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HomeMy WebLinkAboutContract 47462 COBRA Administrative Services Agreement GPID 25345 Employer Tax ID 75-6000528 This COBRA Administrative Services Agreement ("Agreement") is entered into by and between City of Fort Worth ("Employer') and Discovery Benefits, Inc. ("DBI")as of 01/01/2016 ("Effective Date"). Recitals CITYSECRET I l.ft v CMMCT NO. Employer desires to retain DBI as an independent contractor to administer certain elements of its obligations under the Consolidated Omnibus Budget Reconciliation Act of 1985, as amended ("COBRA") and DBI desires to assist the Employer in the administration of such COBRA obligations. Employer and DBI agree that DBI shall assist in the administration of Employer's COBRA obligations on the terms and conditions set forth within this Agreement, including, without limitation,that: Employer has established one or more health plans that include medical, dental,vision, employee assistance plan, health flexible spending arrangement and/or health reimbursement arrangement benefits("Plan"or"Employer Plan")for its employees; Employer is the administrator of the Plan; DBI acts as an independent contractor of the Employer; Employer remains responsible for maintaining the Plan, including the establishment of eligibility and paying all benefits owed or established under the Plan to its participants; and DBI is to provide the agreed upon services without assuming any liability beyond the performance of its services as set forth herein. Now, therefore, in consideration of good and valuable consideration, the parties agree as follows. Article 1 —COBRA Administrative Services DBI agrees to provide Employer with the following COBRA administrative services: 1.1 Except for those things that are the Employer's responsibility under this Agreement, DBI shall assume responsibility for proper interpretation, application, and administration of COBRA rules and regulations for the Employer Plan for COBRA administration under DBI's control. 1.2 Provide consultation to Employer in the interpretation and application of regulations concerning COBRA administration as they apply to the Employer's Plan. 1.3 If requested by Employer, mail DBI's standard initial rights notification letter to all active"Covered"employees and spouses at the initiation of this Agreement. "Covered"is defined as any individual covered by the Employer's Plan as set forth in Exhibit A and that qualifies for federal COBRA continuation coverage. The Employer must provide all information reasonably requested by DBI in order to complete this mailing. 1.4 Upon receipt of complete and timely information from Employer, send via accountable mail,within the applicable time frame required by COBRA or upon the effective date of coverage, whichever is later, DBI's standard initial rights notification letter to newly covered employees and spouses of the Employer Plan informing them of their rights under COBRA. If complete information is not timely received from the Employer, DBI will send the notice described in the preceding sentence as soon as administratively practicable after receiving the required information, but such notice may not be provided within the applicable time frame required by COBRA. 1.5 Upon receipt of complete and timely information from Employer, send via accountable mail within the applicable time frame required by COBRA, DBI's standard qualifying event eligibility and election notice to all eligible qualified beneficiaries under the Employer Plan. If complete information is not timely received from the Employer, DBI will send the notice described in the preceding sentence as soon as administratively practicable after receiving the required information, but such notice may not be provided within the applicable time frame required by COBRA. 1.6 Mail DBI's standard payment coupons and member portal login notice to qualified beneficiaries when COBRA is elected and the first COBRA premium payment has been received. As part of the administrative service fees that DBI charges under this Agreement, DBI shall have the right to retain the COBRA administrative fees that are billed to and paid by COBRA continuants. For purposes of this Agreement, the COBRA administrative fees retained by DBI shall include the two percent (2%) additional premium allowed by COBRA and charged to COBRA continuants. 1.7 Qualified Beneficiaries can pay COBRA premiums by check or automatic recurring ACH without any additional charges. DBI will also provide qualified beneficiaries an additional option to pay COBRA premiums online with either a credit card or a single occurrence ACH request. To the extent permitted by law and the applicable credit card operating rules and regulations, an additional online processing fee, charged by the online third party vendor and payable by the third party beneficiaries, applies for the credit card or single occurrence ACH payment method. The fee is collected by DBI and remitted to the third party vendor and there is no mark up by DBI with respect to the fee. DBI represents that its payment vmethods comol'Lwith- RA. Discovery Benefits simplify:" r-17. UUommq LI ivi COBRA Administrative Services Agreement GPID 25345 Employer Tax ID 75-6000528 1.8 Deposit insurance premiums in a Custodial Account for the benefit of Employer in the manner described in Article 3. 1.9 Collect,track, process, and remit the COBRA premiums that are paid by the qualified beneficiaries to the Employer. A Remit to Carrier option may be available for employers requesting this option. A completed COBRA Authorization Agreement for Direct Payment form is required for employers requesting the Remit to Carrier option. Failure to provide the completed COBRA Authorization Agreement for Direct Payment form will result in DBI remitting premiums to the Employer. 1.10 Coordinate with Employer and insurance carriers on any questions pertaining to a qualified beneficiary's COBRA eligibility and payment status. 1.11 Using DBI's standard communications, maintain communication with the qualified beneficiaries who have elected COBRA coverage concerning eligibility status, Medicare eligibility, advance termination notice for the individual conversion,verification of termination, change of address, benefit and rate changes. 1.12 Provide real-time,online access to information related to the status of qualified beneficiaries and those who have elected COBRA coverage. 1.13 Provide the information required in the event of an IRS or other third party audit as follows: written compliance procedures DBI uses in the administration of COBRA, samples of forms and notices, records that pertain to a qualified beneficiary's actual qualifying event, and a description of how DBI administers COBRA coverage. 1.14 Supply Employer with the initial login information for accessing the Employer web portal for notifying DBI when an employee, spouse or dependent is added to coverage for the first time and notifying DBI when an employee, spouse or dependent has experienced a qualifying event and is eligible for COBRA continuation under the Employer's Plan. 1.15 Supply Employer with the required DBI file format for uploading employee demographic, benefit and qualifying event information to the Employer web portal. 1.16 Provide a toll-free number during DBI normal business hours for questions concerning COBRA compliance, regulations or payment issues. From time-to-time and in compliance with applicable federal and state laws, DBI may monitor and/or record calls which are made to and from the customer service line for quality assurance and training purposes, and/or to ensure that DBI's services fully comply with the terms of this Agreement. 