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Hcp alert october_2012_v4[1]

  1. 1. HUMAN CAPITAL PRACTICEALERT:HEALTH CARE REFORM BILLOctober 2012 www.willis.comPPACA DETERMINATION OF FULL-TIME EMPLOYEES – INTERIM SAFEHARBOREmployers have been anxiously awaiting guidance on how to determine full-time status for theiremployees under the Patient Protection and Affordable Care Act (PPACA) – a determinationcentral to the “pay or play” and “affordability” mandates under PPACA and necessary for manyemployers in their planning.BACKGROUNDBeginning in 2014, PPACA requires employers with 50 or more full-time employees (or theequivalent) to offer affordable health coverage that meets minimum requirements to all full-timeemployees or be subject to potential penalties.The IRS and Department of Labor issued long-awaited interim guidance on August 31, 2012 toassist employers with their implementation. Notices 2012-58 and 2012-59 (also referred to bythe DOL as DOL Technical Release No. 2012-02) offer safe harbors (with new nomenclatureof course) for employer determinations of whether an employee is full-time for purposes of thepay or play and affordability mandates under PPACA and the application of the 90 day maximumwaiting period. The guidance was not issued as regulations so it does not have the force of law.The agencies have solicited additional public comments. There will likely be changes to the rulesafter the appropriate administrative process is completed.Employers can rely on the safe harbor until at least the end of the 2014 plan year. In fact, if thestandard measurement periods (see below for more explanation) extend far enough into thecalendar year, the safe harbor may apply beyond the 2014 plan year. Employers that use the safeharbor will have some certainty that their determinations of full-time status will be respected.Note that the guidance is not mandatory but optional. Therefore, employers who find these rulestoo onerous can use other rules that meet the general requirements under the statute(presumably under a reasonable, good faith standard) at least until regulations are published.Like much of the guidance on PPACA from the federal agencies, there is both good and bad newsfor employers and their administrative staffs.FULL-TIME EMPLOYEE DETERMINATIONThe notice permits employers the option to use a look-back period of up to 12 months todetermine whether new variable-hour employees or seasonal employees are full-timeemployees, without being subject to a penalty under §4980H of the Internal RevenueCode (IRC).
  2. 2. PAY OR PLAY MANDATE IN THE IRCSection 4980H of the Internal Revenue Code was added by PPACA and requires largeemployers (those with the equivalent of 50 or more full-time employees) to offer“affordable,” “minimum essential coverage” or pay a penalty. The penalty is oftenreferred to as the “pay or play” penalty, but the IRC refers to this as the “sharedresponsibility” requirement. If an employer with 50 or more full-time employees (or the equivalent) fails to offer “minimum essential coverage” to even one full-time employee, and that one employee obtains coverage via a state-based exchange, and the individual receives tax credits for the purchase of that coverage, the employer is subject to an annual penalty of $2,000 for all full-time employees (less the first 30). The penalty is determined monthly and applies to all full-time employees, whether or not they have coverage under the employer-sponsored plan. If an employer offers “minimum essential coverage” to all full-time employees, but the coverage is not “affordable,” the employer is subject to a penalty of $250 per month for each full-time employee (annually $3,000) who was not offered “affordable” coverage, obtains coverage via a state-based exchange and receives tax credits for the purchase of that coverage. Affordability means that at least one coverage option that meets the minimum essential benefits requirements has an employee contribution for employee only coverage of no more than 9.5% of the employee’s household income. Here, there is an aggregate maximum penalty of $2,000 times all full-time employees (less the first 30). Employers have rightly asked how they can be expected to know the employee’s household income to make an affordability determination. In response, the IRS issued a safe harbor that permits an employer to make a determination using the employee’s federal taxable wages in Box 1 of the W-2. While that adds some certainty in administration, it will likely understate or overstate the actual household income, sometimes substantially.ONGOING EMPLOYEESEMPLOYERS SELECT THE STANDARD MEASUREMENT PERIODOngoing employees are those that have been working for the employer for at least one“standard measurement period.” Each employer may establish a standard measurementperiod of three to 12 months to determine full-time status. The employer can use a calendaryear, or any other start and end dates for the standard measurement period, as long as thedetermination is made on a uniform and consistent basis for all employees in the samecategory (See: Permitted Employee Categories for Measurement Periods).The determination is made on an individual basis. So, an employer who restricts eligibilityto full-time employees must count hours for all employees who may average less than 30hours a week.IF THE EMPLOYEE IS A FULL-TIME EMPLOYEE DURING THE STANDARDMEASUREMENT PERIODOnce the employer determines the standard measurement period, the employer willdetermine if an employee worked an average of 30 hours per week during that period. If so,then the employer must treat the employee as a full-time employee during the subsequent“stability period” regardless of the number of hours worked during the stability period. Forthis purpose, the stability period must be at least six months but can be no shorter than thestandard measurement period that applied to that employee. 2 Willis North America • 10/12
