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HomeMy WebLinkAbout15- Human Resources ORIGINAL CITY OF SAN BERNARDINO —REQUEST FOR COUNCIL ACTION From: Linn Livingston, Director Subject: ADOPT RESOLUTION WITH of Human Resources NATIONWIDE RETIREMENT SOLUTIONS TO PROVIDE A POST- Dept: Human Resources EMPLOYMENT HEALTH PLAN (PEHP) FOR EMPLOYEES. Date: November 3, 2009 M/CC Meeting Date: Nov. 16, 2009 Synopsis of Previous Council Action: Approved by Mayor and Common Council to implement a Post Employment Health Plan: Management/Confidential: Resolution No. 2007-345 August 22, 2007 Fire Safety Management: Resolution No. 2009-71 April 6, 2009 Fire Safety: Resolution No. 2009-140 June 3, 2009 Middle-Management: Resolution No. 2005-16 January 24, 2005 Police Safety: Resolution No. 2003-253 September 4, 2003 Recommended Motion: 1. Adopt Resolution. 2. Authorize the Human Resources Director as the plan administrator. Signature Contact person: Linn Livingston Phone: x5161 Supporting data attached: Ward: FUNDING REQUIREMENTS: Amount: No cost toyhe City Source: (Acct�No.) (Acct. Description) Finance: Council Notes: A Q Agenda Item No. 11-((e-0q AUP/4" ut-f pass • L CITY OF SAN BERNARDINO — REQUEST FOR COUNCIL ACTION Staff Report Subiect• Authorize an agreement with Nationwide Retirement Solutions to provide a Post-Employment Health Plan(PEHP). Background: The Post-Employment Health Plan (PEHP) for Public Employees was established for the exclusive benefit of public employees who have separated from service. The PEHP plan is a method of providing a tax-exempt reimbursement for qualified post-employment expenses for medical care/premiums (see attached exhibit A). The plan allows for a percentage, which is determined on an annual basis, of an employee's payoff of accrued leave balances to be transferred into a tax-exempt PEHP Plan under Section 501(c) (9) of the Internal Revenue Code of 1986. Plan assets remain tax-exempt under the IRS regulation. The Human Resources Department met and conferred with the bargaining groups and the Mayor and Common Council approved the establishment of a PEHP Plan for the following groups: Management/Confidential (August 22, 2007), Fire Safety Management (April 6, 2009), Fire Safety (June 3, 2009), Police Safety (September 4, 2003), and Middle-Management (January 24, 2005). At this time only the Fire Safety and Fire Management groups have requested to participate in a PEHP program. The Human Resources Department reviewed several vendors and is recommending Nationwide Retirement Solutions (NRS), our current deferred compensation provider, to manage the plan. The PEHP plan offered by NRS has been approved by the Internal Revenue Service (IRS) and NRS is currently providing plans for many public agencies. Financial Impact: There will be no cost to the City. All fees will be paid by the participant (employee). Participants will be subject to an annual fee of$30 plus %2 percent of contributions. Recommendation: 1. Adopt Resolution. 2. Authorize the Human Resources Director as the plan administrator. COPY 1 Resolution No 2 RESOLUTION OF MAYOR AND COMMON COUNCIL OF THE CITY OF SA BERNARDINO TO ADOPT THE POST EMPLOYMENT HEALTH PLAN (PEHP) FO 3 PUBLIC EMPLOYEES FOR THE EMPLOYEES OF THE CITY OF SA 4 BERNARDINO. 5 WHEREAS, a Post Employment Health Plan for Public Employees has been established 6 for eligible public employees, pursuant to section 501(c) (9) of the Internal Revenue Cod 7 permitting such plans; and 8 9 WHEREAS, the City of San Bernardino (Employer) wishes to make contributions, o behalf of its eligible employees, in a manner permitted under the Plan to meet its employees, 10 i post employment health care needs and expenses; and I1 12 WHEREAS, under the PEHP program, Nationwide Retirement Solutions (NRS), Inc. 13 will provide administrative services in exchange for a fee as agreed upon by the Employer an NRS. 14 15 NOW, THEREFORE, BE IT RESOLVED that the Mayor and Common Council of the 16 Employer, meeting in regularly scheduled session, this 16'' day of November, 2009, hereby 17 adopts this PEHP program on behalf of the eligible employees of the Employer. The Human Resources Director is hereby authorized to execute, on behalf of the eligible employees of the 18 Employer, a participation agreement with NRS, authorizing NRS to act as the Administrator o 19 the Plan and the agent of the Employer, and other such agreements and contracts as are necessary 20 to implement the program. 21 22 23 24 25 /// I RESOLUTION OF MAYOR AND COMMON COUNCIL OF THE CITY OF SA BERNARDINO TO ADOPT THE POST EMPLOYMENT HEALTH PLAN FOR 2 PUBLIC EMPLOYEES (PEHP) FOR THE EMPLOYEES OF THE CITY OF SA 3 BERNARDINO. 4 I HEREBY CERTIFY that the foregoing Resolution was duly adopted by the Mayor an 5 the Common Council of the City of San Bernardino at a meeting thereof, held 6 7 on day of , 2009, by the following vote, to wit: 8 COUNCILMEMBERS: AYES NAYES ABSTAIN ABSENT 9 ESTRADA 10 ,BAXTER I j 11 BRINKER SHORETT 12 KELLEY 13 JOHNSON 14 MCCAMMACK 15 16 Rachel G. Clark, City Clerk 17 18 The foregoing resolution is hereby approved this day of 19 , 2009. 20 Patrick J. Morris, Mayor 21 City of San Bernardino 22 Approved as to form: 23 JAMES F. P NMAN, 24 City Attorn 25 By: HR/Agenda Items:Reso.PEHP EXHIBIT A THE POST EMPLOYMENT HEALTH PLAN FOR PUBLIC EMPLOYEES - 3 Copyright 2003, 1996 Nationwide Retirement Solutions All Rights Reserved (plcanvaz.doc) THE POST EMPLOYMENT HEALTH PLAN FOR PUBLIC EMPLOYEES 3 TABLE OF CONTENTS ARTICLE I NAME AND EFFECTIVE DATE 1 .1 Name 6 1 .2 Effective Date 6 ARTICLE II DEFINITIONS 2.1 Account 7 2.2 Administrator 7 tom— .'