1.17 Notify a qualified beneficiary if COBRA coverage terminates earlier than the end of the maximum period of coverage applicable to the qualifying event that entitled the individual to COBRA coverage. The notice will be provided as soon as administratively practicable after DBI determines that COBRA coverage will be terminated early. 1.18 Extend the maximum COBRA period in cases of disability and second qualifying events based on the rules of COBRA. 1.19 Send DBI's standard system generated open enrollment/rate change letter during open enrollment. If requested by Employer, DBI will provide participants with a link to additional plan and benefit description materials provided by Employer through the participant web portal for participant viewing and printing. Article 2—The Employer Employer agrees to provide and be responsible for the following in the COBRA administrative process: 2.1 Provide to DBI accurate"Covered"employee counts on a monthly basis or as requested by DBI. "Covered"is defined as any individual covered by the Employer's Plan as set forth in Exhibit A and that qualifies for federal COBRA continuation coverage. 2.2 Provide to DBI complete demographic and benefit information on qualified beneficiaries currently receiving COBRA coverage under the Employer Plan upon the inception of this Agreement, allowing DBI to take over the administration of qualified beneficiaries currently on COBRA. 2.3 Enter information or upload an electronic file via the Employer web portal containing complete demographic and benefit election information for newly covered employees, spouses and dependents within seven (7)days of obtaining coverage under the Employer Plan. 2 Discovery Benefits simplify' COBRA Administrative Services Agreement GPID 25345 Employer Tax ID 75-6000528 2.4 The Employer shall notify DBI of any initial qualifying event that occurs with respect to an employee, spouse or dependent. Employer shall also notify DBI of a second qualifying event should Employer be notified by an employee, spouse or dependent. Such notice shall be provided using the procedures specified by DBI within thirty(30)days of the qualifying event or the date coverage is lost on account of the qualifying event,whichever is later, unless the qualifying event is the employee's divorce or a dependent aging out of the Plan in which case the notice shall be provided within seven (7) days following the Employer's receipt of notice by an employee, spouse or dependent of such qualifying event. Unless directed otherwise by DBI, notice of a qualifying event shall be provided by entering the required qualifying event information directly into the Employer web portal or uploading an electronic file via the Employer web portal. The Employer shall be solely responsible for determining whether an employee, spouse or dependent has had an initial qualifying event under the Employer Plan and the date of the qualifying event. 2.5 Be solely responsible for its insurers and third party administrators(collectively"Carriers")to send a separate billing statement to DBI that includes only qualified beneficiaries electing COBRA coverage when the remit to Carrier option is selected and DBI is remitting premiums to Carrier. Employer agrees to provide a completed COBRA Authorization Agreement for Direct Payment form to DBI for remit to Carrier. Failure to provide the completed COBRA Authorization Agreement for Direct Payment form will result in DBI remitting premiums back to the Employer. Employer is at all times responsible to pay to DBI its portion of the premium,where applicable, prior to DBI remitting premiums to the Carrier. 2.6 Be solely responsible for reconciling the Carrier billings with the online reports provided by DBI through the Employer web portal. Many Carriers restrict the ability to retroactively terminate COBRA coverage(even in cases of non-payment of premiums by the qualified beneficiary). DBI shall not be liable for paying any loss or damage(including premiums)to the Employer with respect to any retroactive termination of COBRA coverage, provided that DBI has performed in accordance with this Agreement. 2.7 Be solely responsible for selecting a determination period, and establishing and advising DBI of the applicable premium rates to be charged for COBRA continuation coverage. Employer shall notify DBI in writing at least forty-five(45) days in advance of the applicable billing date of any changes in premium rates affecting participants electing COBRA coverage under the Employer Plan and at least forty-five(45)days in advance of the applicable billing date of any changes in premiums applicable to participants during an open enrollment period. 2.8 Be solely responsible for differences in premium payments paid by qualified beneficiaries when notification of rate changes is not communicated to DBI at least forty-five (45)days in advance, causing payments made by COBRA continuants to be incorrect for the new determination period. 2.9 Be solely responsible for advising DBI of any changes in the benefits and options provided by the Employer Plan. 2.10 Be solely responsible for complying with the Employee Retirement Income Security Act of 1974("ERISA"),the Internal Revenue Code (the"Code"), Health Insurance Portability and Accountability Act("HIPAK)and any other applicable federal, state and/or local laws with respect to the Employer Plan,other than the COBRA responsibilities assumed by DBI under this Agreement. 2.11 Be solely responsible for the review and payment of all claims under the Employer Plan and ERISA, including,without limitation,claims for benefits and claims for eligibility determinations under the Employer Plan. DBI shall not be responsible to receive or review claims for benefits under the Employer Plan, and DBI shall not be liable for the payment or funding of any claims for benefits in connection with the Employer Plan, including,without limitation,where sought as damages in an action against the Employer or the Employer Plan and any occurrences prior to the Effective Date of this Agreement. Nothing in this Section 2.11 shall prevent either party from pursuing any rights that it may have under Section 7.6. 2.12 Be solely responsible for maintaining and providing the following information in the event of an IRS or any third party audit: written internal compliance procedures used for notifying DBI of a newly covered employee, spouse or dependent, a qualifying event, a report of terminations for each tax year, or when there are rate and benefit changes. 2.13 Provide the release of any information necessary for COBRA compliance and administration under this Agreement. 2.14 Be solely responsible for providing plan and benefit descriptions (examples include but are not limited to Summary of Benefits and Coverage (SBC), SPDs and/or benefit plan booklets)to qualified beneficiaries during open enrollment. DBI's standard process is to provide a link to these additional materials through the participant web portal for participant viewing and printing. If requested by Employer, DBI may include the additional information with its standard open enrollment/rate change letter under the following terms and conditions: Employer provides DBI with an electronic PDF image of the additional open enrollment materials; a handling fee of$1.00 per page(duplex)will apply for the additional materials; additional materials are limited to a total of 25 duplexed pages (including DBI's standard open enrollment/rate change letter). j---- 3 Discovery Benefits simplify," COBRA Administrative Services Agreement GPID 25345 Employer Tax ID 75-6000528 2.15 Employer acknowledges and agrees that the COBRA Administrative Services provided by DBI pursuant to this Agreement relate to enrollment and disenrollment in the Plan, and that these services,to the extent permitted under HIPAA, shall be deemed to be performed by DBI on behalf of the Employer, in its capacity as the sponsor of the Plan. Employer further acknowledges and agrees that DBI may use or disclose enrollment or disenrollment information that it receives from Employer with respect to a particular qualified beneficiary to provide additional services to the qualified beneficiary without cost to the Employer. Article 3—Custodial account 3.1 By signing this Agreement, Employer appoints DBI as custodian of Employer funds for the purposes and upon the terms and conditions set forth in this Agreement, and DBI accepts such appointment and agrees to act as custodian hereunder and to hold any Employer funds received hereunder in accordance with the terms and conditions set forth in this Agreement. 