  3. 3. IF THE EMPLOYEE IS NOT A FULL-TIME EMPLOYEE No guidance is provided about individualsDURING THE STANDARD MEASUREMENT PERIOD who might move from one category toIf the employer determines that an employee has averaged fewer another; however, a conservativethan 30 hours per week during the standard measurement period and interpretation would apply the measurementis therefore not a full-time employee, then the employer can treat period that has the more favorable result withthat employee as a part-time employee during the subsequent regard to eligibility for coverage.“stability period” regardless of the number of hours worked duringthe stability period. In this circumstance, the stability period can be ADMINISTRATIVE PERIODas long as the standard measurement period but no longer. In order to make a determination of the employee’s status AND have time to administer the plan properly based on that status, the guidance provides up to a 90-dayPERMITTED EMPLOYEE CATEGORIES FOR administrative period safe harbor AFTER theMEASUREMENT PERIODS standard measurement period. However, it will have to overlap with the prior stabilityThe permissible categories of employee for this purpose are: period in order to prevent gaps in coverage (assuming the individual was previously full-1) Collectively bargained (i.e., union) employees and non- time during that stability period). collectively bargained employees2) Salaried and hourly employees THE FOLLOWING EXAMPLE IS PROVIDED BY THE3) Employees of different entities (such as different subsidiaries) GUIDANCE: The Acme Co. has a 12-month4) Employees located in different states stability period from January 1 to December 31, 2014. Based on prior standard measurementOther categories of employees might also qualify (such as periods, the employees who are full-time haveemployees in different divisions); however, the notice only identifiesthese four categories as qualifying for the safe harbor. coverage during that period while part-time employees do not. The standard measurementEmployers who want to minimize the number of full-time period runs from October 15, 2012 to theemployees will likely use separate categories. following October 14, 2013. That permits Acme to have an administrative period between theFor many employers, a 12-month measurement period would result end of the standard measurement period andin the fewest number of full-time employees as that would require the next stability period that follows. Both thethe most consistent status over a long period of time. However, it standard measurement period and the stabilitywould also result in a longer stability period for those employees period can each be 12 months. Employeesdeemed full-time during the measurement period (meaning that who are full-time as of the October 14, 2013coverage would have to be offered even if they worked fewer hours standard measurement period must haveduring the stability period). For other employers, a shorter affordable minimum essential coveragemeasurement period may be the better option, since it will lead tothe shortest stability period for those employees deemed full-time. offered to them as of January 1, 2014 for theRetail operations, or perhaps a ski resort, where activity is highly entire year, while employees who are not full-seasonal, are examples of employers who might benefit from a time do not have to be offered that coverageshorter measurement period. until they meet the full-time standards during a standard measurement period. This givesAll employers who restrict eligibility to full-time employees should the employer a 2 ½-month administrativestart tracking hours and reviewing employment patterns in order to period to add the employee to the plan.identify the measurement and stability periods that best meet theirneeds and objectives. 3 Willis North America • 10/12