_�:_y^ G.t.! AJJ oc i�.l l i, 2.4 Benefit 7 2.5 Code 7 2.6 Contribution 7 2.7 Corporation 7 2.8 Dependent 7 2.9 Effective Date 7 2.10 Eligible Employee 7 2.11 Employee 8 2.12 Employer 8 2.13 Employer Contribution 8 2.14 Entry Date 8 2.15 Health Care Insurance Premium 8 2.16 Health Care Insurance Premium Sub-account 8 2.17 Participant 8 2.18 Participation Agreement 8 2.19 Plan 8 2.20 Plan Year 9 2.21 Post-Retirement Health Benefit 9 2.22 Qualifying Medical Care Expenses 9 2.23 Qualifying Medical Care Expenses Sub-account 9 2.24 Trust Agreement 9 2.25 Trust Fund 9 2.26 Trustee 9 2 2.27 Valuation Date 10 ARTICLE III TRUST 3.1 Trust Agreement 11 3.2 Trust Fund 11 3.3 Investment of Trust Fund 11 3.4 Valuation of Trust Fund 11 ARTICLE IV ELIGIBILITY TO PARTICIPATE 4. i Eligibiii t y To Participate i 3 4.2 Ceasing to Be an Eligible Employee 13 4.3 Dispute as to Eligibility 13 ARTICLE V CONTRIBUTIONS 5.1 Employer Contributions 14 5.2 Determination of Amount of Contributions 15 ARTICLE VI BENEFITS 6.1 Post-Employment Health Benefits 16 6.2 Notice by Employer 16 6.3 Benefit Limits 16 6.4 Timing and Method of Benefit Payment 16 6.5 Prohibition on Alienation 17 6.6 Forfeitures 17 ARTICLE VII ACCOUNTS 3 7.1 Separate Accounts and Records 18 7.2 Valuation of Accounts 18 ARTICLE VIII CLAIMS PROCEDURE 8.1 Written Claims 19 8.2 Denied Claims 19 8.3 Review Procedure for Denied Claims 19 ARTICLE IX ADMINISTRATION OF THE PLAN 9.1 The Administrator 20 r, - �n 7.L %\Utf 9.3 Removal or Resignation 20 9.4 Successor Administrator 21 9.5 Administrative Fees 22 9.6 Powers of the Administrator 22 9.7 Records 22 9.8 Defect or Omission 23 9.9 Liability of Administrator 23 9.10 Funding Policy 23 ARTICLE X AMENDMENT AND TERMINATION 10.1 Termination of the Plan 24 10.2 Termination and Discontinuance of Contributions 24 4 ARTICLE XI MISCELLANEOUS 11.1 Rights of All Interested Parties Determined by Terms of 25 the Plan 11.2 No Employment Rights Created 25 11.3 Number and Gender 25 11.4 Notice to Employees 25 11.5 Notification of Address 25 11.6 Withdrawal of Employer 26 11 .7 Headings 26 2 1 i g Governing Law 6 S THE POST EMPLOYMENT HEALTH PLAN FOR PUBLIC EMPLOYEES - 3 ARTICLE I NAME: EFFECTIVE DATE 1 .1 Name. This plan shall be known as The Post Employment Health Plan for Public Employees - 3. 1 .2 Effective Date. The Plan shall be effective as of January 17, 1997. 6 ARTICLE II DEFINITIONS As used in this Plan, and except as otherwise provided herein, the following terms shall have the meaning hereinafter set forth: 2.1 "Account" shall mean an account established for a Participant pursuant to Section 7.1 hereof. 2.2 "Administrator" shall mean the person or entity possessing authority to control and manage the operation and administration of the Plan. The Administrator shall be the Corporation unless and until the Corporation resigns or is removed by the Advisory Committee representatives (as defined in the Trust Agreement) and Employers in accordance with Article IX. 2.3 Association shall mean each group of employees of government Employers in California, Nevada, and Arizona, who by their employment related common bond are covered under the Plan and their Advisory Committee representatives (as defined in the Trust Agreement). 2.4 "Benefit" shall mean any payment made pursuant to Article VI hereof. 2.5 "Code" shall mean the Internal Revenue Code of 1986, as amended. 2.6 "Contribution" shall mean any contribution made to the Plan pursuant to Article V hereof. 2.7 "Corporation" shall mean Nationwide Retirement Solutions, its successors and assigns. 2.8 "Dependent" shall mean any person who, in relation to the Participant, satisfies the requirements under Code Section 152(a). 2.9 "Effective Date" shall mean January 17, 1997. 2.10 "Eligible Employee" shall mean an Employee who is eligible to participate in the Plan pursuant to the Employer's Participation Agreement. 7 2.11 "Employee" shall mean an individual who is employed by the Employer and is not included in a unit of employees covered by a collective bargaining agreement between employee representatives and one or more employers. 2.12 Employer shall mean a state or local government or political subdivision thereof in California, Nevada, or Arizona, that adopts the Plan by entering into a Participation Agreement with the Administrator. As the context requires, the term "the Employer" as used herein shall apply collectively to all entities that are Employers under the Plan or singly to an Employer. 2.13 "Employer Contribution" shall mean a contribution made pursuant to Section 5.1 hereof. _ Fn Iry D j�1 shall. �_ mean i iG 11 1 uuv of month ioi iii i iii ii ie i aieil ar year. 2.15 "Health Care Insurance Premium" shall mean any amount used to purchase insurance coverage for health benefits, hospitalization, or other medical care as defined in Code Section 213(d)(1). 116 "Health Care Insurance Premium Sub-account" shall mean a sub-account consisting of all Employer contributions designated to fund future Health Care Insurance Premium Reimbursements. 2.17 "Participant" shall mean an Employee or former Employee, or the surviving Dependents thereof, who has an Account under the Plan. 2.18 "Participation Agreement" shall mean the agreement between the Employer and the Administrator by which the Employer adopts the Plan, and which sets forth the terms of the Employer's adoption of the Plan, including: (a) the Employer's rate of contribution to the Plan, and (b) the class of Employees of the Employer who are eligible to participate in the Plan. 2.19 "Plan" shall mean The Post Employment Health Plan for Public Employees - 3, as set forth in this document. 