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Corporate Synergies Service Platform

HEADLINE COPY

CORPORATE SYNERGIES OVERVIEW

Our Company at a Glance • National insurance and employee benefits brokerage and consultancy • Founded in May 2003 as a privately held employee benefits broker; incorporated in Delaware in September 2004; converted to a limited liability company in October 2010 • 5 locations: Camden, New Jersey/Philadelphia Metro (headquarters); New York City; Melville, New York; Bethesda, Maryland; Orlando, Florida • Third largest benefits specialist in the nation ( Business Insurance magazine ) 1 • Place approximately $1 billion in annual premium • 225 professionals; 600 clients • Best Places to Work Employer ( Philadelphia Business Journal and South Jersey Biz ) 2 • Multiple national APEX, iCOMM and insurance carrier awards 3

We apply our deeper understanding to our multi-stage benefits approach, which has an immediate and ongoing positive impact on the employer’s organization and participants:

Strategy • Analyzing risks, goals and participants’ data • Developing a plan to help employers achieve long-term benefits goals Design • Structuring a plan to mitigate risk and create cost efficiencies • Optimizing annual renewals to cost-effectively complement overall strategic goals

Execution • Supporting day-to-day management of the benefits program • Assisting plan participants to get the most out of their benefits

1 2020 Business Insurance magazine ranking of brokers based on percentage of employee benefits business 2 Philadelphia Business Journal (Hall of Fame recipient) and South Jersey Biz 3 Excellence in client communications, employee education and wellness campaigns, one-of-a-kind communications, video media, blog content and website (corpsyn.com, healthdiscovery.org), and The Current Insurance Journal

We draw upon our unique infrastructure, internal subject matter experts and marketplace knowledge to deliver a comprehensive suite of services, improved cost control, value and ease of use. Our full suite of employee benefit consultation and services include: EMPLOYEE BENEFITS

Employee Health and Wellness The decisions employees make about their health have a direct impact on the organization’s bottom line. It’s critical that they understand the relationship between the choices they make (skipping preventive care screenings or neglecting to take medications, etc.) and the employer’s ability to continue to provide quality, affordable healthcare benefits. Our multi-year approach creates a change over time to support the participant’s wellness and the employer’s financial health. Benefits Administration With this optional service, our experts manage open enrollment and new hires, life event and status changes, reporting, eligibility maintenance and verification, conversion, portability, and more. Our enrollment and administration technology modernizes benefit administration and participant self-service with a “smart” information platform that engages and educates users. Automated tasks ease the burden of benefits administration on HR staff. Voluntary Benefits A voluntary benefit program fills gaps in core benefit offerings while providing greater cost control and protection from financial risk. Voluntary benefits are employee-paid, enabling the addition of high-value products at little or no cost... while helping participants meet their needs at different stages of life.

Plan Management At renewal time, our veteran strategists don’t just reflexively move a plan from carrier to carrier or recommend co- pay increases to control cost. They develop creative ways to drive higher value. Once the renewal is in place, they quarterback all related activities between carriers and vendors and our internal service departments. Employee Advocacy Our in-house BenefitsVIP employee advocacy and support center is staffed with experts who work as an extension of the HR team. They serve as a single point of contact for questions and issues. We also provide our optional NurseVIP SM registered nurse service for concierge-level clinical support. Regulatory Compliance Led by an ERISA attorney, our in-house compliance team identifies immediate risk, then develops a plan to keep the plans compliant year after year. Employee Education Our employee education and communications approach is built on a long-term campaign strategy. We help engage employees all year long, not just during open enrollment. Our campaigns are designed to drive positive behaviors, leading to better utilization and cost control. We help empower employees to take an active role in their benefits with clear and valuable information that guides them toward informed decisions.

1,000%

The increase, since 2012, of benefit plans utilizing out-of-pocket maximum deductibles between $6,000 and $6,999.* This trend is due to employers coping with the rising cost of healthcare and signals the need to educate participants about the consequences of their health plan choices. *Zywave Health Plan Design Benchmark Report Is your broker considering market trends and their potential impact on your plan participants when designing your benefits program?

For more information visit corpsyn.com or call 877.426.7779

Corporate Synergies is a national insurance and employee benefits brokerage and consultancy that delivers strategies to control costs, relieve administrative burdens and mitigate risk. With offices in: New Jersey | New York | Pennsylvania | Maryland | Florida All rights reserved. Corporate Synergies Group, LLC California license #: 0E77919 NOTE: This is not intended to be tax or legal advice. Please consult your tax or legal advisor. Certain services are subject to an additional brokerage and consulting fee and are not available in all jurisdictions.