  4. 4. HOW CAN EMPLOYERS DETERMINE IF AN EMPLOYEE WORKS ANAVERAGE OF 30 HOURS PER WEEK? The guidance is short on VARIABLE-HOUR AND SEASONALspecificity and finality. That is still the case, but there is an EMPLOYEES DEFINEDadditional hint. The notice, in a footnote, states that earlierguidance indicated that the yet-to-be-issued regulations will An employee is a variable-hour employee if,propose that an individual who works 130 hours in a calendar based on the facts and circumstances on themonth will be treated as working an average of 30 hours per date the employee begins providing services to the employer (the start date), it cannot beweek and will therefore be a full-time employee. This notice determined that the employee is reasonablyseems to be more definitive regarding that standard. While expected to work an average of at least 30there is still no guidance upon which employers can rely, the hours per week. (The 30 hours per week averageuse of 130 hours per calendar month is at least an option for is the statutory definition of full-time employeeemployers to use for planning purposes. . in PPACA.)NEW EMPLOYEES A new employee who is expected to work initially at least 30 hours per week may still be a variable-hour employee if, based on the factsDETERMINATION MADE BY EMPLOYER BASED ON and circumstances at the start date, the periodREASONABLE EXPECTATIONS of employment at more than 30 hours per week is reasonably expected to be of limited durationIf an employee is reasonably expected at his or her start date and the employer does not reasonably expectto work full-time, the employer would treat that employee as a the employee to work an average at least 30full-time employee and offer coverage no later than the end of hours per week over the initial measurementthe 90-day waiting period (see below). Similarly, if an period selected by the employer.employee is reasonably expected at his or her start date to For example, a variable-hour employee wouldwork part-time (fewer than 30 hours a week), the employer include a retail worker hired at more than 30would treat that employee as a part-time employee, until and hours per week for the holiday season. Thatunless her hours of work changed. However, Notice 2012-58 employee is reasonably expected to continuedoes not provide any exception based on the scheduled hours working after the holiday season but is notof work, so all part-time employees excluded from coverage reasonably expected to work at least 30 hoursshould be tested using the hours counting rules. per week for the portion of the initial measurement period remaining after the holidayVARIABLE-HOUR AND SEASONAL EMPLOYEES season, so that it cannot be determined at the start date that the employee is reasonablyOf course, whether new variable-hour and seasonal employees expected to average at least 30 hours per weekqualify for eligibility will be more difficult to determine given during the initial measurement period. So that employee would be a variable employee and thetheir schedules. Therefore, selection of a standard measurement periods above regarding newmeasurement period is even more crucial given the variability. variable-hour employees would apply.In such cases, an employer may use both a measurementperiod of three to 12 months and an administrative period of The notice confirms that there is no specificup to 90 days (the same as allowed for ongoing employees). definition of seasonal employees in PPACA withHowever, there is a slight difference here. The measurement respect to determining full-time status.period and the administrative period combined may not However, there are other definitions elsewhereextend beyond the last day of the first calendar month in Department of Labor regulations. Noticebeginning on or after the one-year anniversary of the 2012-58 permits employers to use a reasonable,employee’s start date (totaling, at most, 13 months and a good faith interpretation of the term “seasonalfraction of a month). employee;” but, as identified in the examples, to qualify for the safe harbor, an employer must use the same measurement and stability period rules as apply to variable-hour employees. 4 Willis North America • 10/12
  5. 5. INITIAL MEASUREMENT PERIOD AND ASSOCIATED STABILITY PERIOD For example, an employer with a calendarFor variable-hour and seasonal employees, employers are permitted year standard measurement period that alsoto determine whether the new employee is a full-time employee uses a 12-month initial measurement periodusing an “initial measurement period” of between three and 12 beginning on the employee’s start date wouldmonths (as selected by the employer).The employer measures the test a new variable-hour employee for full-hours of service completed by the new employee during the initial time status, first based on the initialmeasurement period and determines whether the employee measurement period and again based on thecompleted an average of 30 hours of service per week or more during calendar year standard measurement periodthis period. Stability periods are determined in the same way as (if the employee continues in employment forongoing employees. that entire standard measurement period) beginning on January 1 of the year after theIF A NEW VARIABLE-HOUR OR SEASONAL EMPLOYEE IS DETERMINED TO BE A start date. So, a variable-hour employee withFULL-TIME EMPLOYEE the employee is treated as a full-time employee a February 12, 2014 start date would have anfor a period of six consecutive calendar months or, if greater, the initial measurement period of February 12,length of the initial measurement period. The guidance states that 2014 through February 11, 2015, and a“The stability period for such (new) employees must be the same as standard measurement period of January 1,the stability period for ongoing employees.” So, an employer