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HomeMy WebLinkAboutCC Resolution 12369 (Employee Dental Program)RESOLUTION NO. 12369 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN RAFAEL AUTHORIZING THE CITY MANAGER TO EXECUTE AN AGREEMENT BETWEEN UNITED CONCORDIA COMPANIES, INC. AND THE CITY OF SAN RAFAEL REGARDING THE DENTAL PROGRAM FOR ALL ELIGIBLE EMPLOYEES AND THEIR DEPENDENTS (From 1/1/08-12/31/09) WHEREAS, the City of San Rafael's dental program is currently self-funded and is administered by Fiserv; and WHEREAS, the City contracted with ABD Services, a benefit brokerage firm, in March 2007, to conduct a marketing analysis of City benefits to determine how the City's dental plan structure and pricing matched other California cities and to review if better options existed at the same price or less; and WHEREAS, ABD Services issued a Request for Proposals (RFP) to a number of dental insurance companies with United Concordia, Cigna, Safeguard, Delta Dental, and Assurant responding; and WHEREAS, the marketing analysis of these responses was presented to the City's Employee Benefits Committee and United Concordia was determined to be the recommended firm by the Committee. NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF SAN RAFAEL DOES RESOLVE, DETERMINE AND ORDER AS FOLLOWS: The City Manager is authorized to execute, on behalf of the City of San Rafael, AN AGREEMENT BETWEEN UNITED CONCORDIA COMPANIES, INC. AND THE CITY OF SAN RAFAEL REGARDING THE DENTAL PROGRAM, a copy of which is hereby attached and by this reference made part hereof. I, JEANNE M. LEONCINI, Clerk of the City of San Rafael, hereby certify that the foregoing Resolution was duly and regularly introduced and adopted at a regular meeting of the Council of said City on Monday, the 15th day of October, 2007, by the following vote, to wit: AYES: COUNCILMEMBERS: Cohen, Heller, Miller, Phillips & Mayor Boro NOES: COUNCILMEMBERS: None ABSENT: COUNCILMEMBERS: None Jbk M LEON INI, CITY CLERK AGREEMENT FOR ADMINISTRATIVE SERVICES THIS AGREEMENT entered into as of the 1 St day of JANUARY 1 2008 by and between CITY OF SAN RAFAEL (hereinafter referred to as "Company") and United Concordia Companies, Inc. (hereinafter referred to as "Claims Administrator"). WITNESSETH: WHEREAS, the Company has established a self-insured employee welfare benefit plan ("the Plan") within the meaning of the Employee Retirement Income Security Act of 1974 as amended ("ERISA"); WHEREAS, the Claims Administrator possesses the administrative capacity to assist the Plan in providing its Participants with dental benefits; WHEREAS, the Company has designated a Plan Administrator to administer the Plan benefits in accordance with the requirements of ERISA; WHEREAS, the Company and the Plan Administrator have requested the Claims Administrator to furnish claims administration services for the Plan; and WHEREAS, the Claims Administrator is willing to administer the claims for certain dental benefits for the Plan's Participants. NOW, THEREFORE, in consideration of the mutual undertakings herein stated, the Company and Claims Administrator, intending to be legally bound hereby, enter into this Agreement for the administration of the claims for certain dental benefits of the Plan. ARTICLE I - DEFINITIONS Definitions of words and terms as used in this Agreement: A. Administrative Fee - the fee payable by Company to Claims Administrator specified in Exhibit A. B. Bank - Wachovia Corporation or such other institution as agreed to by Company and Claims Administrator. C. Covered Services - those services for which Plan Benefits are provided under and subject to the terms and conditions of the Plan. D. Participant - an employee, dependent, retiree or other beneficiary as defined in the Plan, who is duly enrolled by the Claims Administrator in accordance with Article II of this Agreement. ASO -1 REV. 12/2004 ' r: E. Participating Provider - any provider with whom Claims Administrator has a contract or arrangement with respect to payment for services performed for persons enrolled in the Plan. F. Plan - the employee welfare benefit plan, as defined in ERISA, established by the Company for the purpose of providing certain dental care benefits, as described in the Plan/Summary Plan Description, for its Participants, which is marked as Exhibit B and is incorporated herein by reference. G. Plan Administrator - The entity or person designated by the Company as the Plan Administrator, as that term is defined in ERISA. The Claims Administrator is not the Plan Administrator. H. Plan Benefits - all benefits of whatever nature payable to a Participant or a Participating Provider under and subject to the terms and conditions of the Plan. Provider - any duly licensed dental care provider for whose services the Company is obligated to pay under the terms of the Plan. Summary Plan Description ("SPD") - a document, as defined in ERISA, which describes the terms and benefits to be administered by the Claims Administrator marked as Exhibit B and attached hereto and incorporated herein by reference. ARTICLE II - ENROLLMENT A. Eligibility Information. Not less than monthly, Company will provide Claims Administrator with current