PLAN MANAGEMENT OVERVIEW

PLAN MANAGEMENT COMPREHENSIVE CLIENT SUPPORT

When it comes to designing an annual employee benefits strategy and executing every component, details matter. But so does the big picture. Our Plan Management process is comprised of a Multi- Stage Approach that attends to the daily and annual requirements of your benefits program while maintaining a focus on the horizon. Our approach to benefits management delivers an immediate and ongoing positive impact on the employer’s organization and plan participants, allowing for data-driven refinements along the way. strategy to achieve long-term benefits goals and priorities. Our recommendations are shaped by our deeper understanding of you and your employees. Design: Structuring Your Employee Benefit Plans Through data analysis and benchmarking, we optimize your annual renewal experience by identifying cost-effective solutions to accomplish your overall strategic goals. We leverage our position in the marketplace to negotiate optimal, cost-controlled plan designs. Execution: Day-to-Day Benefit Management We relieve administrative burdens, simplifying the entire benefits process by developing a customized Annual Business Plan. Our team of account managers, specialists and underwriters execute the deliverables within this business plan to ensure administrative efficiencies, increased regulatory compliance, and mitigation of risk exposures. We assist plan participants to get the most out of their benefits, providing education and personal support that helps them make informed decisions and properly enroll in and use their plans. Strategy: Analyzing Your Long-Term Goals Using participant data, our experts develop an overall

of employees say their employers are providing benefits and programs to support and improve their well-being during the ongoing COVID-19 crisis. 59% of employees say they can’t afford out-of-pocket healthcare expenses of $1,000 or more. 52% MetLife Employee Benefits Trends Survey, 2020

AFLAC 2020 Benefits Survey

PLAN MANAGEMENT COMPREHENSIVE CLIENT SUPPORT

A Look Inside Our Unique Plan Management Process:

Employee Data Capture and Analysis: Acquiring ongoing data through Corporate Synergies’ internal listening posts (BenefitsVIP® advocacy center, employee engagement surveys, benefits administration system, etc.); analyzing impact of employee behaviors and utilization on cost Ongoing Claims Experience Review: Monitor and report using our Claims Dashboard on expected liability, contractual stop-loss obligations, fixed costs, budget forecasts, etc. Trends and Cost Driver Identification: Evaluating plan performance against business goals through our data analytics tools Benchmarking: Reporting on plans, utilization, costs, demographics, etc.; modeling the impact of changes; evaluating benefit plans against other employers Funding Alternatives: Guidance and recommendations on minimum premium, level funding, self-funding, referenced-based pricing, etc., based on risk tolerance, cash flow requirements and group size Plan Marketing/Renewal Negotiations: Our Underwriters use our Claims Dashboards to provide projections for a “no-surprise renewal.” Combined with our status in the marketplace, along with our ability to uncover anomalies within a carrier renewal calculation, we are able to provide superior negotiating strength for the most cost-effective rates and design. Annual/Multi-Year Program Design: Annual and long-term strategies to

achieve improved cost control and overall value Plan Implementation/Ongoing Support: Yearlong monitoring and reporting of tasks, roles and timelines Open Enrollment Support: Delivery of contracts, amendments and summary plan descriptions; support of employee meetings; development enrollment materials; supervision of carrier and vendor deliverables Compliance Risk Mitigation: Identification and remediation of immediate risks; ongoing strategies to keep plans compliant; continuous information flow on changes in laws and regulations impacting benefits Participant and HR Advocacy: Personal inquiry and issue resolution through our BenefitsVIP employee and HR advocacy and support center Client and Participant Education: Award-winning employee communications campaigns and materials; complimentary webinars, forums and conferences for ongoing client education; weekly releases of thought leadership blog articles, videos and “eAlert” updates Wellness and Disease Management: Designing, implementing and supporting health and wellness programs Vendor Management: Designing metrics, establishing service levels and monitoring best-in-class vendor partners Performance Guarantees: Establishing mutually agreeable standards and metrics for implementation, account management, customer services and processes

Corporate Synergies’ Plan Management process embraces the design, functionality, cost, risk and value of the entire health and welfare program...year to year and over the long term..

Synergies360 SM Corporate Synergies takes a full view of the insurance landscape, studies it from every angle, pursues innovation where none exists, and transforms this deeper understanding into actionable strategies to protect our clients and their participants. We call our approach Synergies360.

For more information visit corpsyn.com or call 877.426.7779

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ADVOCACY OVERVIEW

EMPLOYEE ADVOCACY INQUIRY, CLAIMS & CLINICAL SUPPORT

Today’s healthcare system can be complex and frustrating for employees to navigate. It’s not surprising they feel lost trying to understand plan details and care options on their own. They need— and deserve—the personal support of professional advocates who can guide them when they have questions and issues on benefit plans and care options.

of inquiries to BenefitsVIP are resolved within 24 hours 86%

Corporate Synergies delivers comprehensive, one-on-one participant advocacy through two best-of-breed service offerings:

Q Our standard BenefitsVIP ® employee advocacy and support Q Our optional concierge-level NurseVIP SM RN clinical support