that 2015 through December 31, 2015.wants to be sure they fall within the safe harbor will want to use thestability period for ongoing employees if it is longer than the initial An employee determined to be a full-timemeasurement period. employee during an initial measurement period or standard measurement period mustIF A NEW VARIABLE-HOUR OR SEASONAL EMPLOYEE IS DETERMINED NOT TO be treated as a full-time employee for theBE A FULL-TIME EMPLOYEE the employer is permitted to treat the entire associated stability period. This is theemployee as not a full-time employee for up to one month longer case even if the employee is determined to bethan the initial measurement period but no longer than the a full-time employee during the initialremainder of the standard measurement period (plus any associated measurement period but determined not toadministrative period) in which the initial measurement period ends. be a full-time employee during theIn these circumstances, allowing a stability period to exceed the overlapping or immediately followinginitial measurement period by one month is intended to give standard measurement period. In that case,additional flexibility to employers that wish to use a 12-month the employer may treat the employee as not astability period for new variable-hour and seasonal employees and an full-time employee only after the end of theadministrative period that exceeds one month. stability period associated with the initial measurement period. Thereafter, theTRANSITION FROM NEW EMPLOYEE RULES employee’s full-time status would be determined in the same manner as that of theTO ONGOING EMPLOYEE RULES employer’s other ongoing employees.Once a new employee has been employed for an entire standard In contrast, if the employee is determined notmeasurement period, the employee must be tested for full-time to be a full-time employee during the initialstatus at the same time and under the same conditions as other measurement period, but is determined to beongoing employees. 5 Willis North America • 10/12
  6. 6. a full-time employee during the overlapping or immediately following standardmeasurement period, the employee must be treated as a full-time employee for the entirestability period that corresponds to that standard measurement period (even if that stabilityperiod begins before the end of the stability period associated with the initial measurementperiod). Thereafter, the employee’s full-time status would be determined in the samemanner as that of the employer’s other ongoing employees.OPTIONAL ADMINISTRATIVE PERIOD FOR NEW EMPLOYEESEmployers may also add an administrative period to the initial measurement period beforethe start of the stability period. The administrative period may not exceed 90 days andincludes all periods between the start date of a new variable-hour or seasonal employee andthe date the employee is first offered coverage under the employer’s group health plan, otherthan the initial measurement period.For example, if the employer begins the initial measurement period on the first day of thefirst month following a new variable-hour or seasonal employee’s start date, the periodbetween the employee’s start date and the first day of the next month must be taken intoaccount in applying the 90-day limit on the administrative period. Similarly, if there is aperiod between the end of the initial measurement period and the date the employee is firstoffered coverage under the plan, that period must be taken into account in applying the 90-day limit on the administrative period.There is a limit on the combined length of the initial measurement period (of up to 12months) plus any administrative period (of up to 90 days) applicable for a new variable-houror seasonal employee. Combined, those periods cannot extend beyond the last day of thefirst calendar month beginning on or after the first anniversary of the employee’s start date.For example, if an employer uses a 12-month initial measurement period for a new variable-hour employee, and begins that initial measurement period on the first day of the firstcalendar month following the employee’s start date, the period between the end of the initialmeasurement period and the offer of coverage to a new variable-hour employee who worksfull-time during the initial measurement period must not exceed one month. So, in thisexample, a variable-hour employee with a February 12, 2014 start date would have an initialmeasurement period of March 1, 2014 through February 28, 2015 and if determined to be afull-time employee, coverage must start no later than April 1, 2015.EXAMPLES OF NEW VARIABLE-HOUR EMPLOYEES WITHAN ADMINISTRATIVE PERIODIn these examples the new employee is a new variable-hour employee, and the employer haschosen to use a 12-month standard measurement period for new employees commencing onthe start date, and, a 12-month measurement period for ongoing employees starting October15. Both new and ongoing employees have a 12-month stability period: For new hires, coverage starts the first of the calendar month that is not more than 13 months after hire For ongoing employees, coverage starts the subsequent January 1. 6 Willis North America • 10/12