2.20 "Plan Year" shall mean the calendar year. 8 2.21 "Post-Employment Health Benefit" shall mean a payment made pursuant to Section 6.1 hereof. 2.22 "Qualifying Medical Care Expenses" shall mean those expenses incurred solely for "medical care," as defined in Code Section 213(d)(1), rendered to the Participant or his Dependents. Examples of Qualifying Medical Care Expenses include, but are not limited to, the following: (a) Deductible and co-payments for medical care under any accident and health insurance plan of the Participant or Dependents; (b) Dental care, including routine dental checkups, orthodontia, and dentures, (c) Eye care, including examinations, glasses, and contact lenses; (d) Hearing care, including examinations and hearing aids; iG' R!� t I I ,rirrvi �vr-mirrTin "I outine plly Jllr X11 VnVI���� ,v��v� � (f) Prescription drugs; (g) Any other medical care item which is approved by the Administrator and which is consistent with the definition of "medical care" within the meaning of Code Section 213(d)(1); and (h) Health Care Insurance Premiums.. 2.23 "Qualifying Medical Care Expense Sub-account" shall mean a sub-account consisting of all Employer contributions designated to fund future Qualifying Medical Care Expense reimbursements. 2.24 "Trust Agreement" shall mean the agreement described in Article III hereof, establishing the Trust for the Post Employment Health Plan for Public Employees- 3. 2.25 "Trust Fund" shall mean the Trust for the Post Employment Health Plan for Public Employees - 3 and its assets and investments held at any one time by the Trustee. 2.26 "Trustee" shall mean the Trustee or any successor Trustee designated in accordance with the terms of the Trust Agreement. 2.27 "Valuation Date shall mean each day in which the New York Stock Exchange and the Corporation's home office are open for business. 9 10 ARTICLE III TRUST 3.1 Trust Agreement. All Contributions shall be paid into, and all Benefits provided for herein shall be paid from, the Trust Fund. The Trust Agreement shall be in such form and contain such provisions as the parties may deem appropriate, including, but not limited to, provisions with respect to the powers and authority of the Trustee, the authority of the Administrator and Trustee to amend the Trust Agreement, the authority of the Administrator to settle the accounts of the Trustee on behalf of all persons having an interest in the Trust Fund, and the authority of the Administrator, subject to the approval of the Employer Advisory Committee representatives employing a majority of Participants and Employee Advisory Committee representatives representing a majority of the Participants then participating in the Plan, to remove a Trustee and appoint a successor trustee. \R lL.s. 1 I into. .. Tr. 1 Ai-.r m-rat rl-��II form a part -of the Plon, and all rights 9Y! irn ee !G!ed ii IV. II e Iiu51 nyleeI111.11 II al 1L Ii foi,i I :a and benefits that may accrue to any person under the Plan shall be subject to all the terms and provisions of the Trust Agreement. 3.2 Trust Fund. In no event shall any part of the principal or income of the Trust Fund be paid to or reinvested in the Employer, or be used for any purpose whatsoever other than the exclusive benefit of the Participants and their Dependents and defraying the reasonable expenses of the Plan. Notwithstanding the preceding, Contributions shall be returned to the Employer only under the following circumstances: (a) If a Contribution is made by the Employer by a mistake of fact; (b) If the Internal Revenue Service determines that the Trust is not tax-exempt under Code Section 501 (a); or (c) If the Internal Revenue Service determines that the Trust has unrelated business taxable income under Code Section 512(a)(3)(E). 3.3 investment of Trust Fund. The Trustee shall invest and reinvest the Trust Fund and the income therefrom in accordance with the terms of the Trust Agreement. 3.4 Valuation of the Trust Fund. The value of the Trust Fund shall be determined as of each Valuation Date, as follows: (a) The value per share of a security listed for trading on a national securities exchange shall be the closing price per share at which such security was 11 traded on the exchange on the day as of which the value is to be determined (or, if such security was not traded on that day, on the last preceding day on which it was traded); provided, that if a security is listed for trading on two or more national securities exchanges, the national securities exchange upon which principally it is traded shall be deemed to be the only such exchange on which it is listed; (b) The value per share of a security regularly traded in the over-the-counter market shall be the mean between the highest price bid and the lowest price asked per share of that security on a day as of which the value is to be determined (or, if no quoted bid and asked prices are available for that day, on the last preceding day for which quoted bid and asked prices are available); (c) The unit value of any underlying option available under a variable annuity will be calculated as of the close of the New York Stock Exchange on the Valuation Date; (d) The value of any other investment shall be the fair market value thereof on the day as of which the value is to be determined, as determined by the Trustee; and (e) There shall be added/deducted from the value of the investments any income or liabilities due or accrued properly chargeable thereto. 