BenefitsVIP and NurseVIP advocates provide one-on-one support to plan participants. Once contacted with an inquiry or issue, the advocate remains fully involved through the resolution. The measurement of our advocacy services is the employee’s peace of mind. Our advocacy approach is the industry gold standard of employee advocacy and support.

the average years of experience of NurseVIP RN advocates 27

EMPLOYEE ADVOCACY INQUIRY, CLAIMS & CLINICAL SUPPORT

BenefitsVIP Support Service* Corporate Synergies’ BenefitsVIP advocates are the first-to-call resource for each line of insurance coverage. Drawing upon an average of 20 years of industry experience, they provide compassionate, accurate support. BenefitsVIP services: Q Resolution of benefit and claims problems Q Response to coverage, service and eligibility questions and dependent verifications Q Location of participating physicians Q Assistance with pre-certification issues for medical procedures and prescriptions Q General support of benefit plan users (ID card replacement, information, etc.) Q Coordination of benefits Q Delivery of ongoing education through coachable moments Q Troubleshoot call types; proactively resolution with carriers, pharmacy benefit managers and others to before issues escalate Q Delivery of quarterly client reports

NurseVIP Support Services** NurseVIP registered nurses work personally with employees and their dependents to help them understand a diagnosis and access care. NurseVIP telephonic services: Q Assist sick and injured participants to receive care and understand test results, prescribed care and medication Q Facilitate transfer of medical records, X-rays and lab results prior to physician appointment Q Coordinate diagnostic tests Q Arrange for clinical trial evaluation Q Foster communication and the coordination of benefits between healthcare providers and insurance companies Q Facilitate test result review for diagnosis confirmation Q Set appointments with providers Q Provide research on treatment options Q Arrange for the delivery of medical supplies and durable equipment Q Coach the participant to address all medical concerns Q Coordinate hospice and other services for terminally ill participants Q Optional advocate appointment accompaniment on provider visits

“I wasted a week of time trying to correct a claims problem on my own and BenefitsVIP handled it in a day.” “Thank you for the absolutely outstanding service that you provided while my husband went through his very extensive health issues....” Synergies360 SM Corporate Synergies takes a full view of the insurance landscape, studies it from every angle, pursues innovation where none exists, and transforms this deeper understanding into actionable strategies to protect our clients and their participants. We call our approach Synergies360. BenefitsVIP users

*Standard Advocacy Service **Optional Advocacy Service

For more information visit corpsyn.com or call 877.426.7779

REV072020

Corporate Synergies is a national insurance and employee benefits brokerage and consultancy that delivers strategies to control costs, relieve administrative burdens and mitigate risk. With offices in New Jersey | Pennsylvania | New York | Maryland | Florida All rights reserved. Corporate Synergies Group, LLC California license #: 0E77919 NOTE: This is not intended to be tax or legal advice. Please consult your tax or legal advisor. Certain services are subject to an additional brokerage and consulting fee and are not available in all jurisdictions.

A Mobile App that Links Participants with Their Benefit Plans and Human Support

Now available!

Corporate Synergies offers a mobile app designed to engage and empower employees. The BenefitsVIP app gives plan participants immediate and direct access to their dedicated BenefitsVIP advocacy team as well as tools and resources to help them better utilize their benefits program. Contact BenefitsVIP: One click to connect with their dedicated BenefitsVIP team Your Benefits: Copay, deductibles, coinsurance and other plan information Company Plans: List of all carriers and vendors with group numbers and websites • • The app’s features include: •

Connect to BenefitsVIP ®

One touch puts employees in direct contact with their dedicated team of experts who answer their questions and help resolve issues.*

Link to Benefits Info Store your employee benefits guide, ID cards and contacts to give participants access to the right people and information when they need it.

• Employee Benefits Guide: Seamless year-round access to employee benefits guide

Engage Employees

• Your ID Card: Take a photo of insurance ID cards and send them to a doctor

Rapid, direct contact with benefit details and resources help employees take better control of their healthcare.

• Rx Pricing: Search locally for best prescription prices through GoodRx

• Find a Doctor/Dentist/Optician: Link to provider searches

• Geofencing: Instant alerts to use telemedicine, if applicable, when an ER or Urgent Care is visited

• Emergency Services: Store emergency contact information and medical history in one place

Save Time The app delivers information directly to your plan members’ phones, which reduces the benefits workload on busy HR personnel.

• Find Price: Find out the average cost of various procedures

• Healthcare 101: Definitions of commonly used medical and insurance terms

• Medical Research: A symptom checker from the world renowned Mayo Clinic

*BenefitsVIP is our unique, internal employee benefits and support service that delivers one-on-one inquiry and issue resolution support. Get connected!