3.2 DBI shall open and maintain one or more depository accounts(the"Custodial Account") at Bell State Bank&Trust(the "Bank"), Fargo, ND and hold in such Custodial Account all premiums received from qualified beneficiaries, less any portion of the premium payment that constitutes administrative fees payable by the qualified beneficiary. Upon deposit,such premiums shall become"Employer Funds" (minus any applicable fees or other costs as set forth in this Agreement). For administrative convenience and to reduce costs, DBI shall hold Employer Funds of the Employer together with similar funds from other employers in a single Custodial Account(or one or more Custodial Accounts as determined by DBI). However, DBI shall maintain records as to the exact amount of funds allocated to each employer so that each employer has a legal right to the specific amount of its funds held in the Custodial Account. To that end, at all times,the assets comprising each employer's funds in the Custodial Account shall be considered a separate subaccount for purposes of this Agreement. Depending upon the context,the term, "Custodial Account,"shall refer to either the separate subaccount for the Employer or all of the subaccounts for all employers in the aggregate. 3.3 Employer and DBI intend and agree that all Employer Funds transferred by the Employer to the Custodial Account shall be comprised of and shall remain the general assets of Employer. Except to the extent that outstanding checks have been written or withdrawals made against the Custodial Account balance on behalf of Employer, the Employer Funds may be withdrawn by the Employer at any time(minus any applicable fees or other costs as set forth in this Agreement) and are subject to Employer's general creditors in the same manner as funds contributed to Employer's ordinary checking accounts. 3.4 DBI shall forward health insurance premiums from the Custodial Account to insurance companies, Employer,or Employer's designee as directed by Employer and in accordance with this Agreement and Employer's group health plan. DBI shall neither have nor shall be deemed to have any discretion, control, or authority with respect to the disposition of Employer Funds. 3.5 Employer acknowledges and understands that DBI may receive interest from time to time on the funds held in the Custodial Account and that any such interest received by DBI shall be part of DBI's compensation. Employer acknowledges and understands that compensation otherwise charged by DBI for services under the Agreement would be higher if it did not retain such interest on these funds. The period during which interest may be earned begins on the date the funds are transferred to the Custodial Account and ends when this Agreement terminates. Funds shall be disbursed on a first-in-first-out basis. 3.6 Upon Employer's written request, DBI shall provide Employer with an accounting of all assets,transfers and transactions involving the Custodial Account, including description of all receipts, disbursements and other transactions. Bank charges may apply for providing copies of checks, statements or other certified documentation. 3.7 DBI may resign from its duties as custodian pursuant to this Article 3 at any time by giving written notice to Employer no less than sixty(60)days prior to the effective date of such resignation; provided, in any event, that such resignation shall not be effective until a successor custodian has been appointed or the assets in the Custodial Account have been returned to Employer. Article 4—Confidentiality Neither DBI nor Employer(each a"Party")shall disclose Confidential Information of the other Party.The receiving Party shall use the same degree of care as it uses to protect its own Confidential Information of like nature, but no less than a reasonable degree of care, to maintain in confidence the Confidential Information of the disclosing Party. The foregoing obligations shall not apply to any information that(a) is at the time of disclosure, or thereafter becomes, part of the public domain through a source other than the receiving Party, (b) is subsequently learned from a third party that does not impose an obligation of confidentiality on the receiving Party, (c)was known to the receiving Party at the time of disclosure, (d)was generated independently by the receiving Party, or(e) is required to be disclosed by law, subpoena or other process. DBI may transfer Employer's or the Plan's Confidential Information to a j 4 Discovery Benefits simplify.' COBRA Administrative Services Agreement GPID 25345 Employer Tax ID 75-6000528 governmental agency or other third party,with the same obligations owed to Employer as DBI, to the extent necessary for DBI to perform its obligations under this Agreement or if Employer has given DBI written authorization to do so. For purposes of this paragraph, "Confidential Information"shall mean any information identified by either Party as"Confidential" and/or"Proprietary", or which, under the circumstances, ought to be treated as confidential or proprietary, including non-public information related to the disclosing Party's business, employees, service methods, software, documentation,financial information, prices and product plans (including Information as defined in Section 7.4). DBI reserves the right to independently use its experience and know-how, including processes, ideas, concepts and techniques developed in the course of performing services under this Agreement. DBI represents and warrants that it has implemented and maintains a written and comprehensive information security program, and complies with all applicable laws and regulations, including without limitation state privacy and data security laws and regulations,such as the Massachusetts Standards for the Protection of Personal Information of Residents of the Commonwealth (201 CMR 17.00). In no event shall either party be held liable for disclosing Confidential Information of the other that is required by law or court order. The party will notify the other within ten (10) business days of such request. Article 5—Term of the Agreement 5.1 The term of this Agreement shall commence as of the Effective Date and shall continue for a period of three years(the"Initial Term") and shall expire on December 31, 2018, unless terminated earlier in accordance with the provisions of this Agreement.. Employer shall have the sole right to renew this Agreement for two(2)additional one-year terms, unless terminated in writing by either Party within sixty(60)days prior to the end of the Initial Term or prior to the end of any subsequent one(1)year term. If Employer desires to exercise an option to renew, Employer shall notify DBI in writing of its intention to renew at least sixty (60)days prior to the end of the then-current term. Compensation to be paid during any option term shall be the same as that provided for in the Initial Term, unless otherwise agreed to in writing as an amendment to this Agreement. Notwithstanding the foregoing, DBI reserves the right to increase fees at any time that are caused by Federal postal rate increases, increases in bank fees, or that are due to Federal legislative changes affecting COBRA provided that DBI notifies Employer of such increases at least thirty(30) days prior to the increase. DBI reserves the right to increase fees due to the provision of additional services to the Employer by DBI that were not included in or contemplated by this Agreement on the Effective Date but agreed to in writing by Employer. 