The document summarizes key provisions of the Affordable Care Act that take effect between now and 2014 for employers, including requirements to provide preventive care benefits, distribute summaries of benefits and coverage, and pay fees. It outlines the employer mandate beginning in 2014, under which large employers that do not offer affordable, minimum value health coverage to full-time employees will face penalties. It also discusses subsidies available to individuals through state health insurance exchanges.

1. HEALTHCARE REFORM
Where Do Employers Go From Here?
December 6, 2012

2. These materials are intended to stimulate thought and discussion and to provide the reader with
useful ideas and guidance in the areas of healthcare reform. The materials do not constitute, and
should not be treated as, legal advice. Although we have made every effort to ensure the
accuracy of these materials, neither the authors nor Cox Smith Matthews Incorporated assumes
any responsibility for any individual’s reliance on the written information presented during this
presentation. Laws and regulations are subject to change at any time.
This PowerPoint presentation is an educational tool that is general in nature and for purposes of
illustration only. The materials in this presentation are not exhaustive, do not constitute legal
advice and should not be considered a substitute for consulting with legal counsel. Cox Smith
has no obligation to update the information contained in this presentation.
CIRCULAR 230 DISCLOSURE: Pursuant to Department of Treasury Circular 230, this
presentation is not intended or written to be used, and may not be used by the recipient, for the
purposes of avoiding any federal tax penalty which may be asserted.
© 2012 Cox Smith Matthews Incorporated 2

3. The Supreme Court’s Decision: In a Nutshell
 National Federation of Independent Businesses v.
Sebelius
 Decided on June 28, 2012
 567 U.S. ___ (2012).
 Authored by Chief Justice Roberts
 Joined in various parts by Justices Ginsburg, Breyer,
Sotomayor, and Kagan
 Dissented to in most parts by Justices Scalia, Kennedy,
Thomas, and Alito
© 2012 Cox Smith Matthews Incorporated 3

4. The Supreme Court’s Decision: In a Nutshell
 Individual mandate held not to be a valid exercise of
Congress’s power under the Commerce Clause
 Upheld instead under Congress’s power to “lay and
collect taxes”
 Medicaid Expansion: invalidated provision that threatens
states with loss of Medicaid funding if fail to comply with
expansion
 BUT expansion stands if penalty is only that states
lose new funding if do not comply
© 2012 Cox Smith Matthews Incorporated 4

5. KEY DEFINITIONS
 Grandfathered Coverage:
 Group health plan coverage existing on March 23, 2010
 Applies separately to each benefit package.
 How to lose grandfathering:
 eliminate benefits
 increase copay percentage
 increase fixed costs over prescribed amounts
 reduce level of employer contribution
 add or decrease annual dollar limits.
© 2012 Cox Smith Matthews Incorporated 5

6. KEY DEFINITIONS
 Grandfathered Coverage (cont’d)
 Okay to:
 Add new participants
 Change insurance companies after 11/15/10
 Change TPAs
 Increase premiums (without reducing employer contribution)
 Amend plan to comply with reform.
 Notice to participants required.
 May amend plans to comply with law changes.
© 2012 Cox Smith Matthews Incorporated 6

7. August 1, 2012: Preventive Care Benefits
 New women’s preventive care requirements (including
contraception) effective for the first plan year after August
1, 2012
 This is in addition to previously required preventive care
benefits:
 certain evidence-based items or services;
 certain immunizations;
 for minors, certain preventive care and screenings;
 for women, additional preventive care and screenings
including breast cancer screening, mammography, and
prevention
© 2012 Cox Smith Matthews Incorporated 7

8. September 23, 2012: Summary of Benefits and
Coverage (“SBC”)
 SBCs must be provided as of the first day of the first
open enrollment period that begins on or after
September 23, 2012 (in general, the open enrollment
period for 2013 plan years).
 For special enrollees/new hires, SBCs must be provided
beginning on the first day of the first plan year beginning
on or after September 23, 2012 (for calendar year plans,
January 1, 2013).
© 2012 Cox Smith Matthews Incorporated 8

9. Summary of Benefits and Coverage (“SBC”)
 Plan must notify enrollees of mid-year material
modifications not later than 60 days prior to effective
date; changes for new plan year may be disclosed in
SBC in connection with open enrollment.
 May be provided with SPD and other materials as long
as displayed “prominently” at the beginning.
 MUST use DOL template, glossary, and instructions
(caveat for self-insured plans that do not fit template).
 No penalties in first year if good faith efforts to comply.
© 2012 Cox Smith Matthews Incorporated 9