information specifying individuals who are eligible to be Participants. Company will provide Claims Administrator with notice of changes to such information as it occurs, and Claims Administrator will post such changes no later than 10 business days after receipt thereof from Company. Changes involving termination of a Participant for Plan benefits will be effective on a prospective basis only and will be effective at the end of the month in which proper notice is provided to the Claims Administrator by the Company. All information under this Article shall be provided in a mutually acceptable data processing medium and format. The Company is responsible for ensuring the accuracy of information provided to the Claims Administrator and with such frequency as the parties mutually agree. B. Identification Cards. Claims Administrator shall be responsible for providing standard identification cards to Participants based on information provided to it by Company, pursuant to paragraph A above. Customized identification cards are subject to added fees. C. Enrollment Procedures. Upon a determination by Company that an individual is eligible to participate in the Plan, Claims Administrator shall enroll the individual in a mutually agreed upon manner. Company will obtain from each Participant any necessary releases and consents as required by law for the disclosure of health information to Claims Administrator for the purposes set forth in this Agreement. ASO -1 REV 12/2004 D. COBRA Compliance. The Company and the Plan Administrator shall retain full responsibility for notifying qualified beneficiaries of their termination of coverage and of their rights to continuation coverage, and for administering the exercise of continuation rights, as required by the Consolidated Omnibus Budget Reconciliation Act of 1985, P.L. 99-272; 29 U.S.C. 1161-1168; 26 U.S.C. 4980B and 42 U.S.C. 300bb-1, (COBRA). Claims Administrator shall have no obligation to ensure that any instructions received by qualified beneficiaries or the Company and the Plan Administrator comply with the requirements of such laws and shall be indemnified by the Company and the Plan Administrator from any and all liability arising from such Company's and Plan Administrator's failure to provide such notices or continuation coverage for qualified beneficiaries. ARTICLE III - BENEFITS A. Payment Of Benefits. During the term of this Agreement, Claims Administrator will administer the claims for dental care benefits, subject to all of the terms and conditions set forth in Exhibit B. Determination and Payment of Benefits - Claims Administrator will compute and verify Plan Benefit amounts and prepare and provide to Participants and Participating Providers, when applicable, statements reflecting the amount of Plan Benefits payable and the reasons why a claim has been denied in whole or in part. Claims Administrator will draw drafts and checks or initiate electronic funds transfers in payment of Plan Benefits. 2. Services of Claims Administrator's Participating Providers - If covered services are performed by a Participating Provider, Claims Administrator will make payment directly to the Provider. Participating Providers have agreed to accept the Claims Administrator payment as payment in full for covered services performed for Participants, except where certain maximums, copayments, co- insurance or deductibles are specified in Exhibit B and which are the responsibility of the Participant. Services of Non -Participating Providers - If covered services are performed by a Provider who is not a Participating Provider, Claims Administrator will make payment at the rate specified in Exhibit B. Any difference between the Provider's charge and the Claims Administrator's payment shall be the personal responsibility of the Participant. Payment will be made to the Participant or, if permitted by the Plan and if a valid assignment of the claim is in place, to the Non -Participating Provider. 4. Overpayment of Plan Benefits - The parties will cooperate fully to make every reasonable effort under the circumstances, considering the chances of successful recovery and the costs thereof, to recover any payment made to a Participant or Provider which is in excess of the amount which the person was entitled to receive under the terms as listed in Exhibit B. ASO -1 REV. 1212004 Company assigns to Claims Administrator the authority to pursue recovery of overpayments and Claims Administrator will pursue all reasonable means of recovery of overpayments under the circumstances but will not be obligated to commence litigation, unless otherwise specifically agreed by the parties. Claims Administrator will assume liability for an unrecovered overpayment only if and at such time as it is determined that: (a) the overpayment was caused by Claims Administrator's act or omission which was intentional, grossly negligent, fraudulent or criminal; (b) all reasonable means of recovery under the circumstances have been exhausted; and (c) Claims Administrator's acts or omissions were not undertaken at the express direction of Company. 