5.2 Employer shall pay all charges that have accrued up to the date of the termination within thirty(30) days after the date of the termination. 5.3 This Agreement may be terminated at any time by either party without cause and without liability, by written notice of intention to terminate given to the other party, to be effective as of a date certain set forth in the written notice,which shall not be less than sixty(60) days from the date of such notice. 5.4 Upon termination of this Agreement, any funds in the Custodial Account that have not been disbursed to the insurance companies in accordance with the terms and conditions of this Agreement shall be returned to Employer(minus any applicable fees or other costs as set forth in this Agreement). 5.5 The Agreement shall automatically terminate: (a) If any law is enacted or interpreted to prohibit the continuance of this Agreement, upon the effective date of such law or interpretation;or (b) If any administrative fee for any service provided by DBI to Employer remains unpaid to DBI beyond thirty(30)days past the due date, upon notification by DBI to the Employer in writing that DBI intends to exercise its option to enforce this provision. If either Party is in default under any provision of this Agreement,the other Party may give written notice to the other Party of such default. If the defaulting Party has not used good faith efforts to cure such breach or default within thirty(30)days after it receives such notice, or if good faith efforts to cure have begun within thirty(30)days but such cure is not completed within sixty(60)days after receipt of the notice, the other Party shall have the right by further written notice (the "Termination Notice")to terminate the Agreement as of any future date designated in the Termination Notice. (c) In the event no funds or insufficient funds are appropriated by the Employer in any fiscal period for any payments due hereunder, Employer will notify DBI of such occurrence and this Agreement shall terminate on the last day of the fiscal period for which appropriations were received without penalty or expense to the Employer of any kind whatsoever, except as to the portions of the payments herein agreed upon for which funds shall have been appropriated. 5 Discovery Benefits simplify." COBRA Administrative Services Agreement GPID 25345 Employer Tax ID 75-6000528 5.6 When this Agreement is terminated under Sections 5.1, 5.3 or 5.5, DBI will immediately cease the performance of any further services under this Agreement unless both Parties agree that DBI shall continue performing services during any post- termination"run-out"period. If the Employer engages DBI to administer a post-termination"run-out period," DBI will invoice and collect fees based on the fee schedule in place during the regular contract period. Upon receipt of the"run-out fee,"DBI will continue the processing of qualifying events, initial notices,the collection and tracking of continuant premiums,forwarding premiums to the Employer and processing and reporting of COBRA elections and terminations with respect to those qualified beneficiaries who incurred a qualifying event prior to the date the Agreement was terminated. 5.7 Upon the completion of the later of the Agreement, or any agreed-upon"run-out period,"DBI will cease providing COBRA administration services, and the Employer shall be immediately responsible for all aspects of COBRA administration. DBI shall also return any Employer Funds in the Custodial Account. However, the return of such funds shall remain subject to the completion of a final accounting of all account activities, as well as the deduction of applicable unpaid fees and other expenses under this Agreement or any other agreement between the parties. If necessary, DBI shall have the immediate right to demand and pursue collection of any unpaid fees, reimbursements or other amounts that are due and owing to DBI as of the date of termination pursuant to the terms of this Agreement or any other agreement between the parties. Article 6—Cost of Administration 6.1 Plan Administrative Services Fees Employer shall pay DBI a fee for its services under this Agreement. This fee shall be payable in accordance with the fee schedule attached as Exhibit B. Monthly fees will be invoiced monthly and are due within thirty(30)days after the date of the invoice. 6.2 Compliance with Anti-Rebating Laws Employer represents that if someone other than Employer is paying DBI's fees on behalf of the Employer, such payment shall not violate any applicable anti-rebating laws. 6.3 Past Due Amounts Notwithstanding anything in this Agreement or any other agreement between the Parties to the contrary, if the Employer fails to pay DBI within the required time period any amount(except for amounts subject to a good faith dispute)that is due as a result of any product or service provided by DBI to the Employer under this Agreement or any other agreement between the Parties, including,without limitation, services provided with respect to flexible spending arrangements, health reimbursement arrangements, qualified transportation programs, individual premium reimbursement accounts or health savings accounts, DBI shall be permitted to deduct the undisputed past due amount from any funds held by DBI that were provided by the Employer pursuant to this Agreement or any other agreement between the parties with prior notice and with prior approval of the Employer.This right of offset shall be in addition to any other remedies that DBI may have in this Agreement or any other agreement between the parties with respect to such non-payment, including,without limitation, any right to terminate the Agreement, regardless of whether the past due amount is paid in full as a result of the offset rights provided herein. Article 7—Miscellaneous Provisions 7.1 Limitations. DBI shall: (a) Have no duty with respect to the funding of premiums by Employer or qualified beneficiaries who elect COBRA; (b) Not be liable for paying any premiums of a qualified beneficiary to a Carrier or the Employer to the extent that DBI did not receive the corresponding payment from the qualified beneficiary, Employer or third party; (c) Not be liable for any failure of Employer to remit to the Carriers of the Employer Plan any funds the Employer receives from DBI; (d) Not be liable for any failure of Employer to reconcile its Carrier billings to online reports provided by DBI through the Employer web portal; (e) Not be liable for any failure of Employer to modify its Carrier billing and notify Carriers of a COBRA continuant's termination from COBRA coverage when DBI remits premiums paid by continuants to Employer; (f) Not be responsible for failure of delivery of any notice mailed by DBI using the qualified beneficiary information provided to DBI by Employer; and �— 6 Discovery Benefits simplify' COBRA Administrative Services Agreement GPID 25345 Employer Tax ID 75-6000528 (g) Not be responsible for any loss or damage suffered by any participant, continuant,the Employer or the Employer Plan, should DBI fail to give a required notice because DBI did not receive notice of an event for which a notice was required or the proper address to which the notice was to be sent. 7.2 Audit Rights DBI agrees that the Employer shall, until the expiration of one (1)year after final payment under this Agreement,the right to inspect any COBRA compliance