10. Disclosure of Expenses & Insurer Rebates
(“Medical Loss Ratio”)
 Rules apply to insurers, but may indirectly impact plan
insurance costs.
 Insurer must report to HHS how premium revenue is
expended.
 Insurer must rebate policyholders to extent that premium
ratio exceeds certain thresholds.
 Fiduciary duty rules govern receipt of rebates by plan
sponsors.
© 2012 Cox Smith Matthews Incorporated 10

11. Disclosure of Expenses & Insurer Rebates
(“Medical Loss Ratio”)
 Note: If employees pay premiums on a pre-tax basis, rebates paid
to employees in cash or in the form of a premium reduction will be
considered income and subject to employment tax.
 A rebate paid as a premium reduction is taxable because it
reduces the employee's salary reduction contribution. A rebate
paid in cash is treated as additional compensation and is taxable
as such.
 If premiums paid on an after-tax basis, the rebate would not be
subject to employment taxes regardless of whether it was paid in
cash or used to reduce the amount of the employee's health
insurance premium payment.
© 2012 Cox Smith Matthews Incorporated 11

12. October 1, 2013: Fees for Research Trust Fund
 Insurers and employers with self-insured plans pay:
 2013: $1.00 times average lives covered
 2014 – 2019: $2.00 times average lives covered
 Purpose: Fund comparative clinical effectiveness research
 When: File return reporting fee by July 31 of the calendar
year immediately following the last day of the plan year.
 This is effective for all plan years that end on or after
October 1, 2012.
 Thus, a January 1 – December 31, 2012 plan will file July
31, 2013. But a February 1, 2012 – January 31, 2013 plan
would not have to file until July 31, 2014.
© 2012 Cox Smith Matthews Incorporated 12

13. 2013: Health FSA Reimbursement Limit
 Current Law: No reimbursement limit required – plan
sponsors may choose their limit.
 A $2,500 limit applies on a plan year basis and is
effective for cafeteria plan years beginning after
December 31, 2012.
 In the case of a short plan year, the limit must be
prorated.
 The limit is indexed for cost-of-living adjustments for
plan years beginning after December 31, 2013.
© 2012 Cox Smith Matthews Incorporated 13

14. 2013: Health FSA Reimbursement Limit
 Cafeteria plan documents must be amended to reflect
the $2,500 limit.
 Cafeteria plan sponsors have until December 31,
2014 to amend their plans to conform to the new
requirements, so long as the amendment is effective
retroactively and the plan operates in compliance for
plan years beginning after December 31, 2012.
© 2012 Cox Smith Matthews Incorporated 14

15. 2013: Increased Hospital Insurance Tax
 Current Law: Employer must withhold 1.45% for all
employees as the employees’ portion.
 January 1, 2013: Employee portion of FICA is increased
for high income taxpayers by 0.9%. Employer portion
remains the same.
 Threshold depends on filing status, but employer must
withhold extra percentage starting at $200,000.
© 2012 Cox Smith Matthews Incorporated 15

16. 2013: Elimination of Tax Deduction for
Medicare Part D Employer Subsidies
 Current Law: Employers can deduct full amounts paid
for retiree prescription drugs, including the portion that is
subsidized by government and is excluded from income.
 January 1, 2013: Can no longer deduct subsidized
amount paid for retiree prescription drugs.
© 2012 Cox Smith Matthews Incorporated 16

17. 2013: W-2 Reporting
 An employer that issues more than 250 Form W-2s must
report “cost” of employees’ health insurance on form.
 Coverage under all plans (except Health FSA, HSA,
Archer MSA) is aggregated.
 “Cost” includes employer and employee portion: may
use COBRA method to determine cost (not counting 2%
administrative fee allowed under COBRA).
 Reporting required for 2012 tax year (i.e., 2013 W-2).
© 2012 Cox Smith Matthews Incorporated 17

18. March 1, 2013: Notification re State Exchanges
 By March 1, 2013, employers must notify current
employees (and future employees at time of hire) of:
 existing exchange’s services and contact information
 availability of premium assistance for exchange-
purchased insurance if employer coverage is
“unaffordable” (employer contribution < 60%
 Unavailability of employer subsidy for insurance
purchased through exchange
© 2012 Cox Smith Matthews Incorporated 18

