Transcript www.harrisbeach.com

Health Care Reform:
Understanding the Law and
Compliance Requirements and
Assessing What You Need To Be Doing Now
Fall 2013 Training Program
Presented By:
Karlee S. Bolaños, Esq.
Joshua D. Steele, Esq.
William Q. Lowe, Esq.
harrisbeach.com
(585) 419-8742
99 Garnsey Road
Pittsford, New York 14534
Agenda





General Overview
The Employer Mandate and How To Avoid Liability
Determining Who is a Full-Time Employee
 Hours of Service
 The Look Back and Stability Periods
 New Employees, Rehired Employees, Leaves of
Absence
Calculation and Assessment of the play-or-pay penalty
 Including an in-depth discussion of the Affordability Safe
Harbor
Additional Issues
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
2
Exchange Notices
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
3
Exchange Notices




Employers must begin to provide annual notices to employees about
State and Federal Exchanges – deadline annually is Oct 1
On Sept 11, 2013, the USDOL announced there will be no penalty
imposed on employers that fail to distribute to workers a notice about
available coverage under state and federal government run health
insurance exchanges (referred to as the "health insurance
marketplace")
It is still prudent to provide the notice (all employers covered by the
FLSA must provide) – but I recommend customization in 2014.
DOL issued model notices at:
http://www.dol.gov/ebsa/healthreform/index.html - There are two
versions (one for employers who do offer health plans and one for
employers who do not offer health plans)
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
4
Overview of PPACA
Karlee S. Bolaños, Esq.
(585) 419-8742
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5
Overview: The Law and Regulations

March 23, 2010: The Patient Protection and Affordable Care Act,
“PPACA,” more commonly referred to as the Affordable Care Act,
“ACA,” was passed

Immediate changes took effect as of the first day of the plan year
beginning on or after September 23, 2010 (January 1, 2011 for
calendar year plans) – 6 months after enactment

Employer play-or-pay mandate and the accompanying employer
penalties that were initially set to take effect in 2014 have been delayed
until 2015

Employers should be analyzing, planning and taking action in 2013 and
2104 in order to prepare for 2015
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
6
Key Definitions/Concepts



Large Employer = 50 or more full-time + full-time equivalent employees.
Full-time employee threshold = 30 “hours of service” per week.
Hours of service =




Hours for which an employee is paid, or entitled to payment, for the performance
of duties
Hours for which an employee is paid, or entitled to payment, for a period of time
during which no duties are performed due to vacation, holiday, illness, disability,
layoff, jury duty, etc.
Employer = Common law definition is very broad, includes federal,
state, and local governmental entities.
Employee = Common law definition, an employment relationship exists
when the person for whom the services are performed has the right to
control and direct the individual who performs the services.
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
7
Key Definitions/Concepts

Minimum essential coverage = Coverage that meets minimum
thresholds that will be set by IRS/HHS. Factors include essential
health benefits covered by the plan and cost-sharing
requirements. Your health insurance provider should ensure that
coverage offered constitutes minimum essential coverage.

Both employer penalties under the shared responsibility
provisions (the employer mandate) are only triggered by a fulltime employee receiving government subsidized coverage
through the state-run exchange.
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
8
Shared Responsibility Provisions
2015 Play-or-Pay Penalties

4980H(a) Penalty: If a large employer does not offer minimum essential
coverage to 95% of its full-time employees and their dependents, it will be
subject to a penalty of $2,000 for each full-time employee in excess of 30
employees per year.


(# full-time employees – 30) x $2,000 = annual penalty
4980H(b) Penalty: A large employer that does offer “minimum essential
coverage” to 95% of its full-time employees and their dependents may still
face a penalty if the coverage was not “affordable” or failed to meet a
“minimum value” threshold. Penalty is equal to the lesser of: (a) monthly
penalty of 1/12 of $3,000 multiplied by the number of full-time employees
who receive government subsidized coverage through the exchange, and
(b) the 4980H(a) penalty.
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
9
Potential Annual Penalties for Large Employers
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
10
The Mandate and
How to Avoid Liability
Karlee S. Bolaños, Esq.
(585) 419-8742
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11
Guidance on How to Avoid Liability

There are four main factors relevant to determining whether an
employer will be subject to a penalty:
1.
2.
3.
4.
Is the employer a “large employer”
What employees constitute “full-time employees”
Are any of the currently offered plans “affordable”
Do the affordable plans provide the required “minimum value”

On December 28, 2012, the IRS released proposed regulations that
address, and provide guidance on, the four main determining factors.