12 ARTICLE IV ELIGIBILITY TO PARTICIPATE 4.1 Eligibility To Participate, Each Employee shall become a Participant on the Entry Date coincident with or next following the later of (a) the date on which he becomes an Eligible Employee, or (b) the effective date of the Employer's Participation Agreement. 4.2 Ceasing to Be an Eligible Employee. A Participant who ceases to be an Eligible Employee shall remain a Participant, but shall have no Employer Contributions made on his behalf. The Employer shall resume making Contributions on behalf of such Participant commencing on the Entry Date coincident with or next following the first date thereafter that he again becomes an Eligible Employee. 4.3 Dispute as to Eligibility. In the event of a dispute as to the eligibility of any individual to participate in the Plan, the decision of the Administrator to such eligibility shall be final and conclusive for all purposes. 13 ARTICLE V CONTRIBUTIONS 5.1 Employer Contributions. The Employer shall contribute to the Plan on a periodic basis on behalf of each Eligible Employee who is a Participant during such period an amount specified in the Employer's Participation Agreement to the appropriate sub-account to fund Post Retirement Health Benefits. Amounts contributed shall be segregated to either one or both of the following sub-accounts for (i) reimbursement of the Qualifying Medical Care Expenses not paid by insurance (Qualifying Medical Care Expense Sub-accounts) or (ii) reimbursement of Health Care Insurance Premiums (the Health Care Insurance Premium Sub-accounts). Amounts in each sub-account may not be used for any purpose other than provided by Code sections 105 and 106. Amounts used to reimburse Health Care Insurance Premiums may be paid from the Qualifying Medical Care Expense Sub-account on!\i if all amounts in the Health Care Insurance Premium Sub-account are exhausted at the time the Employee submits the request for reimbursement. Contributions may not vary among Eligible Employees to fund the Qualifying Medical Care Expense Sub-account and will be made as an equal dollar amount for each Eligible Employee. The annual minimum Contribution for each Eligible Employee is $120. This minimum does not include Employer contributions from accumulated compensated absences such as sick leave or vacation. All Contributions shall be made in a manner which satisfies the nondiscrimination rules found in Code sections 505(b) and 105(h) or other applicable law. Contributions to fund Health Care Insurance Premium Sub-accounts may be made as an equal dollar amount or as a percent of salary but such percent or dollar amount must apply to all Eligible Employees. If the Employer funds the Health Care Insurance Premium Sub-account on a percentage of salary basis, the minimum percentage of salary basis is 1/2 of 1% of each Eligible Employee's annual salary. An Employer who has a compensated absence policy under which all Employees accumulate compensated absence pay may require all or a specified portion of accumulated compensated absence benefits be contributed to the Qualifying Medical Care Expense Sub-account in an dollar amount for each Eligible Employee. Compensated absence contributions will be made to the Health Care Insurance Premium Sub-account on the same percentage basis for each Eligible Employee. 14 5.2 Determination of Amount of Contributions. The Trustee shall not be under any duty to inquire into the correctness of the Contributions paid over to the Trustee hereunder; nor shall the Trustee or Administrator be under any duty to enforce the payment of the Contributions to be made hereunder. The Eligible Employees and Association representatives shall have sole responsibility and duty to enforce Employers' contribution obligations. is ARTICLE VI BENEFITS 6.1 Post-Employment Health Benefits. Upon a Participant's separation from service with the Employer for any reason, the Participant, or in the event of a deceased Participant, his Dependents, shall be entitled to be reimbursed from the Participant's Qualifying Medical Care Sub-account for Qualifying Medical Care Expenses incurred by the Participant and his Dependents and from the Participant's Health Care Insurance Premium Sub-account for Health Care Insurance Premiums incurred by the Participant, subject to the limits set forth in Section 6.3 hereof, provided that such Qualifying Medical Care Expenses will not be taken as a deduction on the Participant's or Dependents' federal income tax return. Post-Employment Health Benefits shall be funded solely by Employer Contributions made in accordance with Article V hereof into each respective V p sub-account from which bei nf'fs ill rrirl 6.2 Notice by Employer.The Employer shall certify to the Administrator the date of a Participant's separation of service from the Employer. The Administrator shall rely on any such certification in determining the extent to which a Participant or his Dependents shall be entitled to a Benefit under the Plan. In the case of a Participant's death, the Trustee shall require proof of the Participant's death prior to paying any Benefit to a Dependent under this Article VI. 6.3 Benefit Limits. Any Qualifying Medical Care Expense or Health Care Insurance Premium paid in accordance with Section 6.1 hereof is limited to the Participant's respective sub-account balance as of the Valuation Date immediately preceding the date the claim for such Benefit is submitted to the Trustee. If a claim for Benefits exceeds the sub-account balance at such date, the Trustee will pay the claim to the extent of the Account balance. If future amounts are credited to the Participant's Account, the Participant must submit a current claim form for reimbursement. Only claims for Qualifying Medical Care Expenses and Health Care Insurance Premium Reimbursements will be payable under the Plan. 6.4 Timing and Method of Benefit Payment. All Benefit payments shall be made in cash as soon as administratively practicable following the date a claim for Benefits is submitted to the Administrator. 