19. Notification re State Exchanges
 Premium assistance takes the form of subsidy payments
to a qualified health plan on behalf of the individual.
 Take the form of an advanced credit payment.
 Exchange will determine whether individual qualifies for
premium assistance.
 Has been challenged as to whether premium assistance
is available only under state exchanges or under federal
exchange as well.
© 2012 Cox Smith Matthews Incorporated 19

20. 2014: Coverage Mandate – Large Employers
 Supreme Court case did not address “pay or play”
provision.
 An employer with at least 50 full-time equivalents must
provide “Minimum Essential Coverage” or pay penalty.
 Coverage requirement applies to full-time employees.
 Full-time employees = 30 hours per week (guidance
forthcoming on determining hours of service).
 Counting of part time is up in the air.
 Aggregation rules apply when identifying “employer.”
© 2012 Cox Smith Matthews Incorporated 20

21. 2014: Coverage Mandate – Minimum Essential
Coverage
 Minimum Essential Coverage:
 A yet to be determined benefits package provided by any
of the following four vehicles:
1. Government programs
2. Eligible employer-sponsored plans
3. Individual market plans
4. Grandfathered plans
 Most employer-provided group health coverage will
meet the very broad definition of “minimum essential
coverage.”
© 2012 Cox Smith Matthews Incorporated 21

22. 2014: Coverage Mandate – Large Employers
 Employers will be required to make an “assessable
payment” to IRS if:
 Any full-time employee is certified to the employer as
having purchased health insurance through an
Exchange and a tax credit or cost-sharing reduction is
allowed (i.e., the full-time employee receives a
subsidy)
 And:
© 2012 Cox Smith Matthews Incorporated 22

23. 2014: Coverage Mandate – Large Employers
 The employer does not offer healthcare coverage for all
its full-time employees; or
 Offers minimum essential coverage that either:
 is “unaffordable” (i.e., > 9.5% of employee’s income
per W-2, for self coverage); or
 Does not provide “minimum value” (i.e., employer’s
share of the total allowed “cost of benefits” < 60%,
guidance pending).
© 2012 Cox Smith Matthews Incorporated 23

24. 2014: Coverage Mandate – Subsidies through
the Exchange
 The subsidy, or credit, is designed to make health
insurance affordable to taxpayers who:
 Have a household income for the tax year that is
between 100% and 400% of the federal poverty level,
 Cannot be claimed as a dependent by another
taxpayer, and
 Who are not eligible for other qualifying coverage,
such as Medicare, or “affordable” employer-
sponsored health plans that offer “minimum value.”
© 2012 Cox Smith Matthews Incorporated 24

25. 2014: Coverage Mandate – Subsidies through
the Exchange
 When an eligible individual purchases insurance through
the Exchange, the Exchange makes subsidy payments
to the qualified health plan on behalf of the individual.
 Payments take the form of an advance credit payment
(“monthly premium assistance amount”) under the
Internal Revenue Code.
 The Exchange determines whether the individual meets
the income and other requirements for advance credit
payments, and the amount of the advance payments.
© 2012 Cox Smith Matthews Incorporated 25

26. 2014: Coverage Mandate – Notice to Employee
of Premium Assistance
 Exchange will notify employer of applicant’s eligibility to
receive subsidy.
 Notice must include:
 Employee’s identity
 Notice that employee has been determined eligible for
premium assistance
 Statement that employer may be liable for shared
responsibility payment
 There is an opportunity to appeal (guidance
forthcoming on appeal process).
© 2012 Cox Smith Matthews Incorporated 26

27. 2014: Coverage Mandate – Large Employers
NOT OFFERING A HEALTH PLAN
 Applies when employer does not offer minimum essential
coverage to “its full-time employees,” which IRS proposes to
interpret as “substantially” all full-time employees, with few
exceptions.
 Assessable payment/penalty tax = “applicable payment
amount” times the number of full-time employees (less 30)
during the month.
 2014 “applicable payment amount” is $166.67 with respect to
any month (that is, 1/12 of $2,000). Adjusted for inflation
subsequently.
 So for 2014, annualized penalty = $2,000 x number of full-
time employees minus 30.
© 2012 Cox Smith Matthews Incorporated 27