transactions, procedures, records and participant files relating to Employer's employees(and their spouses and dependents), at DBI's office and at a time reasonably acceptable to DBI, upon providing ten (10) business days advance written notice to DBI. 7.3 Relationship of the Parties Employer and DBI acknowledge and agree that DBI is retained under this Agreement as an independent contractor of the Employer to assist the Employer with its obligations to comply with the continuation coverage provisions of COBRA, and that DBI is not a fiduciary under ERISA and lacks any discretion hereunder. Employer agrees that use of or offset of amounts in the Custodial Account to pay for fees or other amounts due to DBI under this Agreement or any other agreement between the parties shall constitute an Employer action that is authorized by the Employer under this Agreement. Employer agrees that such actions are not discretionary acts of DBI and do not create fiduciary status for DBI. The parties hereto further acknowledge that DBI is an independent contractor and not a joint venturer with or partner, agent or employee of Employer. The parties further agree that DBI does not provide any legal, tax or accounting advice to the Plan and/or Employer. 7.4 Reliance by DBI (a) DBI shall provide the services in accordance with this Agreement based on Information that is provided to DBI by Employer, any designee or agent of Employer(as designated by Employer) and qualified beneficiaries. For this purpose, "Information"means all data, records and other information supplied to DBI, obtained by DBI or produced by DBI (based on data, records or other information supplied to, or obtained by, DBI) in connection with performing the services pursuant to this Agreement, regardless of the form of the Information (e.g., paper, oral, electronic etc.) or the manner in which the Information is provided to DBI. (b) Employer has authorized and instructed DBI in this Agreement to implement its standard administrative forms and procedures to provide services in accordance with this Agreement. DBI's standard administrative procedures may be revised by DBI at any time with thirty(30)days' notice. Employer acknowledges that DBI will rely upon representations by Employer set forth in this Agreement and communications made by or on behalf of Employer, by officials with authority previously designated by Employer, in effecting its obligations under this Agreement. DBI is entitled to rely on the most current Information in its possession when providing services under this Agreement. DBI is not responsible for any acts or omissions it makes in reliance on: (i)written direction or consent by Employer, any designee or agent of Employer(as designated by Employer)or a qualified beneficiary; or(ii) inaccurate, misleading or incomplete Information. Nothing in this Section 7.4(b)shall prevent either party from pursuing any rights that it may have under Section 7.6. (c) Employer and DBI agree that if Employer provides DBI with specific written instructions (in a form acceptable to DBI)to provide services in a manner other than in accordance with DBI standard forms and procedures, DBI may(but need not) comply with Employer's written instructions. 7.5 Online Employer Account In the event Employer accesses services provided by DBI online or through any mobile or other electronic devices("Online Account"), Employer is solely responsible for: (i)designating who is authorized to have access to the Online Account; (ii) safeguarding all of Employer's passwords, usernames, logins or other security features used to access the Online Account ("Online Account Access"); (iii) Employer's use of the Online Account under any usernames, logins or passwords; (iv)ensuring that use of the Online Account complies fully with the provisions of this Agreement; and (v)any unauthorized access, or use, of the Online Account caused by Employer's actions or inactions, including,without limitation, its failure to safeguard the Online Account or Online Account Access. Employer is solely responsible for the maintenance and routine review of computing and electronic system usage records (i.e., log files) and the security of its own data, data storage,computing devices, other electronic systems, and network connectivity. Employer acknowledges that DBI is not liable to Employer, 7 Discovery Benefits simplify:' COBRA Administrative Services Agreement GPID 25345 Employer Tax ID 75-6000528 Employer's employees or any other third-party for any consequences, losses,or damages resulting from unauthorized access or use of the Online Account as set forth in this section. 7.6 Responsibility of the Parties and Indemnification a) Subject to the limitations in Section 7.10, DBI will be liable to and will defend, indemnify and hold harmless Employer, and its respective officers, directors, employees, agents, representatives, successors and permitted assigns from and against any and all Charges, liability, damages, costs, losses and expenses, including attorney fees, disbursements and court costs, reasonably incurred by Employer in connection with any threatened, pending or adjudicated claim,demand, action, suit or proceeding by any third party which was caused solely and directly by DBI's willful misconduct, criminal conduct, material breach of the Agreement or violation of the HIPAA privacy or security rules related to or arising out of the services performed by DBI under this Agreement. b) Except as provided in (a)above, Employer will, to the extent permitted by law, be liable to and will defend, indemnify and hold harmless DBI, and its respective officers, directors, employees, agents, representatives, successors and permitted assigns from and against any and all Charges, liability, damages, costs, losses and expenses, including attorney fees, disbursements and court costs, reasonably incurred by DBI in connection with any threatened, pending or adjudicated claim, demand, action, suit or proceeding by any third party which was caused solely and directly by Employer's willful misconduct, criminal conduct, material breach of the Agreement or violation of the HIPAA privacy or security rules related to or arising out of the services performed by DBI under this Agreement. c) For purposes of this indemnification provision, "Charges"means: (i) excise taxes imposed under Code Section 498013, subject to the provisions of the aggregate limitations set forth in Code Section 4980B and the right of the assessed party to challenge the Internal Revenue Service with respect to all or part of the imposition of such excise taxes; and/or(ii) penalties (in an amount up to$110 per day)that are imposed by a court under Section 502(c)(1)of ERISA and that are paid. Charges shall not include the payment of the claims for benefits under the terms of the Employer Plan. d) Notwithstanding anything in this Section to the contrary, neither Party shall be entitled to indemnification under this Section in circumstances where the Charges sought hereunder result from: (i)the indemnifying Party(the"Indemnitor") following the written instruction of the Party seeking indemnification (the"Indemnitee"); (ii) reasonable reliance by the Indemnitor on information furnished by the Indemnitee; or(iii)the actions or inactions of the Indemnitor in circumstances where the Indemnitor requested, but did not receive, information or guidance from the Indemnitee,which information or guidance the Indemnitee is obligated to provide under the Agreement or which is within the sole control of the Indemnitee under the Employer Plan. e) The party seeking indemnification under(a) or(b)above must notify the indemnifying party within twenty(20)days in writing of any actual or threatened action,suit or proceeding to which it claims such indemnification applies. Failure to so