5. Banking - Plan Benefits shall be made by check drawn by Claims Administrator payable through the Bank. The Company, by execution of this Agreement, expressly authorizes Claims Administrator to issue and accept such checks on behalf of the Company for the purpose of payment of Plan Benefits. Company agrees to provide funds in accordance with Exhibit A through its designated bank sufficient to satisfy all Plan Benefits upon notice from Claims Administrator or the Bank of the amount of checks approved and recorded by Claims Administrator. Company agrees to execute such documents as may be required by Claims Administrator or Bank from time to time to effectuate this provision. B. Amendments To Plan. The Company may amend the Plan to change the dental benefits provided to its Participants, or the eligibility of its beneficiaries to participate, at any time during the term or any extension of this Agreement. Upon written confirmation from the Company and the Plan Administrator that the Plan has been duly amended, the Claims Administrator shall administer claims to conform to the amendments to the Plan. The Company and the Plan Administrator assume all responsibility for communication of Plan amendments to the Participants or for other notices to Participants as required by ERISA or any other applicable law. Claims Administrator reserves the right to terminate this Agreement upon thirty (30) days written notice if the amendments to the Plan constitute a material change in benefits available to Participants under the Plan. If any amendment increases or decreases the Company's anticipated claims expense or the Claims Administrator's administrative costs, the parties shall, prior to the administration of the amendments to the Plan, agree to revise financial terms. If the parties fail to reach an agreement within thirty (30) days of commencement of negotiations, either party may terminate this Agreement by the giving of sixty (60) days prior written notice to the other party. To the extent changes in dental benefits necessitate modification or revision of Exhibit B or any booklet which constitutes a part thereof, the Company shall provide reasonable advance written notice of such amendment to the Claims Administrator. C. Interpretation Of Plan. The Company and the Plan Administrator delegate to the Claims Administrator the authority, responsibility and discretion to interpret and construe the provisions of the Plan, as necessary to: 1. administer all services specified in this Agreement; 2. determine the extent of the benefits to which any Participant is entitled under the Plan; ASO -1 4 REV. 1212004 3. make a full and fair review of each claim denial appealed by Participants in accordance with the requirements of ERISA. Any function not specifically delegated to or assumed by the Claims Administrator pursuant to this Agreement shall remain the sole responsibility of the Company and the Plan Administrator. D. Nature of Services Provided. Claims Administrator provides administrative claims payment services only under this Agreement and does not assume any financial risk or obligation with respect to claims. This Agreement shall not be deemed a contract of insurance or prepaid dental care under the laws and regulations of any jurisdiction where Claims Administrator may be called upon to act in fulfilling its obligations under this Agreement. ARTICLE IV - SERVICES PROVIDED BY CLAIMS ADMINISTRATOR A. Advisory Services. Claims Administrator shall consult with Company and Plan Administrator when requested to do so regarding: Plan design and revisions, including questions regarding eligibility for participation and effective dates and cessation of coverage. 2. Plan administration including questions regarding taxes and Covered Services. 3. The SPD and other material intended for distribution to Participants. Claims Administrator will make available on request a specimen form of SPD. However, Company and Plan Administrator acknowledge and agree that provision of a specimen form of SPD and consultation regarding the SPD is not intended to impose on Claims Administrator any obligation under ERISA with respect to the SPD. Claims Administrator has no obligation to print or distribute the SPD. B. Estimates of Costs and Liabilities. Estimates of Plan Benefit Costs and Fees - Claims Administrator will provide Company with an annual estimate, for budget purposes, of Plan Benefit costs and Claims Administrator's Service Fee and other charges for Subsequent Contract Periods. 2. Estimates of Costs of Proposed Plan Changes - Claims Administrator will provide Company with estimated Plan Benefit cost calculations for proposed changes in the Plan. 3. Estimates of Open and Unreported Claim Liability - Claims Administrator will provide Company with estimates of open and unreported Claim liability following the close of each Contract Period. ASO -1 REV. 12/2004 C. Standard Administrative Forms. Claims Administrator will provide Company and Plan Administrator with standard forms which may be used for administration of the Plan, including those necessary to process enrollments in the Plan, designations of dependents, etc. Company will not use non-standard administrative forms without receiving Claims Administrator's written approval. D. Standard Administrative Manuals. Claims Administrator