28. 2014: Coverage Mandate – Large Employers
OFFERING A HEALTH PLAN
 Penalty tax assessable payment = $250 (1/12 of $3,000,
adjusted for inflation after 2014) times the number of full-
time employees for any month who receive premium tax
credits or cost-sharing assistance (this number is not
reduced by 30).
 Tax is capped at applicable penalty had no coverage
been offered: $166.67 (1/12 of $2,000, adjusted for
inflation after 2014), times the employer's total number of
full-time employees, reduced by 30.
© 2012 Cox Smith Matthews Incorporated 28

29. Excise Tax on Individuals
 Starting in 2014, individuals who do not have Minimum
Essential Coverage will be subject to an excise tax. IRC
§ 5000A
 Amount of penalty will phase in and may vary
 Payment to be collected on individual’s annual tax
return
© 2012 Cox Smith Matthews Incorporated 29

30. Information Returns
 Starting in 2014, Employers must report insurance
coverage information to the covered individual and IRS.
 Form will require employer to certify it offers Minimum
Essential Coverage.
 Form to request name and Social Security number of
all full-time employees who are covered.
© 2012 Cox Smith Matthews Incorporated 30

31. 2014: Plan Design Reforms
 No annual dollar limit on “Essential Health Benefits” on
or after January 1, 2014
 Maximum 90 day waiting period
 No pre-existing condition exclusions or limitations
 Grandfathered plans must provide coverage for adult
dependent child, whether or not the child is otherwise
eligible for other employer-sponsored coverage.
© 2012 Cox Smith Matthews Incorporated 31

32. KEY DEFINITIONS
 Essential Health Benefits include the following general
categories of benefits (states to flesh out details):
a. ambulatory patient services;
b. emergency services;
c. hospitalization;
d. maternity and newborn care;
e. mental health and substance use disorder
services, including behavioral health treatment;
f. prescription drugs;
© 2012 Cox Smith Matthews Incorporated 32

33. KEY DEFINITIONS
g. rehabilitative and habilitative services and
devices;
h. laboratory services;
i. preventive and wellness services and chronic
disease management;
j. pediatric services, including oral and vision care;
and
k. no stand-alone dental or vision.
© 2012 Cox Smith Matthews Incorporated 33

34. 2014: Plan Design Reforms
 Plans may vary premium rates plan only for specific
factors, such as coverage of an individual or family,
geographic area, age, and tobacco use.
 Guaranteed Availability and Renewability of Coverage
 Insurers must accept every employer and individual in
the state who applies, and must renew such
coverage.
 Grandfathered plans are exempt.
 Clinical Trials
 Cannot deny coverage for participation in clinical
trials.
© 2012 Cox Smith Matthews Incorporated 34

35. 2014: Plan Design Reforms
 Individual and Small Group Insurance Markets
 Health plans offered in the individual and small group
markets, both inside and outside of the Exchanges, must
offer a core package of “essential health benefits
(“EHB”).
 Proposed rule defines EHB based on state-specific
benchmark plan. States will select a benchmark plan
from among several options identified in the proposed
rule, and that all plans that cover EHB must offer
benefits that are substantially equal to the benefits
offered by the benchmark plan.
© 2012 Cox Smith Matthews Incorporated 35

36. 2014: Plan Design Reforms (continued)
 Non-grandfathered health plans in the individual and
small group markets must meet certain Actuarial Values
(“AVs”), or metal levels:
 60 percent for a bronze plan, 70 percent for a silver
plan, 80 percent for a gold plan, and 90 percent for a
platinum plan.
 Also catastrophic-only coverage with lower AV for
eligible individuals. HHS is providing a publicly
available AV calculator, which issuers would use to
determine health plan AVs based on a national,
standard population, as required by law.
© 2012 Cox Smith Matthews Incorporated 36

37. 2014: Plan Design Reforms
 No discrimination based on health status
 As to benefits or coverage, including continued
eligibility, based on health status factors
 Health Status Factors:
 health status
 medical condition (physical or mental)
 claims experience
 receipt of healthcare
 medical history
© 2012 Cox Smith Matthews Incorporated 37

38. 2014: Plan Design Reforms
genetic information

 evidence of insurability
 disability; or
 any other health factor, per HHS regulations
 Grandfathered plans are exempt.
© 2012 Cox Smith Matthews Incorporated 38