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Corporate Synergies is a national insurance and employee benefits brokerage and consultancy that delivers strategies to control costs, relieve administrative burden sand mitigate risk.

corpsyn.com

With offices in: New Jersey | New York | Pennsylvania | Maryland | Florida

All rights reserved. Corporate Synergies, LLC California License #: OE77919 NOTE: This is not intended to be a tax or legal advice. Please consult your tax or legal advisor. Certain services are subject to an additional brokerage and consulting fee and are not available in all jurisdictions

COMPLIANCE

TRUSTED ADVISOR COMPLIANCE SERVICES FOR EMPLOYEE BENEFIT PLANS

As employers adjust to a new reality defined by a national health crisis, societal changes and uncertainty over the country’s financial stability, they’re encountering a common truth: they will never again conduct business exactly as before. This realization is impacting every aspect of benefits program management, and particularly that of regulatory compliance. Corporate Synergies’ compliance experts serve as financial risk consultants and trusted business advisors, operating as an extension of the client’s benefits and leadership teams. Our compliance consultants closely examine the legislation, regulation and guidance (at the federal, state and local level) that will have the greatest impact on clients’ health and welfare plans and insurance arrangements. Helping employers and plan sponsors avoid reporting penalties and fines is a given; we also enable and support each client’s strategic decisions with careful research into how changing regulatory requirements will impact their specific organization and industry. Our customized, step-by-step guidance reduces risk and lowers exposure and costs from governmental agency audits, participant lawsuits, mergers and acquisitions and business succession processes. Our roadmap includes required client actions to ensure compliance with new or changing government regulations regarding the COVID-19 crisis, state and local healthcare mandates, and reporting and disclosure requirements.

$12.7M in potential government fines and penalties in the past year. Our experts mitigated more than

100% of new-client compliance assessments conducted by Corporate Synergies reveal errors that could have triggered fines or penalties

COMPLIANCE SERVICES FOR EMPLOYEE BENEFIT PLANS

Our compliance advisors’ recommendations and calls to action are underpinned by their careful research of new and changing regulations. Their attention to detail results in enduring client relationships and peace of mind.

General Compliance Corporate Synergies’ in-house experts monitor and provide timely updates and support related to the ACA, ERISA, HIPAA, COBRA, USERRA, Cafeteria Plans and Flexible Spending Accounts (Section 125/FSA), Medical Expense Programs (Section 105), Annual Reporting Requirements (Form 5500) and other requirements. Services include: Compliance Assessment In-depth review (or “mock audit”) of current plans, policies, procedures and filings using our proprietary 50+ question survey; analysis includes compliance with federal, state and local laws and regulations Q Delivery of a complete findings report with recommendations, an action plan for remediation of all identified deficiencies and ongoing best practices

Fee requirement; SBC disclosure requirements and applicable deadlines and penalties Q Notice & Disclosure Requirements (review of past, present and future disclosures, and notices (including Form W-2 information reporting and ACA information reporting (under Code Sections 6055 and 6056) requirements and applicable deadlines and penalties) COBRA Q Full review of existing processes Q Development of customized communication documents and recommendations for administrative procedures and operational systems HIPAA Q Assessment, gap analysis and ongoing support Q Customized compliance plan Q Up-to-date HIPAA documentation Q Business associates agreements Q Training for privacy officers and PHI handlers is available to all clients and as a stand-alone service required under the ACA) Q Reporting requirements

Wellness Plans Q Analysis of compliance with HIPAA/ACA rules and

requirements; ADA, GINA and other EEOC rules and guidance Q Analysis of incentive program and applicable compliance deadlines and penalties eAlert Client Notificaiton Q Automatic notifications; requires no registration or subscription Q Delivered directly to your inbox Q Relevant to your benefit plans and nothing more Q Explaining strategies for compliance with federal, state and local laws and regulations ERISA Reporting and Filing Q Timely preparation of signature- ready Form 5500(s), Schedules (A and C) and Summary Annual Reports (SARs); Form 5500 services (also available as a stand-alone service) Q Wrap document preparation for each segment of the health and welfare benefit plan (medical, dental, vision, disability, etc.) to be kept on file Q Preparation of summary plan description (SPD) for distribution to participants

Requirements reviewed include:

Affordable Care Act (ACA) Q Confirm plan’s compliance with applicable ACA provisions such as MLR rebate requirements; HRA integration requirements; PCOR Fee requirement; Insurers’

Continued on the next page.

COMPLIANCE SERVICES FOR EMPLOYEE BENEFIT PLANS

Fee-Based Service

Q Distribution of Medicare Part D Notice and annual reminder of this Notice requirement Q Delivery of compliance checklists and calendars as handy reminders NEW: COVID-19 Compliance Support Q Analysis of government actions Q Step-by-step actions in automatic eAlert notifications Live Events Learn from our respected insurance and benefits compliance experts

while you earn SHRM PDCs and/or HRCI credits for select continuing education events, free of charge. Webinars, conferences and forums for HR, Finance and C-level executives are delivered in a variety of formats with easy-to- understand, actionable information on compliance and other trending topics in employee benefits and cost-containment strategies.