will prepare, update and provide Company and/or Plan Administrator with Claims Administrator's standard administration manual to assist in Plan administration. E. Establishing Banking Arrangements. Claims Administrator will assist Company in establishing banking arrangements for the reimbursement of Plan Benefits and payment of Administrative Fees. F. Directories. Claims Administrator will provide Company and Plan Administrator with a sample of Participating Provider Directories. The Plan Administrator is responsible for supplying provider directories to Plan Participants. G. Report Services. Claims Administrator will furnish Company and/or Plan Administrator management reports in accordance with Exhibit C, provided that the content of such reports may be modified or restricted to maintain compliance with Claims Administrator's Privacy Practices and Procedures and applicable privacy law. It is understood and agreed that the Group shall request and utilize such data for the limited purpose of satisfying "Plan Administrative Function" (as that term is defined in 45 C.F.R. § 164.504) which the Company may have with regard to the Plan. H. Additional Services. No additional services are provided by the Claims Administrator other than those expressly agreed herein. ARTICLE V - CLAIM EXPENSE AND OTHER CHARGES The Company shall pay the Claims Administrator as specified in Exhibit A for all claims paid on behalf of the Plan's Participants plus the additional amounts set forth therein. The financial arrangement set forth in Exhibit A may be modified from time to time during the initial term or any extension of this Agreement as mutually agreed upon in writing by the parties. Plan Benefits are entirely funded by the Company. Claims Administrator provides administrative and claims payment services only. Notwithstanding the termination of this Agreement, and regardless of the reason for termination, Company shall be liable to Claims Administrator for the cost of any Plan Benefit paid by Claims Administrator pursuant to this Agreement. ASO -1 g REV. 12/2004 ARTICLE VI - AUDIT Company may audit Claims Administrator's administration of Plan benefits hereunder, subject to the following conditions: A. Procedure. In case of any audit under this Audit provision, Company will give Claims Administrator notice in writing of its desire to conduct an audit. Company and Claims Administrator will agree on the scope of any audit request. The Company shall not request more than one audit per calendar year. Audits shall be conducted only for a period no greater than the two most recently completed contract years. Audits shall be conducted during normal working business hours at the offices of the Claims Administrator by an auditor mutually acceptable to the Claims Administrator and the Company which approval shall not be unreasonably withheld by either party. Claims Administrator shall provide appropriate records and documents for Company to evaluate the administration of the benefits. Company will discuss with Claims Administrator the operational details of the audit. Audits shall not be conducted for the same scope and time frame or portion of time of a previously conducted audit unless the Company is required by a governmental agency with which it has a contractual arrangement to audit a period or periods for which a final audit has been performed or in cases of fraud or suspected fraud or unless the audit identifies a systematic discrepancy in which event an audit or re -audit may be conducted of a period no greater than the four most recently completed contract years (including the current audit period) solely for the purpose of examining such systematic discrepancies. B. Confidential Information. Prior to the commencement of any audit, Company and its outside auditor, if any, will execute a written agreement reasonably satisfactory to Claims Administrator to protect the confidentiality of patient specific dental care information and Claims Administrator's proprietary or confidential information, provided that Claims Administrator will in no event be required to disclose any information in violation of applicable law. C. Types of Audits. Financial Audits. Subject to the requirements of Paragraph A and B of this Audit provision and all applicable laws, regulations and Claims Administrator's policies, Financial Audits shall be limited to an examination of Claims Administrator's records of provider charges and reimbursements for Plan benefits administered under this Agreement. Company shall reimburse Claims Administrator for the actual cost of any computer time expended as a result of any financial audit request. Further, if any financial audit request requires more than 40 hours of personnel of Claims Administrator, the Company shall reimburse the Claims Administrator for personnel time in excess of such hours at the rate of $100 per hour. ASO -1 REV. 12/2004 2. Claims Audit: (a) Subject to the requirements of Sections A and B of this Audit provision and all applicable laws, regulations and Claims Administrator's policies, the Company shall have the right under this Agreement to conduct an audit of the claims for the benefits paid under the Plan. The audit shall be