenses.” (Be careful in relying on this Publication, however, as it is specifically designed to address what medical expenses are deductible on Form 1040, Schedule A, not what is reimbursable under a health reimbursement account.)
If you need more information regarding whether an expense is an Eligible Medical Expense under the HRA Plan, contact OneExchange.
Timing of Eligible Medical Expenses. Only Eligible Medical Expenses incurred by a person while that person is a Participant may be reimbursed from an HRA. Expenses are “incurred” when the medical care is provided, not when the person is billed, charged or pays for the expense. Therefore, an expense that has been paid but not incurred, like a pre-payment to a physician, cannot be reimbursed until the service or treatment has been provided.
12
In the event that an overpayment or erroneous payment is made as a reimbursement from a Participant’s HRA Account, OneExchange will be entitled to recover the amount of the overpayment or erroneous payment, including by offset of future benefits under the HRA Plan.
13
CLAIMS PROCEDURES FOR HRA REIMBURSEMENTS
This section describes the procedures for submitting claims for reimbursements from your HRA. This SPD does not describe how you should submit claims under the Eligible Medical Plan you choose through OneExchange. For information on how to submit those claims, contact the insurer of the Eligible Medical Plan(s) you have chosen.
Submitting HRA Claims
Your HRA balance can only be used to reimburse Eligible Medical Expenses that you have already paid. You can’t make payments directly from the HRA. However, OneExchange has entered into automatic premium reimbursement agreements with many insurers. This will allow you to obtain reimbursement for insurance plan premiums each month without submitting a new reimbursement request form each month. You can activate automatic reimbursement of your healthcare plan premiums by visiting the OneExchange website or speaking with OneExchange customer service at 1-844-570-2791. To receive reimbursement from your HRA for Eligible Medical Expenses that are not automatically reimbursed, you must obtain a reimbursement form from OneExchange, complete it and mail or fax it to:
Mail: Towers Watson’s OneExchange, P.O. Box 981155, El Paso, TX 79998-1155 Fax: 1-855-321-2605
You must also include a copy of (1) your insurance premium bill, or (2) an “explanation of benefits” or
“EOB” from a healthcare plan, or (3) if no EOB is provided, a written statement from the service provider
that includes the name of the patient, the date service or treatment was provided, a description of the
service or treatment; and proof of payment.
Claims Administrator. The “Claims Administrator” referred to in this SPD with respect to HRA reimbursements is the OneExchange department that handles HRA reimbursement claims processing. The “Claims Administrator” with respect to eligibility for an HRA subsidy and the amount of such HRA Subsidy is Aon Hewitt at the claim level and the Plan Administrator at the appeal level. The address and fax number listed above are only used for HRA reimbursement claims submission. For HRA reimbursement claims questions, contact OneExchange at 1-844-570-2791. For questions on eligibility for and amounts of HRA Subsidies, contact the Transocean Benefits Center.
Authorized Representatives
You may authorize another person to represent you in making a claim for a benefit or in appealing the
denial of a claim. The HRA Plan may, from time to time, specify forms you must use or procedures you
must follow to authorize another person to represent you.
Claims Deadlines
Most claims can be submitted for reimbursement at any time. However, no reimbursements will be made
for claims submitted after these deadlines:
Claims for a deceased Participant must be submitted within 180 days following the date of the
Participant’s death.
Claims for Participants who cease to be eligible under the HRA Plan must be submitted within
180 days following loss of eligibility for HRA Subsidies.
14
When is a claim submitted? A claim is considered submitted to the Claims Administrator upon actual delivery to the Claims Administrator in the proper form with all of the required information. If the claim is not complete, it may be denied or the Claims Administrator may contact you for the additional information.
Claims Processing Details
Claims Decision Deadline
The Claims Administrator must notify you of an initial claim payment or denial within 30 days of receiving
the initial claim. If the Claims Administrator needs more information from you and if the Claims
Administrator provides an extension notice during the initial 30-day period, the Claim Administrator has 45
days to notify you of a claim payment or denial. After receiving an extension notice, you have 45 days to
complete your claim. If you do not supply the requested information within the 45-day period, your claim
will likely be denied.
If your claim for reimbursement is approved, you will be provided reimbursement as soon as reasonably
possible following the determination. Claims are paid in the order in which they are received.
Denials of Claims
If any part of your claim is denied you will be given a written or an electronic notice that will include:
The reason for the denial;
A reference to the specific plan provisions on which the denial was based;
A description of any additional material or information needed to perfect the claim and a
statement of why the information is necessary;
If any internal rule, guideline, or protocol was relied on in denying the claim, a copy of the rule,
guideline or protocol will be provided;
If the claim was denied on appeal and was based on an exclusion or a limit like “medical
necessity” or “experimental treatment”, either the scientific or clinical judgment for the exclusion
or limit as applied to your circumstance, or a statement that such an explanation will be provided
to you free of charge upon request;
A statement describing any appeal procedures offered by the plan including any applicable
deadlines, and your right to obtain further information about the procedures; and
A statement of your right to file a lawsuit under ERISA if your claim is denied on final appeal to
the Plan Administrator.