ACA Reporting Technology Q Provided through a best-of-breed technology partner Q Tracks, determines and documents eligibility status for all employees, using client data from payroll or time-and-attendance platforms Q Supports all associated filings required by the IRS

For more information visit corpsyn.com or call 877.426.7779

REV 072020

Corporate Synergies is a national insurance and employee benefits brokerage and consultancy that delivers strategies to control costs, relieve administrative burdens and mitigate risk. With offices in New Jersey | Pennsylvania | New York | Maryland | Florida All rights reserved. Corporate Synergies Group, LLC California license #: 0E77919 NOTE: This is not intended to be tax or legal advice. Please consult your tax or legal advisor. Certain services are subject to an additional brokerage and consulting fee and are not available in all jurisdictions.

compliance ALERT

Agencies Issue Guidance on COVID-19 Vaccine-Related Premium Surcharges and Discounts

October 7, 2021

On October 4, the U.S. Departments of Labor, Treasury and Health and Human Services issued FAQ guidance confirming the permissibility of implementing COVID-19 vaccination discounts and surcharges under employer-provided group health plans to incentivize employees to become vaccinated. This guidance clarifies that vaccine premium incentive programs (whether offering a premium discount or imposing a surcharge) are considered to be “activity - only” health -contingent wellness programs and must comply with HIPAA wellness program regulations. From these requirements and other applicable guidance, employers and plan sponsors should consider taking the following next steps: • Determine the Incentive Limits under the HIPAA Rules • Develop Reasonable Alternatives and Reasonable Accommodations • Ensure ACA Affordability Standards are Met • Ensure Compliance with Federal and State Government Vaccine Mandates/ Executive Orders Among other clarifications, the new guidance addresses how COVID-19 vaccine premium incentives impact affordability of an offer of employer-sponsored coverage for purposes of the ACA Employer Shared Responsibility rules. Employers and plan sponsors that are considering implementing a premium surcharge or discount should examine all of the potential risks, cost savings and administrative hurdles that may come from such a program. While, on the one hand, implementing such a program can incentivize workers to get vaccinated and result in cost savings for the group health plan, if not properly implemented it can result in significant liabilities, including penalties under the ACA’s Employer Mandate for not offering affordable health insurance coverage. ■

Action Required:

Review the latest guidance.

•

If considering a vaccine premium incentive program:

Examine the potential risks, benefits and logistics. Ensure any program complies with HIPAA wellness program regulations.

•

↓ Full Explanation Follows ↓

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On October 4, the U.S. Departments of Labor (DOL), Treasury and Health and Human Services (the “Agencies”) issued FAQ guidance (the “Guidance”) regarding the application of the HIPAA wellness rules and ACA affordability rules to vaccine - related premium surcharges and discounts. The Agencies confirmed the permissibility of implementing COVID-19 vaccination discounts and surcharges under employer-provided group health plans to incentivize employees to become vaccinated. Agencies Issue Guidance on COVID-19 Vaccine-Related Premium Surcharges and Discounts While the new Guidance doesn’t change the law, it clarifies how HIPAA and ACA rules apply to vaccine -related premium surcharges and discounts —resolving questions that had not been answered by the EEOC’s May 28 guidance (the “EEOC Guidance”) pertaining to employers’ vaccine incentive programs under the ADA and GINA (discussed below). In the new Guidance, the Agencies clarify that vaccine premium incentive programs (whether offering a premium discount or imposing a surcharge) are considered to be “activity - only” health -contingent wellness programs under HIPAA wellness program regulations issued in 2013 (the “HIPAA Rules”). Due to this determination by the Agencies, this triggers five restrictive conditions or requirements that plan sponsors must comply with in order for their premium incentive program to be considered a permissible wellness program under the HIPAA Rules. (1) The program must give individuals eligible for the program the opportunity to qualify for the incentive at least once per year; (2) The incentive (when added to all other wellness incentives for health-contingent programs) must not exceed 30% of the total cost of employee-only coverage (or, if a dependent can earn the incentive too, the cost of the coverage in which the employee and dependent are enrolled); (3) The program must be reasonably designed to promote health or prevent disease (the Guidance gives the example of an employer providing a toll-free hotline to answer questions about the vaccine and provide assistance with scheduling appointments); (4) The program’s incentive must be available to all similarly situated individuals, which includes allowing a reasonable alternative standard (or waiver of such standard) for certain individuals. Specifically, a reasonable alternative must be provided to obtain the incentive for those for whom it is unreasonably difficult due to a medical condition or medically inadvisable to receive the COVID-19 vaccine (in an example in the Guidance, the reasonable alternative is requiring the individual to provide an attestation that the individual will follow CDC masking guidelines for unvaccinated individuals); and (5) The plan or issuer must disclose in all plan materials describing the terms of an activity-only wellness program the availability of a reasonable alternative standard to qualify for the reward (and, if applicable, the possibility of waiver of the otherwise applicable standard), including contact information for obtaining a reasonable alternative standard and a statement that recommendations of an individual's personal physician will be accommodated. How does the Guidance change the Law?