6.5 Prohibition on Alienation. The rights of a Participant or Dependent to 16 receive a Benefit shall not be subject to alienation or assignment, and shall not be subject to anticipation, encumbrance or claims of creditors except to the extent required by applicable law. 6.6 Forfeitures. If a Participant has no Dependents on the date of his death, he will forfeit the balance in his Account. Benefit payments for Qualifying Medical Care Expenses which, if paid, would result in discrimination in violation of Code section 105(h), its regulations or any other applicable provision of law shall also be forfeited. A Participant's account may also be forfeited if the Administrator is unable to locate the Participant within 36 months after the Administrator sends a letter by certified U. S. mail, postage prepaid, to the Participant's last known address. Any amount forfeited under this Section 6.6 shall be allocated on the Valuation Date coincident with, or immediately following, the date on which the Administrator determines that a forfeiture hcas occurred to the Accounts of all other Participants who (i) are (or were) employed by the forfeiting Participant's Employer and (ii) have an account balance on the Valuation Date. Forfeitures shall be allocated among the Participants in accordance with procedures established by the Administrator from time to time. 17 ARTICLE VII ACCOUNTS 7.1 Separate Accounts and Records. The Administrator shall maintain separate sub-accounts in the name of each Participant having an interest in the Trust Fund. A statement of a Participant's sub-accounts) as of the last day of each calendar quarter and such other dates as the Trustee may determine in its discretion, shall be distributed to him within a reasonable time after such date showing: (a) the sub-account balance(s); (b) Employer Contributions credited to the Participant's sub-account(s); (c) gains and losses of the Trust Fund allocated to the Participant's sub-account(s); (d) Qualifying Medical Care Expenses and Health Care Insurance rrCl I Illjl I IJ aid 111111 the Participant's It'$ $ub-a ^^'1''+lc1• nr�rJ rt•cip ccoolJI 11 tJ), \.1 IV (e) administrative fees paid from the Participant's sub-account(s). 7.2 Valuation of Sub-Accounts. As of each Valuation Date, all income and gains (realized and unrealized) of the Trust Fund for the period since the next preceding Valuation Date (or, if there is no prior Valuation Date, since the Effective Date) shall be credited to, and all losses (realized and unrealized) and expenses of the Trust Fund for such period shall be charged to, the Participants' sub-accounts in proportion to their balances as of the next preceding Valuation Date (or as of the Effective Date, if there is no prior Valuation Date), provided, however, that if there has been a withdrawal from a Participant's account since the next preceding Valuation Date, such Participant's Account balance at the Valuation Date, rather than the next preceding Valuation Date, shall be used to allocate income, gains, losses and expenses to such Participant's sub-accounts. 18 ARTICLE VIII CLAIMS PROCEDURE 8.1 Written Claims. All claims for Benefits shall be made in writing in accordance with such procedures as the Administrator shall prescribe, including deadlines, documentation requirements and forms. 8.2 Denied Claims. If a claim for Benefits is denied in whole or in part, the Administrator shall furnish the claimant a written notice setting forth the reason for the denial, including reference to pertinent Plan provisions, describing any additional material or information that is required from the claimant and explaining why it is required, and explaining the review procedure set forth in Section 8.3 hereof. Such notice shall be given within five (5) business days of the date of denial. 8.3 Review Procedure for Denied Claims. Within 60 days of the denial of any claim for Benefits, a claimant may file a written request for a review of such denial by the Administrator. Any claimant seeking review of a denied claim is entitled to examine all pertinent documents and to submit comments in writing. Within 60 days after its receipt of a request for review of a denied claim, the Administrator shall render a written decision on its review which references the Plan provisions on which its decision is based. 19 ARTICLE IX ADMINISTRATION OF THE PLAN 9.1 The Administrator. The Administrator shall be the Corporation unless and until the Corporation resigns or is removed by the Advisory Committee (as defined in the Trust Agreement) representatives in accordance with Section 9.3 below. The Trustee shall administer the Plan in accordance with its terms. The Administrator shall have the authority to control and manage the operation and administration of the Plan and the responsibility of filing and distributing reports and returns with or to government agencies and Participants, and their Dependents as required under the Code and other applicable law. The Administrator, by a written instrument, may delegate its r?S!