39. 2014: Plan Design Reforms
 Cost-Sharing (co-pays, deductibles, co-insurance)
 Cannot exceed the limitations provided in the bill for
essential health benefits.
 Based on maximum out-of-pocket expenses for high
deductible health plans, adjusted for cost of living
 2014 numbers not yet available.
 Deductible: $2000 for self-only and $4000 for family
 Grandfathered plans are exempt.
© 2012 Cox Smith Matthews Incorporated 39

40. 2014: Plan Design Reforms
 Expanded Wellness Program
 Financial incentives for participation in a wellness
program can be based upon health status, including
up to 30% of the cost of plan coverage.
 Additionally, for any wellness program designed to
promote tobacco cessation, the new proposed
regulations would allow a reward up to 50% of the
cost of plan coverage.
 Wellness program standards apply to grandfathered
plans.
© 2012 Cox Smith Matthews Incorporated 40

41. 2014: State Exchange Reimbursement =
Qualified Benefit
 Reimbursement or direct payment for insurance
premiums on state Exchange will be a qualified benefit
under a cafeteria plan.
 Exception if employer offers Exchange enrollment
© 2012 Cox Smith Matthews Incorporated 41

42. 2018: Cadillac Tax
 Excise tax will be imposed on insurers on high cost
employer-sponsored health coverage:
 40% nondeductible excise tax levied on insurers,
employers (for HSAs and MSAs), and plan
administrators if annual premium exceeds $10,200 for
single coverage and $27,500 for family coverage
 Note: This tax is calculated ONLY on the excess
amount over the annual limitation (e.g., one dollar
over $10,200 $0.40 tax over 12 months).
© 2012 Cox Smith Matthews Incorporated 42

43. Waiting for Guidance: Automatic Enrollment
 Employers with over 200 FTEs that offer health plans
must automatically enroll new employees.
 Notice must be provided to employee of opportunity
to opt out of automatic enrollment in employer’s
health plan.
 Watch for Regulations. Compliance is not expected
before regulations are issued.
© 2012 Cox Smith Matthews Incorporated 43

44. Waiting for Guidance: Discrimination Testing
 Insured health plans must pass some of IRC § 105(h)
discrimination testing or employer pays excise tax ($100
per day per person).
 Grandfathered plans are exempt.
 Effective first plan year beginning on or after September
23, 2010
 Government has announced nonenforcement policy
pending regulations
© 2012 Cox Smith Matthews Incorporated 44

45. Waiting for Guidance: Reporting and
Disclosure Requirements
 Plans must submit to HHS, State Insurance
Commissioner, and make available to the public, certain
information, in plain language, in relation to coverage
transparency:
 claims payment policies and practices
 periodic financial disclosures
 data on enrollment and disenrollment
© 2012 Cox Smith Matthews Incorporated 45

46. Reporting and Disclosure Requirements
 data on the number of claims that are denied
 data on rating practices
 information on cost-sharing and payments with
respect to any out-of-network coverage
 information on enrollee and participant rights
under this title
 other information as determined appropriate by
HHS
© 2012 Cox Smith Matthews Incorporated 46

47. Reporting and Disclosure Requirements
 DOL will provide rules.
 Grandfathered plans are exempt from these
requirements.
 Effective first plan year beginning on or after September
23, 2010.
© 2012 Cox Smith Matthews Incorporated 47

48. Waiting for Guidance: Grants to Small
Businesses for Wellness Programs
 Grants from 2011 to 2015, for new wellness programs
 Only for employers with fewer than 100 employees working
25+ hours per week
 HHS to outline requirements, but will concern:
 Health awareness initiatives
 Maximizing employee engagement
 Changing unhealthy behaviors and lifestyle choices
 Providing supportive environment.
© 2012 Cox Smith Matthews Incorporated 48

49. Waiting for Guidance: Efficiency Standards and
Wellness Promotion Reporting Requirements
 HHS to develop reporting requirements (and penalties!).
 Annual report submitted by group health plan to HHS and
made available during open enrollment.
 Report must describe activities that:
 improve health outcomes
 prevent hospital readmission
 improve patient safety and reduce medical errors
 target health and wellness
 Grandfathered plans are exempt.
© 2012 Cox Smith Matthews Incorporated 49