Denial of Benefits or Coverage Due to Vaccination Status

The new Guidance further provides that conditioning eligibility for benefits or coverage for otherwise covered items or services (including to treat COVID- 19) on participants being vaccinated (sometimes referred to as a “Gatekeeper Rule”) is not permissible under the HIPAA Rules since it would constitute discrimination against these participants based on a health factor.

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Impact on ACA Employer Mandate Affordability

The new Guidance further addresses how COVID-19 vaccine premium incentives impact affordability of an offer of employer- sponsored coverage for purposes of the ACA Employer Shared Responsibility rules (“Employer Mandate”). Similar to other non- tobacco premium incentives, vaccine incentives are treated as “not earned,” and thus, can increase the cost of coverage for Employer Mandate purposes. Specifically, if the incentive is a premium discount, the discount is treated as not earned, and thus, affordability is based on the assumed increased premium cost for the participant, and similarly, if the incentive is a premium surcharge, the surcharge is treated as applying to everyone, and thus, affordability is based on the assumed increased premium cost. Does Compliance with the HIPAA Rules Mean that the Premium Surcharge or Discount Complies with the ADA and GINA? No. The Guidance clarifies in a footnote that compliance with the HIPAA Rules is not determinative of compliance with any other provision of the PHS Act, ERISA, the Code, or any other State or Federal law, including the ADA and GINA. Specifically, the Agencies note that this Guidance addresses “wellness program incentives provided by group health plans and health insurance issuers” and does not address “incentives offered by employers as part of workplace policies and unrelated to their group health plan,” and further, with respect to such workplace policies recommends that employers consult with the EEOC Guidance for determining compliance. The EEOC Guidance provides that the ADA wellness rules do not apply where the employer merely requests proof of COVID- 19 vaccination because that does not constitute a medical exam or a disability-related inquiry. However, employers must still provide a reasonable accommodation to an employee who cannot get the vaccine due to a disability (or, under Title VII, because of a sincerely-held religious belief). If, instead, the employer is administering the vaccine directly or through an agent, then an employer’s pre -screening questions constitute a disability-related inquiry subject to the ADA. In that case, incentives are only permitted if they are not so substantial as to be “coercive.” With respect to GINA, the EEOC Guidance provides that an incentive for a family member getting vaccinated is generally permissible and no incentive limits apply, as long as the family member gets the vaccine from a third party and not through the employer or its agent. An employer is not permitted to give an incentive to an employee for a family member getting the vaccine from the employer or its agent. On September 9, President Biden signed two executive orders related to vaccine mandates – one that applies to federal contractors and one that applies to private sector employers with 100 or more employees. On September 24, the Safer Federal Workforce Task Force (“Task Force”) issued guidance on the federal contractor requirement, which generally requires employees of federal contractors to be fully vaccinated by December 8 unless they are eligible for an accommodation based on disability or a sincerely- held religious belief. The DOL’s Occupational Safety and Health Administration (“OSHA”) is developing a rule regarding the order that applies to employers with 100 or more employees. We expect OSHA to be issuing this rule soon. At the state level, we expect several states to impose their own vaccine- related laws and mandates, and to challenge the federal government’s vaccine mandates. Employers and plan sponsors that are considering implementing a premium surcharge or discount should examine all of the potential risks, cost savings and administrative hurdles that may come from such a program. While, on the one hand, implementing such a program can incentivize workers to get vaccinated and result in cost savings for the group health plan, if not properly implemented it can result in significant liabilities, including penalties under the ACA’s Employer Mandate for not offering affordable health insurance coverage. Compliance with the ADA and GINA Compliance with Federal and State Government Vaccine Mandates What should employers and plan sponsors do next?

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The Guidance lays out the specific compliance requirements under HIPAA for employers and plan sponsors seeking to implement premium discounts or surcharges on its group health plans. From these requirements and other applicable guidance, employers and plan sponsors should consider taking the following next steps: • Determine the Incentive Limits under the HIPAA Rules: If an employer wants to impose a surcharge on unvaccinated employees for group health plan coverage (or reduce the cost of coverage for vaccinated employees), it will need to ensure that the incentive, taken together with all other non-tobacco incentives, does not exceed the 30% incentive limit under the HIPAA Rules. • Develop Reasonable Alternatives and Reasonable Accommodations: Establish methods for employees and participants to earn incentives through the “reasonable alternative standard” and “reasonable accommodation” rules discussed above if such employees/participants cannot get vaccinated due to a medical reason, disability or sincerely held religious beliefs. • Ensure ACA Affordability Standards are Met: As discussed above, a vaccine surcharge is considered to be “not earned” and can result in an increase of the employee’s share of the cost of coverage for affordability purposes under the ACA’s Employer Mandate rules. • Ensure Compliance with Federal and State Government Vaccine Mandates/Executive Orders: Employers that are federal contractors should make sure that they are in compliance with recent executive orders and the Task Force’s recent guidance. Private sector employers with 100 or more employees should review the applicable OSHA guidance when it becomes available. Finally, all employers should review and take into account any applicable state laws or mandates that may impact their vaccination program. ■

If you have any additional questions, please call your Corporate Synergies Account Manager or 866.CSG.1719.