Appealing a Denied Claim
If you wish to appeal a denied claim, you may do so. The appeal must be made in writing to the Claims
Administrator within 180 days after the date on which you receive the original claim denial. You may give
the Claims Administrator written comments, documents, records and other information relating to your
claim for benefits that you want to have considered on appeal, and all that information will be considered,
even if it was not submitted or considered in the original claim decision. The review on appeal won’t defer
to the claim denial and won’t be made by the person who made the original claim denial, or a subordinate
of that person.
15
You are also entitled, upon request, to see and get a free copy of any plan policy statement or guideline
that relates to the denied benefit, even if the policy statement or guideline was not relied on in denying the
claim. You may also request to see all documents, records, and other information relevant to your claim
for benefits and to get free copies of that information. This includes any information that:
Was relied on in making the benefit decision;
Was submitted, considered or generated in making the benefit decision, even if it was not relied
on;
Shows that administrative procedures or safeguards were followed to make sure that the benefit
decision was appropriately made based on the plan documents (excluding information in other
claimants' files); and
Is a statement of policy or guidance under the plan concerning the denied treatment or benefit for
your diagnosis, even if it was not relied on in making the benefit decision.
In deciding an appeal of any claim denial that is based in any way on a medical judgment (including
things like whether a treatment is experimental or not medically necessary), the Claims Administrator
must get advice from a health care professional who has training and experience in the relevant area of
medicine. Upon your request, you will be provided the names of any medical experts who were consulted
in connection with your claim denial, even if the advice was not relied upon in making the denial. The
health care professional consulted by the Claims Administrator cannot be a person who was consulted by
the Claims Administrator in connection with the claim denial (or a subordinate of the person who was
consulted in the original claim).
The Claims Administrator must make its decision on your appeal within a reasonable time following the
date the appeal was received but not longer than 60 days.
Denials of Appeals
If any part of your claim is denied on appeal, you will be given a written or an electronic notice that will
include:
The specific reason(s) for the denial;
A reference to each of the specific plan provision(s) on which the denial is based;
If any internal rule, guideline or protocol was relied on in denying the claim on appeal, either
include that specific rule, guideline or protocol, or a statement that a rule, guideline or protocol
was relied on in denying the claim and that a copy will be provided to you free of charge on
request;
If the claim denial on appeal was based on an exclusion or a limit like "medical necessity" or
"experimental treatment“, either the scientific or clinical judgment for the exclusion or limit as
applied to your circumstances, or a statement that such an explanation will be provided to you
free of charge upon request;
A statement that you are entitled, upon request, to see all documents, records, and other
information relevant to your claim for benefits and to get free copies of that information;
A statement describing any further appeal procedures offered by the plan, including any
applicable deadlines, and your right to obtain further information about any such procedures; and
A statement of your right to file a lawsuit under ERISA if you claim is denied on final appeal to the
Claims Administrator.
16
Authority of the Claims Administrator
The Plan Administrator has delegated the Claims Administrator discretionary authority and responsibility
for determining benefits under the HRA Plan, as described earlier in these Claims Procedures. In
processing claims and appeals, the Claims Administrator has discretionary authority to interpret the
provisions of the HRA Plan and to interpret the facts and circumstances of claims for benefits. No
benefits will be paid under the HRA Plan unless the Claims Administrator decides in its sole discretion
that the claimant is entitled to them. Any decision made by the Claims Administrator on final appeal is
conclusive and binding, unless you file suit under ERISA upon denial of your claim on final appeal.
Requirements Before Filing Suit
You cannot bring any legal action against the HRA Plan, Plan Administrator or Claims Administrator for
any reason unless you first complete all the steps in the appeal process described in this document. After
completing that process, if you want to bring a legal action against the HRA Plan, Plan Administrator or
Claims Administrator, you must do so within one year of the date you’re notified of the final decision on
your appeal, or you lose any rights to bring such an action.
Offsets for Overpaid Claims
If you’re paid more than you should have been reimbursed for a claim or if a claim is paid for ineligible
expenses, the Claims Administrator may deduct the overpayment from future claim payments due to you
under the HRA Plan.
17
WHEN PARTICIPATION ENDS UNDER THE HRA PLAN
Participation Termination Events
A Participant’s participation in the HRA Plan will end on the earliest of:
If the Participant is a retiree, the date the Participant is rehired by Transocean as an active
employee. (The participation of the retiree’s dependents who are Participants will terminate
at the same time.)