-( i1CiE�ijlitie5 to control and manage the operation tii f 'h Plan r-• •°• _� CylJ..Jf I V! !t!C f lan and 1 the responsibility to file reports and returns. If the Administrator has made such a delegation, the Administrator shall not be liable for any act or omission by the person to whom such responsibility is delegated. To the extent permitted by law, the Trust shall indemnify each employee of the Administrator and any agent or person who has been appointed by the Administrator, against any liability (not reimbursed by insurance) incurred in the course of the administration of the Plan, except liability arising from his own negligence, willful misconduct or breach of fiduciary duty. 9.2 Agents. The Trustee may employ such agents, including counsel, as it may deem advisable for the administration of the Plan. Such agents may not be Participants. The fees of such agents shall be charged to the Participants' Accounts in accordance with Section 7.2 hereof. 9.3 Removal or Resignation. The Administrator may resign as Administrator at any time by a written instrument delivered to all Advisory Committee representatives giving notice of such resignation. The Administrator may be removed, for cause relating to performance that fails to meet generally accepted standards, practices and procedures applicable to persons providing similar types of administrative services, by the Employers employing and Associations representing a majority of the Participants then participating in the Plan by a written notice delivered to the Administrator. In the event of a dispute over the execution of the duties of the Administrator, the dispute shall be subject to arbitration between the Administrator and a representatives) established by the 20 Advisory Committee. The Administrator shall be granted 180 days to cure any deficiencies identified by the arbitrator before any removal may be considered effective. Any notice of removal or resignation of the Administrator shall be effective 60 days after receipt by the Administrator or Advisory Committee representatives, as the case may be, or at such other time as is agreed to by the Administrator and the Advisory Committee representatives. If, within 60 days after notice of resignation or removal of the Administrator, the Advisory Committee representatives have not designated a successor Administrator, the Administrator may apply to any court of competent jurisdiction for the appointment of a successor Administrator. 9.4 Successor Administrator. The Administrator, subject to the veto right described below, may appoint a successor Administrator. The Administrator shall provide 30 days' advance notice to the Advisory Committee that it has designated a successor Administrator. If Employee Advisory Committee representatives representing a majority v i Par i icipai its and I if E mpio y er AdvlSOry Committee representatives employing a majority of Participants object to the designated successor in writing to the Administrator within 30 days after the date of the Administrator's notification mailing, then the designation shall not become effective. If there is no sufficient objection, the Administrator shall deliver to the Trustee copies of: (a) a written instrument executed by the Administrator appointing such successor, and (b) a written instrument executed by the successor in which it accepts such appointment. Such instruments shall indicate their effective date. If a vacancy in the office of Administrator 'occurs and the Administrator has not appointed a successor Administrator in accordance with the preceding paragraph, the Advisory Committee representatives representing a majority of the Participants then participating in the Plan shall appoint a successor Administrator and shall deliver to the Trustee copies of (a) a written instrument executed by such Advisory Committee representatives appointing such successor, and (b) a written instrument executed by the successor in which it accepts such appointment. Such instruments shall indicate their effective date. If the Administrator is removed by Advisory Committee representatives in accordance with Section 9.3 hereof, the written instrument removing the Administrator shall also appoint a successor Administrator. Any successor Administrator shall have all the powers and duties of the original Administrator. 21 9.5 Administrative Fees. The Administrator shall be paid from the Trust Fund an administrative fee for each Participant equal to an amount determined from time to time in accordance with the Participation Agreement between the Administrator and the Participant's Employer. Such fees shall be charged against the Participants' Account balances. 