Employers must utilize the rules set forth in the proposed regulations to
ensure they will avoid penalties in 2015.
If final regulations are more restrictive, employers who have complied
with the proposed regulations will be provided with sufficient time to
come into compliance with the final regulations.

Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
12
Who Is a
Full-Time Employee?
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
13
The Full-Time Employee Issue




Even though part-time employees’ hours of service are
counted for purposes of determining whether an employer is a
"large" employer, the play-or-pay penalty only applies with
respect to full-time employees.
Therefore, the determination of whether an employee is
full-time or part-time is critical.
With respect to any month, a full-time employee is a person
who is employed for an average of at least 30 hours of
service per week.
Remember the difference between hours of service and hours
of work.
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
14
The Full-Time Employee Issue
Calculating Hours of Service

Hourly Employees


Employers must calculate actual hours of service from records
of hours worked and hours for which payment is made or due
Non-Hourly Employees



Actual hours of service and hours for which payment is
made or due
Daily equivalency (8 hour day)
Weekly equivalency (40 hour weeks)
Note: The rules prohibit the use of the daily or weekly equivalency
method if the result would be to understate substantially an
employee’s hours of service such that it would cause an
employee not to be treated as full-time.
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
15
The New Measurement and Stability Periods

For many employees it is difficult or impossible to
accurately project the number of hours he/she will
work in a week/month


Presents issues when determining who must be
offered coverage
Safe Harbor Rules

Allow employers to avoid liability based on inaccurate
projections through the use of measurement and
stability periods
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
16
The New Measurement and Stability Periods
(cont.)
Key Concepts




Standard Measurement Period: A period of time of at least 3, but no more than 12,
consecutive months that an applicable large employer selects and uses in determining
whether an ongoing employee is a full-time employee under the look-back
measurement method.
Initial Measurement Period: A time period of at least 3 but not more than 12
consecutive calendar months used as part of the process of determining whether
new variable hour employees are full-time employees under the look-back
measurement method.
Stability Period: A period of time that follows, and is associated with, a standard or
initial measurement period. Employee status as full-time or part-time is determined by
the previous measurement period and remains locked in during the stability period.
Administrative Period: An optional period of no more than 90 days beginning
immediately following the end of a measurement period and ending immediately before
the start of the associated stability period.

Advisable to have coincide with open enrollment period
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
17
The New Measurement and Stability Periods
(cont.)
Types of Employees


Ongoing employees
New employees (Full-Time and Variable Hour)
Categories of Employees

Employers may use measurement periods and stability periods that
differ either in length or in their starting and ending dates for the
following categories of employees:
1.
2.
3.
4.
Each group of collectively bargained employees covered by a separate
collective bargaining agreement;
Collectively bargained employees and non-collectively
bargained employees;
Salaried employees and hourly employees;
Employees located in different states
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
18
The New Measurement and Stability Periods
(cont.)
Generally for Ongoing Employees




Employers may select a period of time between three months and one
year to use as the look-back, “standard measurement period”
If the employee was employed on average at least 30 hours per
week during the look-back period then the employee must be
treated as full-time during a corresponding stability period regardless
of the number of hours of service the employee actually works in
stability period
The duration of the stability period must be the greater of six
consecutive calendar months or the length of the look-back period
The employer determines the months in which the standard
measurement period starts and ends, provided that the determination
must be made on a uniform and consistent basis for all employees in
the same category
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
19
The New Measurement and Stability Periods
(cont.)
New Employees


Previous guidance made major distinctions between current and new
employees - the new rules eliminate much of the distinction
For all new employees, employer must determine whether, at his/her
start date, the employee is “reasonably expected” to work full time


If “reasonably expected” to work 30 hours on average, an employer must
offer coverage within three months to avoid liability
If unclear, the employee will be treated as a Variable Hour or Seasonal
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
20
The New Measurement and Stability Periods
(cont.)
New Employees: Variable Hour and Seasonal

Variable Hour Employee: Based on the facts and circumstances at
the employee’s start date, it cannot be determined whether the
employee is reasonably expected to work on average at least 30
hours per week


For 2014, this also includes individuals expected to work 30 or more hours per
week but whose employment is expected to be of “limited duration”
Seasonal Hour Employee: Term is not specifically defined.
Employers are to use a “reasonable good faith interpretation” of
the term.