50. Waiting for Guidance: Electronic Operating
Rules – Phase 1
 In July 2011, HHS issued regulations adopting operating
rules for two HIPAA electronic transactions.
 Eligibility for health plan
 Healthcare claim status
 HIPAA-covered health plans must comply by January 1,
2013.
 Regulations adopt standards developed by Council for
Affordable and Quality Healthcare.
© 2012 Cox Smith Matthews Incorporated 50

51. 2013: Electronic Operating Rules – Phase 1
 Plan must maintain adequate documentation that
demonstrates:
 the plan conducts electronic transactions for health
plan eligibility and health claim status transactions in
compliance with the HHS regulations; and
 the plan completed end-to-end testing for transactions
with vendors (e.g., hospitals and physicians).
© 2012 Cox Smith Matthews Incorporated 51

52. 2013: Electronic Operating Rules – Phase 1
 Plan must ensure business associates comply, too.
 Enforcement through periodic audits and penalties
© 2012 Cox Smith Matthews Incorporated 52

53. 2014: Electronic Operating Rules - Phase 2
 Plans to adopt and implement uniform operating rules
(established by HHS) for electronic fund transfers and
healthcare payments and remittance
 HHS Regulations issued January 2012
 Effective date: January 1, 2014
© 2012 Cox Smith Matthews Incorporated 53

54. 2014: Electronic Operating Rules - Phase 2
 Plans to use Unique Health Plan Identifier (“HPID”)
 Compliance date for large plans: October 1, 2014; small
plans: October 1, 2015
 Plans can obtain HPID’s beginning October 1, 2012
through a national enumeration system.
 Covered entity must use HPID when it identifies a health
plan in a standard transaction.
© 2012 Cox Smith Matthews Incorporated 54

55. 2014: Electronic Operating Rules - Phase 3
 Plans to adopt and implement uniform operating rules (to
be established by HHS) for:
 Health claims or equivalent encounter info
 Enrollment and disenrollment in a health plan
 Health plan premium payments
 Referral certifications and authorizations
 HHS Regulations no later than July 2014
© 2012 Cox Smith Matthews Incorporated 55

56. What should I have done in 2010?
 Weigh benefits of grandfathered status versus costs of
continued compliance.
 Evaluate cost savings of existing retiree plans (net of
compliance expenses).
 Determine whether your business is eligible for small
business tax credit.
 Establish COBRA cost method for each plan (for 2011
reporting requirement).
 No dumping of participants into High-Risk Pool
© 2012 Cox Smith Matthews Incorporated 56

57. What should I have done in 2010 - 2011?
 Delete lifetime dollar limits on “Essential Health Benefits”
from plans.
 Restrict annual dollar limits on “Essential Health
Benefits.”
 Revisit dependent coverage provisions.
 Review preventive care benefits and eliminate
deductibles and co-pays.
 Amend plans to allow permitted rescission.
© 2012 Cox Smith Matthews Incorporated 57

58. What should I have done in 2010 - 2011?
 Review eligible classes, differing waiting periods,
differing benefits, and differing premiums to identify and
weed out prohibited discrimination.
 Review and amend plan claims process.
 Eliminate restrictions on designation of in-network
primary physicians.
 Eliminate restrictions on designation of in-network
primary care pediatricians.
© 2012 Cox Smith Matthews Incorporated 58

59. What should I have done in 2010 - 2011?
 Eliminate prior authorization and in-network
requirements for emergency care.
 Eliminate pre-authorization for access to OB/Gyns.
 Confer with insurer or TPA about data collection and
reporting assistance.
© 2012 Cox Smith Matthews Incorporated 59

60. COX SMITH MATTHEWS INCORPORATED
EMPLOYEE BENEFITS ATTORNEYS:
Mary M. Potter William M. Fisher
L. Katherine Noll Jillian L. Gordon
Joshua A. Sutin
112 E. Pecan Street, Suite 1800
San Antonio, Texas 78205
(210) 554-5500 tel
(210) 226-8395 fax
www.coxsmith.com
This PowerPoint presentation is an educational tool that is general in nature and for purposes of
illustration only. The materials in this presentation are not exhaustive, do not constitute legal advice
and should not be considered a substitute for consulting with legal counsel. Cox Smith Matthews
Incorporated has no obligation to update the information contained in this presentation.
© 2012 Cox Smith Matthews Incorporated 60