If the Participant is a retiree who is eligible for Medicare, the date the Participant ceases to
maintain continuous coverage under an Eligible Medical Plan. (The participation of the
retiree’s dependents who are Participants will terminate at the same time.)
The date of the Participant’s death. (If the Participant is a retiree, the participation of the
retiree’s dependents who are Participants will terminate upon the retiree’s death. However,
a surviving spouse may be eligible to continue to receive a reduced HRA Subsidy (based on
the same factors used to determine the amount of the retiree’s HRA Subsidy). Aon Hewitt
will determine eligibility for such reduced HRA Subsidy and will communicate any such
eligibility to the retiree’s surviving spouse.)
The date an amendment that terminates the Participant’s eligibility under the HRA Plan is
effective.
The date the HRA Plan is terminated.
Transocean currently intends that the HRA Plan will terminate no later than December 31, 2025. As with
all the plans it provides, Transocean reserves the right to modify or terminate the Plan at any time,
including prior to December 31, 2025.
Termination permanent. Once a Participant’s participation ends, it cannot be reinstated at any later date.
COBRA Continuation Coverage
A federal law commonly referred to as “COBRA” (the Consolidated Omnibus Budget Reconciliation Act),
requires most employers sponsoring group health plans to offer employees and their families the
opportunity to temporarily extend their health coverage at group rates in certain cases where their
coverage would otherwise end. It provides similar rights to retirees if the employer commences a Chapter
11 bankruptcy proceeding and they lose coverage as a result. If this occurs, the Plan Administrator will
inform you of your right to elect COBRA coverage and all of the related details.
18
HRA PLAN ADMINISTRATIVE AND ERISA INFORMATION
Plan Name
The formal name of the plan is the Transocean Retiree Health Reimbursement Arrangement (HRA) Plan.
The plan is commonly known as the HRA Plan.
Plan Sponsor and Other Employers Participating in Plan
The Plan sponsor is Transocean Inc. (referred to in this SPD as the “Company”).
Although the Company is the most significant employer maintaining the HRA Plan, the HRA Plan does
provide for the possibility of adoption by affiliated companies. HRA Plan participants and covered
dependents may, upon written request to the Plan Administrator, receive information as to whether a
particular employer is a sponsor and, if so, the address of that employer.
Employer Identification Number
The EIN assigned to the Company by the IRS is 66-0582307.
ERISA Plan Number
519
Type of Plan
The HRA Plan is a welfare benefit plan providing medical benefits. The HRA Plan is intended to qualify as
a self-insured medical reimbursement plan for purposes of Sections 105 and 106 of the Internal Revenue
Code, as amended (“Code”), as well as a health reimbursement arrangement as defined in IRS Notice
2002-45.
Plan Administrator/Agent for Legal Process
The Transocean Administrative Committee appointed by the Board of Directors of the Company is the
Plan Administrator and named fiduciary of the Plan.
The Plan Administrator has the discretionary authority under the Plan to interpret and construe all terms
of the Plan and to decide all questions of eligibility and to determine the amount, manner and time of
payment of all benefits.
The Plan Administrator may delegate its responsibilities and authority under the Plan, and has delegated
all HRA reimbursement claims and appeal processing responsibilities (and discretionary authority to
perform those functions) to the Claims Administrator. To the extent the Claim Administrator processes
appeals, they serve as appeals fiduciaries.
19
The contact information for the Plan Administrator is:
Transocean Inc.
Administrative Committee
c/o Benefits Department
4 Greenway Plaza
Houston, TX 77046
(713) 232-7500
Claims Administrator
The Plan Administrator has delegated the authority to OneExchange to provide the daily administration of
the HRA Plan and to process claims and decide appeals related to HRA reimbursements under the HRA
Plan. The Plan Administrator retains the authority to process claims and decide appeals related to
eligibility for HRA Subsidies. The applicable Claims Administrator shall have the authority, in its
discretion, to interpret the terms of the Plan, to decide questions of eligibility for coverage or benefits
under the Plan, and to make any related findings of fact. All decisions made by the Claims Administrator
shall be final and binding on the participants and beneficiaries to the full extent permitted by law.
The Claims Administrator’s contact information for questions related to HRA reimbursements is:
Towers Watson 10975 South Sterling View Drive
South Jordan, UT 84905
1-844-570-2791 (U.S. number for Medicare-eligible Participants)
1-844-570-2792 (U.S. number for non-Medicare-eligible Participants)
801-944-9805 (non-U.S. number for Medicare-eligible Participants)
801-944-9806 (non-U.S. number for non-Medicare-eligible Participants)
http://Medicare.OneExchange.com/Transocean or http://OneExchange.com/Transocean
The Claims Administrator’s contact information for submitting claims for HRA reimbursements only is:
Towers Watson P.O. Box 981155
El Paso, TX 79998-1155
Fax: 855-321-2605
Plan Funding
The Company pays the entire cost of the HRA Plan from the general assets of the Company.