Examples being agricultural workers or retail workers employed only during
holiday seasons
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
21
The New Measurement and Stability Periods
(cont.)




For new Variable Hour employees and Seasonal employees, an
employer may determine whether a new employee is full-time by
using an initial measurement period of between 3 and 12 months that
begins on any date between the employee’s start date and the first
day of the calendar month following the start date
The stability period for such employees must be the same length as
the stability period for ongoing employees
Each Variable Hour/Seasonal employee will have his/her own initial
measurement and stability periods
New variable hour employees are eventually transitioned from
their initial measurement period to the employer’s general
measurement period.
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
22
The New Measurement and Stability Periods
(cont.)
Status Changes and Rehires

A new variable hour or seasonal employee who has a change in
employment status to a full-time position during the initial
measurement period must be treated as a full-time employee as of:



the first day of the fourth month following the change in employment status;
or
if earlier, and the employee averages more than 30 hours of service
per week during the initial measurement period, the first day of the
first month following the end of the initial measurement period
(including any optional administrative period applicable to the initial
measurement period)
Break in Service Rule: If an employee does not earn an hour of
service for 26 consecutive weeks and is rehired, their status (as fulltime, variable or seasonal) will be re-determined at the time of rehire
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
23
The New Measurement and Stability Periods
(cont.)
Unpaid Leaves of Absence


The new rules created a method for averaging hours during the
look back period when an employee was on unpaid leave (such as
FMLA or USERRA leave) or when an employee worked for only a
portion of the calendar year
Average the hours of work per week during the measurement
period, excluding special unpaid periods, and use that as the
average for the entire measurement period
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
24
Hours of Work
Special Rules for Educational Institutions



The regulations address special issues presented in educational
institutions by providing an averaging method for “employment break
periods” that generally would result in an employee who works
full-time during the active portions of the academic year being treated
as a full-time employee.
Employment break period = Period of at least 4 consecutive weeks
during which an employee is not credited with an hour of service
(summer vacation).
Under this method, employers may either:
 Exclude employment break periods and determine whether the employee had at least 30 hours of
service per week during the school year; or
 Calculate the employee’s average number of weekly hours of service during the school year and
treat the employee as if he/she earned the same average during the summer months

Credit maximum per calendar year is 501 hours of service.
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
25
Determining Full-Time Employees: What do
you need to do now?




You need to determine what measurement/stability periods you would
like to use.
Most employers are choosing to use a 12 month measurement and
stability period.
Most employers are not utilizing different measurement and
stability periods for different categories of employees –
administrative convenience.
Employer’s need to do this now so they know who will be considered
“full-time” employees on January 1, 2015.
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
26
Example of 12 Month Standard
Measurement Period
Standard Measurement Period # 1
November 1, 2013 to October 31, 2014.
Administrative Period # 1
November 1, 2014 to December 31, 2014.
Stability Period # 1
January 1, 2015 to December 31, 2015.
Standard Measurement Period # 2
November 1, 2014 to October 31, 2015.
Administrative Period # 2
November 1, 2015 to December 31, 2015
Stability Period # 2
January 1, 2016 to December 31, 2016.
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
27
Ensuring that You “Offer” Coverage



Section 4980H(a) of the ACA provides that an applicable large
employer is liable for a penalty if, for any month, any full-time
employee is certified as receiving a premium tax credit or subsidy
and the applicable large employer fails to offer its full-time employees
(and their dependents) the opportunity to enroll in minimum
essential coverage
The regulation clarifies that an “offer” will exist if an employee has an
effective opportunity to elect to enroll (or decline to enroll) at least
once per year
The regulation also clarifies that certain recordkeeping requirements
should be followed to demonstrate that an offer of coverage was
made by the employer to the employee and the dependent
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
28
Is Coverage Offered to
Full-Time Employees
Affordable?
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
29
Determining “Affordability”


To avoid all penalties, a covered employer must provide self-only health
plan coverage that is “affordable” (Family coverage does not need to be
“affordable”). Generally, a plan is not affordable if the employee’s
premium contribution exceeds 9.5% of his/her household income.
Employers may take advantage of one of three safe harbors to
determine whether the plan they offer is “affordable”:




Form W-2: Employee premium share does not exceed 9.5% of the amount
in Box 1
Rate of Pay: Employee premium share does not exceed 9.5% of the total of
the employee’s hourly rate of pay multiplied by 130 hours per month
Federal Poverty Line: Employee premium share does not exceed 9.5% of
the federal poverty line for one person
Remember, only the premium for self-only coverage with the employer’s
lowest-cost minimum value plan needs to be “affordable”
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
30
Details of the W-2 Safe Harbor


Application of the W-2 safe harbor is determined after the end
of the calendar year and on an employee-by-employee basis,
taking into account the Form W-2 wages and the required
employee contribution for that year
For an employee who was not a full-time employee for the
entire calendar year, the Form W-2 safe harbor is applied by
adjusting the employee's Form W-2 wages to reflect the
period when the employee was offered coverage and then
comparing those adjusted wages to the employee share of the
premium during that period
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
31
Affordability: What do you need to do now?