What are your organization’s plans? Take our Vaccine Mandate, Incentive & Surcharges survey

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EMPLOYEE EDUCATION OVERVIEW

EMPLOYEE EDUCATION & COMMUNICATIONS ENROLLMENT & PLAN USAGE SUPPORT

Corporate Synergies’ employee education and communications programs promote informed enrollment, responsible plan usage and overall organizational health. Our award-winning* staff writers and designers are employee benefits and insurance industry veterans who understand the nuances of communicating complicated concepts to a variety of audiences. They develop messaging that simplifies benefits while matching the “how” and the “what” of plan education and communications to the employer’s business goals. Comprehensive Communications Support Our communication programs enhance the value of your plan by helping your participants become better-informed, responsible benefit and healthcare consumers. We work with you to develop communications that support your efforts to: QQ Connect with participants during enrollment, special campaigns and throughout the plan year QQ Engage participants with targeted information, helping them understand plan options and enroll appropriately QQ Guide participants to properly use their benefits to save them (and you) time and money QQ Influence responsible behaviors to improve participant health and well-being and help them better control benefit costs

14% of enrolled employees can explain 4 main benefit concepts: deductibles, co-payments, co-insurance and out-of-pocket maximums. Source: Journal of Health Economics

Employees rank employee

communications among their top benefit challenges.

Source: Zywave Broker Services Survey

*Corporate Synergies’ employee education, communications and wellness programs are recognized by APEX and iCOMM for excellence in direction, design, implementation and content.

EMPLOYEE EDUCATION & COMMUNICATIONS ENROLLMENT & PLAN USAGE SUPPORT

Benefits Enrollment and Wellness Communications at a Glance Corporate Synergies provides a library of campaigns designed to drive employee education, engagement and participation. The number of campaigns and deliverables depends on the communications model selected (Level 1: Core; Level 2: Expanded; or Level 3: Custom). Each model includes a detailed 12-month campaign timeline and a full complement of education and communications materials. You have access to campaigns that are designed to drive employee education, engagement and participation. The number of campaigns and deliverables depends on the communications model selected. A typical campaign consists of a kick-off letter, poster, postcard, flyer and newsletter. The Core Model engages and educates employees with a library of templates for benefit summaries, posters, flyers, postcards, and Microsoft PowerPoint ® presentations, and our monthly Benefits Connection employee health and wellness newsletter. Level 1 Core Communications Model

Level 3 Custom Model

We provide up to 120 hours of design and writing services as well as personal consultation with our Director of Employee Education, Communications and Wellness. The Custom Model features client-specific stock photography, translation services, and custom printing, binding, distribution and fulfillment services.

Our communications programs educate participants on all aspects of employee benefits.

Level 2 Expanded Model

For an additional fee, Level 2 builds on the Core Model with enhanced and additional components, such as expanded benefits statements, This model features employer branding, strategy and messaging.

For more information visit corpsyn.com or call 877.426.7779

WELLNESS OVERVIEW

EMPLOYEE HEALTH & WELLNESS STRATEGY, EDUCATION & ENGAGEMENT

Corporate Synergies’ metrics-driven employee wellness and disease management programs promote informed behaviors and personal engagement in support of improved organizational health. Our award-winning* staff writers and designers are employee benefits industry veterans with a demonstrated ability to simplify complicated health and benefits concepts for a variety of audiences. They develop programs that emphasize taking personal responsibility for health, heighten engagement in the wellness process and increase healthcare consumerism. Corporate Synergies’ wellness campaigns match the “how” and the “what” of workforce health objectives to the employer’s long-term business and financial goals. Health and Wellness Consultation Our wellness communication campaigns guide plan participants through a logical process that highlights the results of proactive, positive behaviors on personal health and finances. We partner with employers to develop campaigns that: Q Educate and engage employees toward informed health behaviors and benefits consumerism Q Leverage the use of incentives that are commensurate with a participant’s activities Q Use metrics to track and measure the initiative over time Q Delivers a measurable Value/Return on Investment

62% of employers are increasing the use of wellness programs as a benefits cost- management approach. Source: CFO Research/ Prudential Financial Report A Corporate Synergies client utilizing a compliance-based wellness strategy achieved a $1.2 M decrease in claims over the previous year.

*Corporate Synergies’ wellness programs are recognized by APEX and iCOMM for excellence in direction, design, implementation and content.