notify the indemnifying party shall not be deemed a waiver of the right to seek indemnification, unless the actions of the indemnifying party have been prejudiced by the failure of the other party to provide notice within the required time period. f) In the event of a legal, administrative or other action arising out of the administration, processing or determination of a claim for Plan benefits which is filed or asserted against DBI ("Claim Litigation"), DBI may, at its election,select and retain its own counsel to protect its interest. DBI shall be responsible for payment of all legal fees and expenses reasonably incurred by it in defense of Claim Litigation unless the Claim Litigation is attributable to the Employers actions or inactions in which case the Employer,to the extent permitted by law, shall be responsible for payment of DBI's legal fees and expenses. DBI shall consult with the Employer before settling Claim Litigation, but DBI shall have the sole discretion to resolve Claim Litigation. DBI and the Employer shall cooperate fully with each other in the defense of Claim Litigation. In addition, nothing in this subsection (f)shall prevent DBI and/or the Employer from pursuing any rights that such party has under subsection (a)or(b)of this Section 7.6. g) Nothing in this agreement shall ever be construed so as to require Employer to create a sinking fund or to assess, levy and collect any tax to fund its obligation under section 7.6 of this agreement. 8 Discovery Benefits simplify.` COBRA Administrative Services Agreement GPID 25345 Employer Tax ID 75-6000528 7.7 Employer Plan Data a) DBI agrees to retain for eight(8)years Employer Plan records under this Agreement, including without limitation records of all assets and transactions involving the Custodial Account. Upon termination of this Agreement, DBI will maintain Employer's records in an electronic format up to eight(8)years. b) Following the Agreement's termination and provided all fees have been paid, DBI will cooperate with Employer(or Employer's subsequent service provider)to effect an orderly transition of DBI services provided under the Agreement and will release to Employer(or Employer's subsequent service provider), in DBI's standard format, a copy of all data, records and files regarding qualified beneficiaries within a reasonable time period following the termination date. All costs associated with the release of data, records, and files from DBI to Employer shall be paid by Employer. c) Upon termination of this Agreement, DBI will be entitled to retain a copy of all"Information" (as defined in Section 7.4), including any data, records and files released by DBI pursuant to Section 7.7(b), and will be entitled to continue to use and disclose such Information for claims,audit, legal and contractual compliance purposes to the extent permitted by law. 7.8 Health Plan Identifier Employer acknowledges and agrees that DBI does not, and shall not, have any responsibility for obtaining one or more health plan identifiers (HPID)for the Plan from the Enumeration System identified in 45 CFR§ 162.508 or for updating the Enumeration System with respect to the HPID. 7.9 Intellectual Property All materials, including,without limitation, documents, forms (including data collection forms provided by DBI), brochures,tip sheets, posters, and online content("Materials")furnished by DBI to Employer are licensed (not sold). Employer is granted a personal, non-transferable and nonexclusive license to use Materials solely for Employer's own internal business use. Employer does not have the right to copy, distribute, reproduce, alter, display, or use these Materials or any DBI trademarks for any other purpose. Employer agrees that(a) it will keep Materials confidential and will use commercially reasonable efforts to prevent and protect the content of Materials from unauthorized use and (b) its license to use Materials ends on the termination date of this Agreement. Upon termination, Employer agrees to destroy Materials or, if requested by DBI, return them to DBI. In no event shall either party be held liable for disclosing Confidential Information of the other that is required by law or court order. The party will notify the other within ten (10) business days of such request. 7.10 Limitation of Remedies In no event shall either Party be liable to the other for consequential, special, exemplary, punitive, indirect or incidental damages, including without limitation any damages resulting from loss of use or loss of profits arising out of or in connection with this Agreement,whether in an action based on contract, tort(including negligence)or any other legal theory whether existing as of the Effective Date or subsequently developed, even if the Party has been advised of the possibility of such damages. In addition, notwithstanding any other provision in this Agreement to the contrary, the maximum total liability of DBI to Employer shall be limited to direct money damages in an amount not to exceed the dollar amount that is available to cover such liability under the insurance policy or policies provided for in Section 7.19. This remedy is Employer's sole and exclusive remedy. 7.11 Entire Agreement This Agreement, including any Exhibits attached (including DBI's response to RFP 15-0222 Health Benefits Management), constitutes the entire contract between DBI and Employer and no modification or amendment shall be valid unless agreed to in writing by both parties. If there is an inconsistency between the terms of this Agreement and the terms of any prior agreement between the parties,the terms of this Agreement will control, unless otherwise provided in such other agreement. Any amendment to this Agreement must be in writing and signed by authorized representatives of both Parties. This Agreement may be signed in one or more counterparts,each of which shall be considered an original, but all of which shall constitute one and the same instrument. The provisions of this Agreement shall be binding upon and shall inure to the benefit of the parties hereto and their heirs, assigns and successors in interest. This Agreement may not be assigned without prior written agreement of the other Party. 7.12 Governing Law All questions with respect to the construction of this Agreement and the rights and liabilities of the parties except as otherwise provided, shall be determined in accordance with the laws of the State of Texas. 9 Discovery Benefits simplify."' COBRA Administrative Services Agreement GPID 25345 Employer Tax ID 75-6000528 7.13 COBRA COBRA means the Consolidated Omnibus Budget Reconciliation Act of 1985, as amended, and the related regulations and interpretations by the Internal Revenue Service and Department of Labor. The terms, "qualifying event"and"qualified beneficiary"shall have the meanings given to them in COBRA. 7.14 Severability If any provision of this Agreement is determined by a court to be unenforceable or invalid, such determination shall not affect any other provision,each of which shall be construed and enforced as if such invalid or unenforceable provision were not contained herein. 7.15 Survival Sections 2.8 and 2.15,Article 4, Sections 5.3 and 5.6, Section 6.2 and Article 7 shall survive the termination of this Agreement. 7.16 Notice DBI shall not be bound by any communication until it has been received at its office at 4321 20th Avenue South, Fargo, ND 58103 or at such other address as it has specified to the Employer. The Employer shall not be bound by any communication until it has been received at the address shown below or such other address as it has specified by Employer to DBI with copy to the City Attorney's Office at the same address. 