  7. 7. Thus, for ongoing employees, during the Acme waits until August 1, 2015 to enroll her in coverage, Acmeadministrative period from October 15 does not satisfy the standards for the safe harbor. To meet thethrough December 31 of each calendar year, terms of the safe harbor, the coverage would have to be offeredthe employer continues to offer coverage to by July 1.employees who qualified for coverage for thatentire calendar year based upon working an EXAMPLE 2 – CONTINUOUS FULL-TIME EMPLOYEEaverage of at least 30 hours per week during Same as above but now Acme tests Betty as an ongoing employeethe prior standard measurement period. In based on her hours from October 15, 2014 through October 14,these examples, the employer offers health 2015 (Acme’s first standard measurement period that beginsplan coverage only to full-time employees after her start date). Acme will pass the test if Betty works an(and their dependents). average of 30 hours a week during that period and Acme offers her coverage July 1, 2016 through December 31, 2016. (BettyEXAMPLE 1 – 12-MONTH INITIAL already has coverage for the period of January 1, 2016 throughMEASUREMENT PERIOD June 30, 2016, because that period is covered by the initialFOLLOWED BY 1+ PARTIAL-MONTH stability period following the initial measurement period, duringADMINISTRATIVE PERIOD which she was already determined to be a full-time employee.)Acme Industries hires Betty, Alice and Joanon May 10, 2014. Each works a variable-hour EXAMPLE 3 – INITIALLY FULL-TIME EMPLOYEE,schedule. The initial measurement period is BECOMES NON-FULL-TIME EMPLOYEEMay 10, 2014, through May 9, 2015. Alice already has coverage through June 30, 2016 based on her initial testing period. Acme again tests her as an ongoingBetty works an average of 30 hours per week employee based on her hours from October 15, 2014 throughduring this initial measurement period. Acme October 14, 2015 (Acme’s first standard measurement period thatoffers coverage to Betty as a full-time begins after Alice’s start date). If she works an average of 28employee during the stability period that runs hours a week during the period October 15, 2014 through Octoberfrom July 1, 2015 through June 30, 2016 (after 14, 2015, Acme must continue to offer coverage to Alice throughthe administrative period from May 9 through June 30, 2016 (based on the initial testing period result) but isJune 30). NOT required to offer her coverage for the period of July 1, 2016 through December 31, 2016.Since Betty works an average of 30 hours perweek during her initial measurement period EXAMPLE 4 – INITIALLY NON-FULL-TIME EMPLOYEEthat did not exceed 12 months, and there was Joan only works an average of 28 hours per week during the periodan administrative period totaling not more from May 10, 2014 through May 9, 2015 (her initial measurementthan 90 days; and the combined initial period). Acme need not offer coverage to her for the remainder ofmeasurement period and administrative 2015. However, Acme must test Joan again as an ongoingperiod did not last beyond the final day of the employee for the first standard measurement period followingfirst calendar month beginning on or after her her employment start date (October 15, 2014 through October 14,one-year anniversary, Acme complied with 2015 in our example). If Joan works an average of 30 hours perthe pay or play mandate. week during the October 15, 2014 to October 14, 2015 period, Acme must offer her coverage starting January 1, 2016 (the firstAcme must test Betty again based on the stability period following the standard measurement period).period from October 15, 2014 through October14, 2015 (Acme’s first standard measurementperiod that begins after Betty’s start date). EXAMPLE OF SEASONAL EMPLOYEEHowever, if the total Initial Measurement EXAMPLE 1 – 12-MONTH INITIAL MEASUREMENTPeriod plus the Administrative Periods PERIOD; 1+ PARTIAL MONTH ADMINISTRATIVE PERIOD Infinity Industries runs a ski resort and offers health planexceeds the first day of the month following coverage only to full-time employees (and their dependents).Betty’s anniversary, the plan would not Infinity hires Stan, a ski instructor, on November 15, 2014 andcomply. So, in this case Acme hires her May10, 2014 and her initial measurement period expects him to work through March 15, 2015. Infinityruns from June 1, 2014, through May 31, 2015. determines that Stan is a seasonal employee based upon aShe works an average of 30 hours per week reasonable good faith interpretation of that term. His initialduring this initial measurement period. If measurement period runs from November 15, 2014, through 7 Willis North America • 10/12