Right to Change or Terminate Plan
The Company reserves the right to amend or terminate all benefits under the HRA Plan for any reason
and without notice.
If the HRA Plan is amended or terminated, you will not be entitled to any plan benefits or have any further
rights other than payment of benefits you had accrued before the HRA Plan was amended or terminated.
20
In general, no plan assets may ever revert to or be paid to the Company. If the plan is terminated,
amounts then credited to HRA accounts may continue to be made available to Participants or forfeited as
provided in the document(s) by which the plan is terminated.
Agent for Service of Legal Process
The person designated to receive service of legal process for the Plan is the Plan Administrator.
Plan Year
HRA Plan financial records are kept on a calendar year basis (January 1 - December 31).
Contact for Questions
For questions relating to your eligibility for an HRA subsidy:
Benefits Center
1-855-744-5005
+1 646-259-0401
www.yourtransoceanbenefits.com
For questions relating to the administration of the HRA: Based on age:
Pre-65: 1+844-570-2792, or www.oneexchange.com/Transocean
65 +: 1+844-570-2791, or medicare.oneexchange.com/Transocean
21
YOUR ERISA RIGHTS UNDER THE HRA PLAN
As a participant in the plan, you are entitled to certain rights and protections under the Employee
Retirement Income Security Act of 1974 (ERISA). ERISA provides that all plan participants are entitled
to:
Receive Information about Your Plan and Benefits
Examine, without charge, at the Plan Administrator’s office and at other specified locations, such
as worksites and union halls, all documents governing the plan, including insurance
contracts and collective bargaining agreements, and a copy of the latest annual report
(Form 5500 Series) filed by the plan with the U.S. Department of Labor and available at the
Public Disclosure Room of the Employee Benefits Security Administration.
Obtain, upon written request to the Plan Administrator, copies of documents governing the
operation of the plan, including insurance contracts and collective bargaining agreements,
and copies of the latest annual report (Form 5500 Series) and updated summary plan
description. The administrator may make a reasonable charge for the copies.
Receive a summary of the plan’s annual financial report. The Plan Administrator is required by
law to furnish each participant with a copy of this summary annual report.
Prudent Actions by Plan Fiduciaries
In addition to creating rights for plan participants, ERISA imposes duties upon the people who are
responsible for the operation of the employee benefit plan. The people who operate your plan, called
“fiduciaries” of the plan, have a duty to do so prudently and in the interest of you and other plan
participants and beneficiaries. No one, including your employer, your union, or any other person, may fire
you or otherwise discriminate against you in any way to prevent you from obtaining a plan benefit or
exercising your rights under ERISA.
Enforce Your Rights
If your claim for a plan benefit is denied or ignored, in whole or in part, you have a right to know why this
was done, to obtain copies of documents relating to the decision without charge, and to appeal any
denial, all within certain time schedules.
Under ERISA, there are steps you can take to enforce the above rights. For instance, if you request a
copy of a plan document or the latest annual report from the plan and do not receive them within 30
days, you may file suit in a federal court. In such a case, the court may require the Plan Administrator to
provide the materials and pay you up to $110 a day until you receive the materials, unless the materials
were not sent because of reasons beyond the control of the administrator. If you have a claim for benefits
which is denied or ignored, in whole or in part, you may file suit in a state or federal court (after you have
followed all of the claims and appeals procedures provided for under the plan). If it should happen that
plan fiduciaries misuse the plan’s money, or if you are discriminated against for asserting your rights, you
may seek assistance from the U.S. Department of Labor, or you may file suit in a federal court.
The court will decide who should pay court costs and legal fees. If you are successful, the court may
order the person you have sued to pay these costs and fees. If you lose, the court may order you to pay
these costs and fees, for example, if it finds your claim is frivolous.
22
Assistance with Your Questions
If you have any questions about your plan, you should contact the Plan Administrator. If you have
any questions about this statement or about your rights under ERISA, or if you need assistance in
obtaining documents from the Plan Administrator, you should contact the nearest office of the
Employee Benefits Security Administration, U.S. Department of Labor, listed in your telephone
directory or the Division of Technical Assistance and Inquiries, Employee Benefits Security
Administration, U.S. Department of Labor, 200 Constitution Avenue N.W., Washington, D.C. 20210. You
may also obtain certain publications about your rights and responsibilities under ERISA by calling the
publications hotline of the Employee Benefits Security Administration.