7.17 Disputes The parties shall cooperate in good faith to resolve any and all disputes (each, a"Dispute")that may arise under or in connection with this Agreement. The existence or resolution of any Dispute as to a matter shall not reduce or otherwise affect the payment or performance by Employer its obligations under this Agreement as to any other matter, unless pursuant to the terms of any such resolution. Employer and DBI shall attempt in good faith to resolve any Dispute arising out of or relating to this Agreement promptly by negotiation between executives who have authority to settle the controversy and who are at a higher level of management than the persons with direct responsibility for administration of this Agreement. Either Party may give the other Party written notice of any Dispute not resolved in the normal course of business. Within fifteen (15)days after delivery of the notice,the receiving Party shall submit to the other Party a written response. Any notice and the response shall each include: (i)a statement of each Party's position and a summary of arguments supporting that position; and (ii)the name and title of the executive who will represent that Party and of any other person who will accompany the executive. Within thirty (30) days after delivery of the disputing Party's notice,the executives of the parties subject to the dispute shall meet at a mutually acceptable time and place, and thereafter as often as they reasonably deem necessary to attempt to resolve the Dispute. All reasonable requests for information made by one Party to the other will be honored. 7.18 Force Majeure Neither DBI nor Employer, as applicable under the circumstances, shall be liable or deemed to be in default for failure to perform or delay in the performance of any of their respective obligations under this Agreement(other than the Employer's obligation to provide funding for claims or pay service fees)to the extent that such failure or delay results from any act of God; military operation;terrorist attack;widespread and prolonged loss of use of the Internet; national emergency, government restrictions or disruption of the financial markets. 7.19 Insurance During the term of this Agreement, DBI shall maintain general, professional, and cyber liability insurance with policy limits of not less than$1,000,000 per occurrence and in the aggregate for the purpose of providing coverage for claims arising out of the performance of its services under this Agreement. Upon request, DBI shall provide Employer with a certificate or certificates of insurance reflecting such insurance coverages and naming Employer as an additional insured to the general liability policy. 7.20 Tax Obligations The Plan and/or the Employer,to the extent permitted by law, is responsible for any state or federal tax, fee, assessment, surcharge and/or penalty imposed, assessed or levied against or with respect to the Plan including those imposed pursuant to the PPACA, as amended from time to time. This includes the funding, remittance and determination of the amount due for the PPACA required taxes and fees. In the event that DBI is required to pay or elects to pay any such tax,fee, assessment, surcharge and/or penalty, DBI shall report the payment to the Employer and the Employer shall,to the extent permitted by law, promptly reimburse DBI for such amount(or for Employer's proportionate share of such amount, as determined by DBI), 10 Discovery Benefits simplify:' COBRA Administrative Services Agreement GPID 25345 Employer Tax ID 75-6000528 except as provided in Section 7.6. This payment shall be in addition to the Plan administrative service fees described in Section 6.1. The Employer is at all times responsible for the tax consequences in the establishment and operation of the Plan. 7.21 Waiver It is understood and agreed that by execution of this Agreement, Employer does not waive or surrender any of its governmental powers. 7.22 Miscellaneous Any number of counterparts of this Agreement may be signed and delivered, each of which shall be considered an original and all of which,together, shall constitute one and the same instrument. Nothing express or implied in this Agreement is intended to confer, and nothing herein shall confer, upon any person other than the parties hereto any rights, remedies, obligations or liabilities whatsoever. Where the context of the Agreement requires, the singular shall include the plural and vice versa, and the masculine gender shall include the feminine. If any provision of this Agreement is held to be invalid, illegal or unenforceable, the validity, legality and enforceability of the remaining provisions shall not in any way be affected or impaired. Authorization This Agreement, including any attachments or other exhibits, is accepted and agreed to by the Parties as of the effective date of this Agreement. Si or mployer by: Signed for iscove Benefits by: S san anis,Assistant Ci y Manager Suzann r, Chief Compliance Officer/EVP 1000 Throckmorton Street, Fort Worth, TX 76102 4321 Avenue S, Fargo, ND 58103 M&C: C-27335 Date:June 16, 2015 Form 1295 Certification No. 4PPROVED AS TO FORM AND LEGALITY, etatant City Att ne .Ile- - �? 0000a% a by $o City SecmtwY OFFMAL RECORD Discovery Benefits simplify." r-T. mo' lrr,i y 'TH COBRA Administrative Services Agreement GPID 25345 Employer Tax ID 75-6000528 Exhibit A Covered Services A.1 Covered Plans. The Plans covered by this Agreement include the following: Plans Plans Covered Under This Agreement Major MedicalI AI Group Dental Group Vision II Health Flexible Spending Account(FSA) Health Reimbursement Arrangement(HRA) Rx Plans Employee Assistance Program (EAP) LZIq Other(please define) F] r 12 Discovery Benefits simplify." COBRA Administrative Services Agreement GPID 25345 Employer Tax ID 75-6000528 Exhibit B COBRA Fee Schedule COBRA Administrative Fees Qualifying Event Fee $28.00 per Qualifying Event (2%administrative fee retained bY Discove yNN ZZ -- Initial Notification $2.00 per notice Takeover Notification $15.00 per notice 777'y a COBRA Notification and Election Included HIPAA Certificates Included Certificate of Coverage and HIPPA Portability Rights) Election Tracking Included Premium Billing and Remittance Included Termination Tracking and Notification Included 77 Postage and Printing Included for standard mailings and materials (Additional charges may apply for non-standard and/or ex edited requests.) Additional Open Enrollment Materials A handling fee of$1.00 per page (duplex)will apply for additional materials(additional materials are limited to 25 duplexed pages that include DBI's standard open enrollment/rate change letter). Minimum Monthly Fee $150 (Applies only if the Qualifying Event and Initial Notification fees are less than this amount. Discovery does not charge implementation,set-up or renewal fees. Fees are listed net of commissions. Monthly administrative fees are guaranteed for three years. Discovery reserves the right,with thirty(30)days advance written notice to Employer,to increase fees at any time that are caused by Federal postal rate increases, increases in bank fees, or that are due to Federal legislative changes. 13 Discovery Benefits simplify." Business Associate Agreement cPID 26346 THIS PAGE INTENTIONALLY LEFT BLANK 14 Discovery Benefits simplify., CERTIFICATE OF INTERESTED PARTIES FORM 1295 10f1 Complete Nos.1-4 and 6 if there are interested parties. OFFICE USE ONLY Complete Nos.1,2,3,5,and 6 if there are no interested parties. CERTIFICATION OF FILING 1 Name of business entity filing form,and the city,state and country of the business entity's place Certificate Number: of business. 2016-4506 Discovery Benefits, Inc. Farg, ND United States Date Filed: 2 Name of governmental entity or state agency that is a party to the contract for which the form is 01/21/2016 being filed. City of Fort Worth Date Acknowledged: 3 Provide the identification number used by the governmental entity or state agency to track or identify the contract,and provide a description of the goods or services to be provided under the contract. 