  8. 8. November 14, 2015 and he works 60 hours per week from November 15, 2014 through March 15, 2015. However, since heis not reasonably expected to average 30 hours per week for the 12-month measurement period, Infinity does not treatStan as a full-time employee and does not offer him coverage at hire. Coverage will start January 1, 2016 if Stan averages30 hours a week. So, the initial measurement period is not more than 12 months (and combined with the administrativeperiod does not extend beyond the first month beginning after his anniversary), thus Infinity complies with the safeharbor.NINETY-DAY WAITING PERIODGroup health plans may not require a waiting period that exceeds 90 days before coverage is effective for employees anddependents who are otherwise eligible for the plan. The plan can still have other eligibility requirements, such as beingin an eligible job classification or achieving job-related licensure requirements specified in the plan’s terms, unless thecondition is designed to avoid compliance with the 90-day waiting period limitation.The requirement is based on eligibility, not the employee’s actual election, so the plan will still comply with therequirement even if employees take additional time to elect coverage.If the plan requires full-time status for eligibility and it cannot be determined that a newly hired employee is reasonablyexpected to regularly work full-time, the plan may take a reasonable period of time to determine whether the employeemeets the plan’s eligibility condition. That period can be as long as the measurement period described above. Thewaiting period cannot exceed 90 days AFTER the measurement period. Therefore, employers can use the longest timeperiod described above for the determination of the employee’s full-time status and still meet the 90-day waiting periodlimitation if coverage is effective no later than 13 months from the employee’s start date, plus the time remaining (if any)until the first day of the next calendar month.CONCLUSIONThe notices provide some much needed assistance to employers to begin planning for 2014. Employers may rely on therules in the notice through 2014. That means measurement periods will last through 2014 and could extend to stabilityperiods that last into 2016. The Notice offers an explicit safe harbor. The additional reliance a safe harbor provides islikely something that most employers will welcome.Employers who restrict eligibility for coverage to full-time employees should review their existing processes andcapability for recording hours worked. We recommend such employers take immediate action to ensure such data arecaptured. As soon as practical thereafter, an employer may want to review the data to identify what measurementperiod and stability period best meets its needs in terms of managing coverage eligibility and minimizingadministrative costs.More guidance is needed. The notice asks for comments from the public about the development of rules associated withthe short time assignments, temporary employees, high turnover positions or other special circumstances. The agenciesalso requested comments on other issues: mergers or acquisitions, variable start dates, more specific definitions ofseasonal employees, etc. Willis will update this Alert when more guidance is available. 8 Willis North America • 10/12
  9. 9. KEY CONTACTSU.S. HUMAN CAPITAL PRACTICE OFFICE LOCATIONSNEW ENGLAND ATLANTIC Mobile, AL Pittsburgh, PA Irvine, CA 251 544 0212 412 645 8506 949 885 1200Auburn, ME Baltimore, MD207 783 2211 410 584 7528 Orlando, FL Schaumburg, IL Las Vegas, NV 407 562 2493 847 517 3469 602 787 6235Bangor, ME Knoxville, TN 602 787 6078207 942 4671 865 588 8101 Raleigh, NC SOUTH 704 344 4856 CENTRAL Los Angeles, CABoston, MA Memphis, TN 213 607 6300617 437 6900 901 248 3103 Savannah, GA Amarillo, TX 912 239 9047 806 376 4761 Novato, CABurlington, VT Metro DC 415 493 5210802 264 9536 301 581 4262 Tallahassee, FL Austin, TX 850 385 3636 512 651 1660 Phoenix, AZHartford, CT Nashville, TN 602 787 6235860 756 7365 615 872 3716 Tampa, FL Dallas, TX 602 787 6078 813 490 6808 972 715 2194Manchester, NH Norfolk, VA 813 289 7996 972 715 6272 Portland, OR603 627 9583 757 628 2303 503 274 6224 Vero Beach, FL Denver, COPortland, ME Reston, VA 772 469 2842 303 765 1564 Rancho/Irvine, CA207 553 2131 703 435 7078 303 773 1373 562 435 2259 MIDWESTShelton, CT Richmond, VA Houston, TX San Diego, CA203 924 2994 804 527 2343 Appleton, WI 713 625 1017 858 678 2000 800 236 3311 713 625 1082 858 678 2132NORTHEAST Rockville, MD 301 692 3025 Chicago, IL McAllen, TX San Francisco, CABuffalo, NY 312 288 7700 956 682 9423 415 291 1567716 856 1100 SOUTHEAST 312 348 7700 Mills, WY San Jose, CAMorristown, NJ Atlanta, GA Cleveland, OH 307 266 6568 408 436 7000973 539 1923 404 224 5000 216 861 9100 New Orleans, LA Seattle, WAMt. Laurel, NJ Birmingham, AL Columbus, OH 504 581 6151 800 456 1415856 914 4600 205 871 3300 614 326 4722 Oklahoma City, OKNew York, NY Charlotte, NC Detroit, MI 405 232 0651 The information contained in this publication is not212 915 8802 704 344 4856 248 539 6600 intended to represent legal or Overland Park, KS tax advice and has beenNorwalk, CT Gainesville, FL Grand Rapids, MI 913 339 0800 prepared solely for203 523 0501 352 378 2511 616 957 2020 educational purposes. You San Antonio, TX may wish to consult your attorney or tax adviserRadnor, PA Greenville, SC Milwaukee, WI 210 979 7470 regarding issues raised in610 254 7289 704 344 4856 414 203 5248 this publication. 414 259 8837 Wichita, KSWilmington, DE Jacksonville, FL 316 263 3211302 397 0171 904 562 5552 Minneapolis, MN 763 302 7131 WESTERN Marietta, GA 763 302 7209 770 425 6700 Fresno, CA Moline, IL 559 256 6212 Miami, FL 309 764 9666 305 421 6208 9 Willis North America • 10/12