9.6 Powers of the Administrator. The Administrator shall have all such powers as may be necessary to carry out the provisions of the Plan, and the actions taken and the decisions made by the Administrator shall be final and binding upon all parties. The powers of the Administrator shall include, but not be limited to, the following: (a) To act for the Plan in accepting an Employer for participation in the Plan and in entering into a Participation Agreement with such Employer; (b) To establish conditions fry n rticinafinn in the Plan; (c) To determine all questions with regard to employment, eligibility, coverage, and other similarly related matters; (d) To determine all questions relating to the amount of any Benefits and all questions pertaining to claims for Benefits and procedures for claim review; (e) To prescribe procedures to be followed by Participants in filing claims for Benefits; (f) To prepare and distribute information explaining the Plan to Participants; (g) To appoint or employ individuals to assist in the administration of the Plan and any other agents deemed advisable, including banking, legal, accounting, and actuarial counsel; (h) To resolve all other questions arising under the Plan, including any questions of construction; (i) To take any such further action as the Trustee shall deem advisable in the administration of the Plan; and (j) To pay claims for Benefits either by issuing claims checks or by delegating the authority to issue claims checks in accordance with Section 9.1 hereof. 9.7 Records. The acts and decisions of the Administrator shall be duly recorded. The Administrator shall make available for examination by any claimant, during the business hours of the Administrator, a copy of this Plan and such records as may pertain to the computation of Benefits of such claimant. 22 9.8 Defect or Omission. Any defect, omission or inconsistency in this Plan shall be corrected by the Administrator by such action as may be necessary to correct such defect, supply such omission, or reconcile such inconsistency. 9.9 Liability of Administrator. Except for its own negligence, willful misconduct, or breach of fiduciary duty, neither any Employee of the Administrator nor any agent or other person appointed by the Administrator shall be liable to anyone for any act or omission in the course of the administration of the Plan. 9.10 Funding Policy. The Administrc for shall establish and review a funding policy consistent with the objectives of the Plan. 23 ARTICLE X AMENDMENT AND TERMINATION 10.1 Amendments. The Administrator, through its board of directors, reserves the right to amend this Plan at any time in such manner as it may be necessary or advisable in order to qualify and retain the qualification of the Trust Fund as a voluntary employees' beneficiary association in accordance with Code section 501 (c)(9), and any such amendment may, by its terms, be retroactive; and to-amend, alter, modify or suspend, in whole or in part, any provision or provisions of this Plan at any time, retroactively or otherwise, by written notice to the Trustee, the Employers and the Association representatives. In any event, no such amendment shall: (a) increase the duties or obligations of the Trustee or Employer 'fhnl If iTC .A/rltterj ^%Sr s nil (b) decrease any Participant's Account balance; or (c) cause or permit any portion of the corpus or income of the Trust to revert to, or become the property of, or be used for the benefit of the Employer, or divert any portion of the corpus or income of the Trust for purposes other than the exclusive benefit of the Participants and their Dependents. 10.2 Termination and Discontinuance of Contributions. All of the Employers and Advisory Committee representatives then participating in the Plan collectively may terminate the Plan at any time by notice to the Administrator and Trustee. The Plan shall terminate if all participating Employers withdraw from the Plan in accordance with Section 11.6. Upon termination of the Plan, Benefits shall be paid by the Trust Fund or by such other means determined by the Administrator in accordance with the Trust Agreement until all liabilities under the Plan to Participants have been satisfied. 24 ARTICLE XI MISCELLANEOUS 11.1 Rights of All Interested Parties Determined by Terms of the Plan. The Plan and Trust are purely voluntary on the part of the Employer; the Trust shall be the sole source of Benefits provided under the Plan; and in no event shall the Administrator or Employer be liable or responsible therefor. The Plan shall be binding upon all parties thereto and all Participants, and upon their respective heirs, executors, administrators, successors, and assigns, and upon all persons having or claiming to have any interest of any kind or nature under the Plan or the Trust. 11.2 No Employment Rights Created. The creation and maintenance of the PI,^,1,r; � t(;'i„ r,n, C'Cr1jer any ry iiJ i3Oi�fli ivied employment ii On an�r �mplCY�ee, and all Employees shall remain subject to discharge to the same extent as if the Plan had never been established. 11.3 Number and Gender. Where necessary or appropriate to the meaning hereof, the singular shall be deemed to include the plural, the plural to include the singular, the masculine to include the feminine and neuter, the feminine to include the masculine and neuter, and the neuter to include the masculine and feminine. 11.4 Notice to Employees. Notice of the existence and the provisions of this Plan and amendments thereto shall be communicated by the Employer or Advisory Committee representatives to all persons who are, or who become Eligible Employees. 11.5 Notification of Address. Each person eligible to receive Benefits shall notify the Administrator in writing of his post office address and any change of post office address thereafter. Any communication, statement or notice addressed to such person at his last post office address as filed with the Administrator (or if no post office address was filed with the Administrator, then his last post office address shown by the Employer's payroll records) will be binding upon such person for all purposes of this Plan, and neither the Employer nor the Administrator shall be obligated to search for or ascertain the whereabouts of any such person. 