47050 Flexible Spending Account, Health Savings Account and COBRA Administrative Services 4 Nature of interest(check applicable) Name of Interested Party City,State,Country(place of business) Controlling Intermediary Noridian Mutual Insurance Company Fargo, ND United States X 5 Check only if there is NO Interested Party. ❑ 6 AFFIDAVIT I swear,or affirm,under penalty of perjury,that the above disclosure is true and correct. KIRSTEN STIENING Notary Public State of North Dakota My Commission Expires,April 25,2020 S' e of authorized agent of contracting business entity - Wwwwwwww AFFIX NOTARY STAMP/SEAL ABOVE rp� �J Sworn to and subscribed before me,by the said Sc 2"z'-we ° e ti/' this the a471- day of G�1GC� 20J (o_,to certify which,witness my hand and seal of office. Signature of officer administ ring oath Printed name of officer administering_yath T' e of officer administering h Forms provided by Texas Ethics Commission www.ethics.state.tx.us Version V1.0.34416 M&C Review Page 1 of 2 Official site of the City of Fort Worth,Texas CITY COUNCIL AGENDA FoRy T'� RTIJ COUNCIL ACTION: Approved on 6/16/2015 DATE: 6/16/2015 REFERENCE **C-27335 LOG NAME: 14FSAHSACOBRA16 NO.: CODE: C TYPE: CONSENT PUBLIC NO NO SUBJECT: Authorize Execution of a Three-Year Contract with Discovery Benefits, Inc., for Administration of the City's Flexible Benefit Plan, Health Savings Account and COBRA in the Amount of Up to $294,714.00 (ALL COUNCIL DISTRICTS) RECOMMENDATION: It is recommended that the City Council authorize the execution of a three-year contract with Discovery Benefits, Inc., for administration of the City's Flexible Benefit Plan, Health Savings Account and COBRA in the amount of up to $294,714.00. DISCUSSION: The purpose of this Mayor and Council Communication is to seek authorization from the City Council to enter into a contract with Discovery Benefits, Inc. (Discovery Benefits), for administration of the City's Flexible Benefit Plan, Health Savings Account and COBRA. The total cost of the three-year contract will not exceed the amount of$294,714.00. The rates for the two one-year renewal options are guaranteed and the annual cost will be dependent upon employee enrollment. Staff determined it would be in the City's best interest to ensure that it was getting the best overall product and price by going out to the market and giving all providers the opportunity to compete for the City's business. On February 17, 2015, a Request for Proposal (RFP) was issued requiring interested vendors to submit proposals by April 2, 2015. The RFP was designed to solicit proposals for the following services individually or in combination with each other: (1) Third Party Administrator(TPA) for the City's self-funded Medical and Disease Management Program; (2) Pharmacy Benefit Management (PBM); (3) Flexible Spending Account (FSA), Health Saving Accounts (HSA) and COBRA administration; (4) Employee Assistance Program, and (5) Medicare Advantage. In April 2015, an Ad Hoc Selection Committee (Committee) was formed that included one retiree, five active employees- one from the Water Department, two from the Health Benefits Advisory Committee (HBAC) and two from the Human Resources Department. The Committee was active in the analysis of the proposals. Human Resources staff and the City's benefits consultant, A.J. Gallagher Benefits Services, facilitated the RFP review and Committee meetings. Thirty-four vendors were solicited from the Purchasing Division database system; five vendors responded representing five proposals. After a lengthy review process, the Committee by consensus agreed that Discovery Benefits provided the best overall quality of service and pricing. Discovery Benefits also introduced a new service provided in their COBRA product that can aid in reducing the City's future COBRA enrollment and future claims cost attributed to COBRA participants. Discovery Benefits affords the stability of the administration of the flexible benefit plans, savings accounts and COBRA. The associated cost and fees are as follows: A. Flexible Benefit Plan $3.85 per participant per month - administration for the three Flexible Benefit Plans that will provide reimbursements to active employees for allowable medical, dental and vision benefits, dependent care, and adoption assistance. Average number of participants is 1,473. Total Estimated Contract Cost-$204,159.00; average annual cost-$68,053.00 B. Health Saving Account http://apps.cfwnet.org/council_packet/mc review.asp?ID=21204&eouncildate=6/16/2015 2/1/2016 M&C Review Page 2 of 2 $1.95 per participant per month -administration for the health (medical, dental, vision) benefits payments for the active employees and non-Medicare retirees enrolled in the City's Consumer Health Choice Plan. Average number of participants is 765. Total Estimated Contract Cost-$53,703.00; average annual cost-$17,901.00 C. COBRA Administration $31.02 per qualifying event plus new hire notification and managing COBRA continuants billing and payments.Average number of qualifying events is 396. Total Estimated Contract Cost is -$36,852.00; average annual cost-$12,284.00 Open enrollment for the 2016 Benefit Plans is scheduled to begin October 8, 2015. The Calendar Year average cost for the contract is $98,238.00. The proposed Fiscal Year 2016 budget includes funds for this contract through September 2016. An appropriation request for the remainder of Calendar Year 2016 will be included as part of the Fiscal Year 2017 budget process. Authority for the remaining fiscal years that are encompassed by the Agreement will be requested annually as part of the overall budget process and the contract will include a standard fiscal funding out clause that would comply with state law requirements by allowing the City to terminate the Agreement without penalty, if in the future, the Council elects not to appropriate funds for the Flexible Benefit Plans, Health Savings Accounts and COBRA Administration to continue. AGREEMENT TERMS - Upon City Council approval, the initial three-year term of this contract shall begin on January 1, 2016 and expire on December 31, 2018. The contract may be renewed for up to two successive one-year terms at the City's option. This action does not require specific City Council approval, provided that the City has appropriated sufficient funds to satisfy the City's obligations during the renewal term. M/WBE OFFICE -A waiver of the goal for MBE/SBE subcontracting requirements was requested by the Department and approved by the M/WBE Office, in accordance with the BDE Ordinance, because the purchase of goods or services from source(s)where subcontracting or supplier opportunities are negligible. FISCAL INFORMATION/CERTIFICATION: The Financial Management Services Director certifies that funds will be included in the City Manager's proposed budget for Fiscal Years 2015 -2016 for the Group Health and Life Insurance Fund. Upon approval of the above recommendations and upon the adoption of the Fiscal Year 2015 -2016 Budget by the City Council to include the above recommendations, funds will be available in the Fiscal Year 2016 operating budget, as appropriated. Prior to expenditure being made, the Human Resources Department has the responsibility to validate the availability of funds. TO Fund/Account/Centers FROM Fund/Account/Centers 60109 5310101 0148540 $468.00 60109 5310101 0148520 $97,770.00 Submitted for City Manager's Office by; Susan Alanis (8180) Originating Department Head: Brian Dickerson (7783) Additional Information Contact: Margaret Wise (8058) ATTACHMENTS http://apps.cfwnet.org/council_packet/mc review.asp?ID=21204&councildate=6/16/2015 2/1/2016