coordinated with the Claims Administrator and the scope of an audit shall be limited to reviews of claims documentation, membership data and benefit summaries. Audit sampling methodology shall be mutually agreed to by the parties and must be based on the universe of claims under review. A preliminary draft of the audit report shall be submitted to the Claims Administrator fifteen days prior to issuance of the final report. (b) On an annual basis, Company will be provided with 40 hours of audit support. Company shall reimburse Claims Administrator for any additional hours of audit support at a rate of $100 an hour. (c) The provisions of this Audit section shall survive termination of this Agreement. (d) Audit reports prepared by Company or its representatives shall be reviewed by the Claims Administrator prior to issuance. ARTICLE VII - LITIGATION If litigation or arbitration proceedings are commenced by a Participant or Provider against Claims Administrator or Company, or both parties, in connection with payment of claims for Plan benefits ("Claims Litigation"), unless otherwise agreed by the parties: A. In actions asserted only against Claims Administrator: Claims Administrator will provide written notice to Company as soon as practicable and will, at Company's written request, provide Company with information with respect to the ongoing status of the Claims Litigation; and 2. Claims Administrator will select and retain counsel. B. In actions asserted against Claims Administrator and Company, unless a material conflict of interest arises between the parties, the parties will agree on a defense strategy for the action and Claims Administrator will select counsel reasonably satisfactory to Company to represent both parties. C. In actions asserted against Claims Administrator and Company where a material conflict of interest exists between the parties, each party will select and retain its own counsel. ASO -1 REV. 12/2004 D. In all litigation under this Article VII, Company shall reimburse Claims Administrator for all such legal fees, costs and disbursements, judgments or settlements unless such claims litigation was caused by acts of intentional misconduct or gross negligence by Claims Administrator in the performance of services under this Agreement. E. In all Claims Litigation the parties will provide each other with reasonable cooperation necessary in the defense of Claims Litigation; F. Company shall be liable for the full amount of any Plan Benefits paid as a result of Claims Litigation. In no event will Claims Administrator be liable for any amount of Plan benefits paid as a result of Claims Litigation. ARTICLE VIII — PRIVACY AND CONFIDENTIALITY A. Confidential Information. Claims Administrator, Company, and Plan Administrator acknowledge that in discharging their obligations under this Agreement they may disclose or make available to each other confidential information. Claims Administrator, Company and Plan Administrator agree to protect and preserve the confidential, proprietary and trade secret nature of each other's confidential information and further agree not to disclose the other's confidential information to any other person, firm or entity without obtaining the other's prior written consent unless otherwise provided by law. B. Use of Individually Identifiable Health Information. The use and disclosure of personally identifiable health information related to Participants ("Protected Information") is subject to various privacy laws, including state laws governing the privacy of personal financial and health information, the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"), and regulations adopted thereunder by the Department of Health and Human Services (45 CFR Parts 160, 162, 164 and proposed Part 142). The parties will treat all such information in accordance with those laws, and will use or disclose Protected Information received from the other only for the purposes stated in this Agreement, or to comply with judicial process or any applicable statute or regulation. C. Business Associate Addendum. The parties acknowledge and agree that on and after the final compliance date for the "Privacy Rule" established pursuant to regulations implementing the Health Insurance Portability and Accountability Act of 1996 ("HIPAA") (45 C.F.R. Parts 160 and 164), Claims Administrator shall be a "Business Associate" of the Plan (as that term is defined in 45 C.F.R. § 160.501). Accordingly, Company shall, for and on behalf of the Plan, agree to the attached "Business Associate Addendum" coincident with its execution of this Agreement. The parties further agree that this Agreement along with the Business Associate Addendum shall thereafter govern Claims Administrator's obligations regarding the use and disclosure of Protected Information when performing its functions under this Agreement. ASO -1 REV. 1212004 ARTICLE IX - TERMINATION AND RENEWAL A. This Agreement shall continue until 12:00 midnight on the termination date specified in Exhibit A, at which time, unless changed or terminated as provided herein, it shall automatically renew for a further period of twelve (12) consecutive months and thereafter from year to year. Such initial