25 11.6 Withdrawal of Employer. If an Employer withdraws from the Plan, it shall no longer be a participating employer in the Plan. In such event, the Administrator shall maintain the Accounts of each Participant who is or was an Employee of such Employer, and shall pay Benefits to each such Participants in accordance with the terms of the Plan. Expenses of the Trust fund and administrative fees shall be charged against such Participants' Accounts in accordance with Section 7.2 and 9.5 hereof for as long as such Accounts are maintained by the Administrator. 11.7 Headings. The headings and subheadings in this Plan are inserted for convenience and reference only and are not intended to be used in construing this Plan or any provision hereof. 11.8 Governing Law. This Plan shall be construed according to the law of the State of Illinois and applicable Federal Low and all provisions hereof shall be administered according to the law of the State of Illinois and applicable federal law. (plcanvaz.doc) 26 Nationwide Privacy Statement Thank you for choosing Nationwide®. Our privacy statement explains how we collect, use, share, and protect your personal information. So just how do we protect your privacy? In a nutshell, we respect your right to privacy and promise to treat your personal information responsibly. It's as simple as that. Here's how. Confidentiality and security We follow all data security laws. We protect your information by using physical and technical safeguards. We limit access to your information to those who need it to do their jobs. Our business partners are also legally bound to use your information for our purposes only. They may not share it or use it in any other way. Collecting and using your personal information We collect information about you when you ask about or buy one of our products or services. The information comes from your application, business transactions with us, and consumer reports — but only if applicable to the product or service that you choose. Please know that we only use that information to sell, service, or market products to you. We may share the following types of information: • Name, address, Social Security number • Assets and income • Property address and value • Account and policy information • Consumer report information • Family member and beneficiary information Sharing your information for business purposes When you buy a product, we may share your personal information for everyday servicing purposes with our sister companies and business partners. Some examples include mailing your statement or processing transactions that you request. You cannot opt out of these. We also share your personal information with your broker or independent agent. They use your personal information to manage your policy or account. We may also share your personal information where federal and state law requires. Sharing your information for marketing purposes We don't sell your information for marketing purposes. We have chosen not to share your personal information with anyone except to service your product. So, there's no reason for you to opt out. If we change our policy, we'll tell you and give you the opportunity to opt out before we share your information. Nationwide® On Your Side Using your medical information We sometimes collect medical information. We may use this medical information for a product or service you're interested in, to pay a claim, or to provide a service. We may share this medical information for these business purposes if required or permitted by law. But, we won't use it for marketing purposes unless you give us permission. Accessing your information You can always ask us for a copy of your personal information. Please call us at 1-877-677-3678 to access your personal information or for questions about our privacy policy. For TTY/TDD services, please call 1-800-995-4457. We have a process that allows you to review your information and for your protection we will verify your identity first. We can only give access to information that we control. We don't charge a fee for giving you a copy of your information now, but we may charge a small fee in the future. You can call your agent or producer to change your personal information. But, we can't update information that other companies provide to us. So, you'll need to contact these other companies to change your information. A parting word ... These are our privacy practices. They apply to all current and former clients of Nationwide Financial and the affiliates and subsidiaries that offer life insurance, banking services and investments. This includes the following companies: Nationwide Life Insurance Company Nationwide Life and Annuity Insurance Company Nationwide Retirement Solutions, Inc. Nationwide Deferred Compensation, Inc. Nationwide Trust Company, FSB a division of Nationwide Bank NFS Distributors, Inc. Pension Associates, Inc. Nationwide Financial Institution Distributors Agency, Inc. Nationwide Retirement Solutions, Inc. of Arizona Nationwide Retirement Solutions, Inc. of Ohio Nationwide Retirement Solutions, Inc. of Texas Nationwide Retirement Solutions Insurance Agency, Inc. Nationwide Financial Institution Distributors Agency, Inc. Nationwide Investment Services Corporation Nationwide Securities, Inc. Nationwide Investment Advisors, LLC Effective Date: September 24, 2007 NFS-0230-G