EMPLOYEE HEALTH & WELLNESS STRATEGY, EDUCATION & ENGAGEMENT

Wellness Strategies at a Glance Your wellness strategy begins with a consultation to review goals and objectives. A short- and long-term strategy can then be developed to target the unique needs of your organization. Corporate Synergies specializes in aligning wellness providers with technology platforms to fit your strategy. From there, our award-winning team of communication experts and designers brings your strategy to life with engaging content to drive participation in your program. Three Program Models to Fit Budgets and Business Goals Our three levels of support spans from the offering of four pre-configured wellness campaigns to the highly engaged design and delivery of customizable programs. Materials for multiple channels reinforce your strategy and build upon a multi-year plan of which each year includes a detailed campaign timeline.

VOI measures: Q Increased productivity Q Decreased absenteeism and presenteeism Q Increased retention Q The cost savings of retaining

Our wellness programs are designed to create long- lasting cultural changes. These holistic solutions tie directly to the goals

employees than training a new hire Q Decreased long- and short-term disability claims Q Decreased hospital stays Q Increased morale and job satisfaction

and objectives of the employer’s healthcare strategy.

ROI measures: Q Population risk factors

Q Claims and pharmacy data Q Worker’s compensation data Q Biometric screening results Q Health assessment results Q Online coaching participation and movement Q Tobacco cessation participation and utilization

The Bottom Line: Wellness VOI and ROI

Corporate Synergies works with you to demonstrate evidence of the Value of Investment (VOI) and Return on Investment (ROI) of wellness programs.

For more information visit corpsyn.com or call 877.426.7779

TECHNOLOGY OVERVIEW

TECHNOLOGY SOLUTIONS FOR EMPLOYEE BENEFITS

Today, more than ever before, there is a greater need by employers to control costs and operate more efficiently. Employees are also demanding time- and money-saving strategies. The cost control, compliance and efficiency demands of today’s health and benefit programs are daunting for everyone. Plan sponsors and users need technologies that eliminate guesswork and manual processes, which are fraught with the potential for errors and missteps. Corporate Synergies offers best-of-breed technologies that support comprehensive plan design analysis and design, daily and annual benefits administration, employee enrollment and decision support, and Affordable Care Act information and reporting: QQ SmartBen Essentials SM Participant Decision-support and Benefits Administration Platform QQ SynergiesSELECT SM Private Insurance Exchange QQ Gatekeeper ACA Information Gathering and Reporting Tool QQ Medical/Rx Plan Intelligence (MRPI) Claims Analyzer Suite Our technologies help employers and their employees keep pace with the demands of benefits. We help stakeholders save time and money and elevate the quality and value of benefit programs.

51% of employers indicate they are expanding the use of technology to manage costs associated with employee benefits programs. This is the second highest strategy utilized, behind making plan design changes (66%). Source: Prudential’s Study of Employee Benefits, Today & Beyond

TECHNOLOGY SOLUTIONS FOR EMPLOYEE BENEFITS

SmartBen Essentials Decision-Support and Administration Platform

MRPI Claims Analyzer Our Medical/Rx Plan Intelligence (MRPI) claims analyzer software suite drills down and identifies hidden cost drivers in health and welfare benefits plans. We model the impact of plan design changes, demographics, and clinical and lifestyle management programs to determine the most sensible and data-driven approach to achieving cost savings and optimal plan design. We analyze current plan structure and design, historical, current and projected costs, claims experience and utilization, funding arrangements, contracts, etc. Using the results of the MRPI analysis, our underwriters and account management team will outline a strategy consistent with your current and future business plan. Gatekeeper ACA Information Gathering and Reporting Tool Our Gatekeeper technology solution empowers you to achieve and maintain Affordable Care Act compliance for hours tracking, reporting and the Employer Mandate requirement. Gatekeeper determines and documents employee eligibility status and accepts data from existing payroll, time and attendance, and HRIS systems. The Gatekeeper ACA tool is available in conjunction with our SmartBen Essentials benefits administration technology or as a stand-alone solution.

Our best-of-breed technologies save employers and plan participants time and money.

SmartBen Essentials, our proprietary benefits administration technology, empowers participants with online self- service tools to reduce the burden of enrollment and ongoing administration on HR personnel. The technology streamlines and automates enrollment and eligibility systems, connects you with your participants, educates them, and helps them manage their benefits. SmartBen Essentials modernizes benefits administration and participant self-service processes with a “smart” benefits enrollment and employee communication platform that empowers users. The technology is the only system with artificial intelligence designed to help participants with decision-making. upon our unique services platform, Synergies360. Our private exchange combines decision-support technology with comprehensive services to drive cost control for the employer and benefit consumerism for the employee. Like BenefitsVIP, SynergiesSELECT is more than a decision-support tool. Unlike most broad-based private exchanges, SynergiesSELECT is a full- service benefits solution. We manage your comprehensive program and serve as a single point of contact. As a result, you have better control over benefit costs and your employees are empowered to make the benefit choices that are right for them. SynergiesSELECT Private Exchange SynergiesSELECT is a first-party private exchange solution built

For more information visit corpsyn.com or call 877.426.7779

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