period and each successive renewal period is hereinafter called a "Contract Period". B. Upon at least sixty (60) days written notice to the other party prior to the end of any Contract Period, the Company or the Claims Administrator may request a change in the financial terms of this Agreement. If the parties are unable to agree upon such requested change within sixty (60) days of the initial notice, this Agreement will automatically terminate at the end of the Contract Period in which the request for change is made, unless the parties agree in writing to an extension thereof. C. The Company or the Claims Administrator may terminate this Agreement at the end of any Contract Period by the giving of no less than thirty (30) days written notice to the other party prior to the end of such Contract Period. D. If the amount due is not received by the end of five (5) business days from a payment due date, this Agreement may be terminated without written notification to the Company. In the event of automatic termination of this Agreement under this paragraph, the Claims Administrator, at its option, may reinstate this Agreement or enter into a new Agreement with the Company. Unless otherwise agreed, this reinstatement or new Agreement shall be on a month-to-month basis. ARTICLE X - MISCELLANEOUS A. Amendments to Comply with Law. Notwithstanding any provision contained herein to the contrary, the Company or the Claims Administrator shall have the right, for the purpose of complying with the provisions of any law or lawful order of a court or regulatory authority, to amend this Agreement, including any Exhibits hereto, or to increase, reduce or eliminate any of the benefits provided for in this Agreement for any one or more Participants who shall be enrolled under this Agreement, and each party will agree to any amendment of this Agreement which is necessary in order to accomplish such purposes. The Company also agrees to pay any change in claims expense and administrative expense that results from such amendment. If the parties cannot agree to any such change or amendment, notwithstanding any provision of this Agreement to the contrary, the Company or the Claims Administrator may terminate this Agreement as of the end of the month by the giving of sixty (60) days written notice prior thereto. B. Other Amendments. This Agreement shall be subject to amendment of modification by mutual written agreement between the Claims Administrator and Company. This Agreement supersedes all prior written or oral agreements or understandings between the parties. ASO -1 REV. 12/2004 C. Notices. Unless otherwise provided herein, all notices required or permitted to be sent in accordance with this Agreement may be either personally delivered, or sent by regular U.S. mail or nationally recognized overnight courier service, to the following addresses: To the Company at: CITY OF SAN RAFAEL 1400 FIFTH AVENUE SAN RAFAEL, CA 94901 Attention: LESLIE LOOMIS, Director of Human Resources To Claims Administrator at: United Concordia Companies, Inc. 4401 Deer Path Road Harrisburg, PA 17110 Attention: President The parties may change the address listed herein by sending notice of such change in writing to the other party in accordance with the method outlined in this Article. D. Choice of Law. Except as otherwise governed by ERISA, this Agreement is entered into pursuant to the laws of the state of (Group Sold State) and shall be interpreted pursuant to such law. E. Severability. In the event of the unenforceability or invalidity of any section or provision of this Agreement, such section or provision shall be enforceable to the fullest extent permitted by law, and such unenforceability or invalidity shall not otherwise affect any other section or provision of this Agreement and this Agreement shall otherwise remain in full force and effect. F. Assignment. Services to be provided by Claims Administrator under this Agreement may be performed in whole or in part by Claims Administrator, by any of its affiliates, or by any subcontractor selected by it or by such affiliates. Except as set forth in the preceding sentence, neither party may assign or delegate any of the rights and obligations hereunder to any third party without the prior written consent of an officer of the other party. G. Counterparts. This Agreement may be executed in any number of counterparts, each of which shall be deemed an original and constitute one and the same instrument. H. Independent Contractors. In fulfilling its obligations in connection with this Agreement and the Plan, Claims Administrator acts in the capacity of independent contractor as to Company and Plan Administrator. ASO -1 REV. 12/2004 I. Headings. Headings in this Agreement have been inserted for convenience and shall not be used to interpret or construe its provisions. IN WITNESS WHEREOF, the parties intending to be legally bound have caused this Agreement to be executed the day and the year first above written. [COMP NY CITYY OFA FF S ATTEST: By:k"'-01A-0 �OEANNE l_ ONCINI, KA NO OFF, City Clerk Title: A ty Ma na pr APPROVED AS TO FORM i=fARY 31 RAGGffIANTI, City Attorney UNITED CONCORDIA COMPANIES, INC. Title: President & CEO ASO -1 12 REV. 12/2004