After utilizing the selected measurement period to determine
who constitutes “full-time” employees, employers must ensure
that coverage offered to those employees is affordable.
Determine which “safe-harbor” works the best for your
work force.
Identify employees or categories of employees that are in the
“danger zone”.
Consider required changes to ensure affordability.



Increasing employer contributions for self-only coverage
Linking employer contributions to employee wages or rate of
pay safe harbor
Adoption of a new less expensive plan as a safety net
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
32
Additional Issues
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
33
Individual Mandate

This was the most controversial issue addressed by the US
Supreme Court

Beginning in 2014, virtually everyone must have at least a minimum
level of coverage or pay an individual tax penalty for failing to do so

The penalty will be phased in over three years, beginning in 2014

In 2016: Penalty is the greater of $695 per individual per year,
up to a maximum of $2,085 per family per year, or 2.5% of
household income

Important because this will drive employees who do not receive
qualifying coverage from their employer into the exchanges, thus
triggering employer mandate penalties
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
34
Retaliation/Whistleblower Protections

No employer may discharge or otherwise retaliate against (including
intimidating, threatening, restraining, coercing, blacklisting or
disciplining) any employee with respect to their compensation, terms,
conditions or privileges of employment because the employee:





Received a credit or subsidy by enrolling in coverage through an exchange
Provided, caused to be provided, or is about to provide or cause to be provided to the
employer, Federal government or state attorney general information relating to any
violation of, or any act or omission the employee reasonably believes to be a violation
of, any provision of Title I of the Act
Testified or is about to testify in a proceeding concerning such violation
Assisted or participated, or is about to assist or participate, in such a proceeding
Objected to, or refused to participate in, any activity, policy, practice or assigned task
that the employee reasonably believed to be in violation of any provision of Title I of
the Act or any rule, regulation, standard or ban under Title I of the Act
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
35
Retaliation/Whistleblower Protections (cont.)




Beginning in 2014, health insurance issuers will be prohibited against
retaliating against persons who are not their employees with respect to
those persons’ compensation, terms, conditions or other privileges of
employment, including their employer-sponsored health insurance
Employees will be protected from retaliation not only by his/her
employer, but also by the insurance issuer that provides the employersponsored health insurance coverage to the employee
Complaints of retaliation must be filed with OSHA within 180 days of the
alleged retaliatory conduct. Respondent may file a written response
within 20 days of receipt of complaint
After investigation, OSHA will issue findings and preliminary orders
which may be appealed first to an administrative hearing before an ALJ,
then to the Administrative Review Board and finally the Court of Appeals
for the circuit in which the violation allegedly occurred
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
36
Other Items Remain “Open”
Although the new regulation addresses many topics, a number
of related items remain unaddressed. Open items which are
raised, but not answered, in the new regulations include:









Exactly what type of coverage will constitute “minimum essential coverage;”
What are the final rules on determining “minimum value;”
How the rules apply to “successor” employers;
The exact definition of a “seasonal” employee; whether special rules should
be created for “short-term” employees or “high-turnover” positions;
Whether special rules should apply for temporary staffing agencies;
How exactly the play-or-pay rule applies to employers who contribute to
multi-employer plans;
Reporting requirements on the employer’s health plan coverage;
How hours of service are calculated for certain industries (e.g., airline pilots and
colleges that pay professors based on course credits taught, not on hours
worked); and
Whether the state run exchanges will be ready in 2014.
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
37
Issues of Concern




Status Changes – Obtaining employee contributions from
employees that transition from full-time to part-time positions.
Cadillac Plan Tax – Starting in 2018, employers will be subject to an
excise tax on their sponsored health insurance coverage if the value
of that coverage exceeds $10,200 for individual coverage and
$27,500 for family coverage. The tax is equal to 40% of the
aggregate value of coverage in excess of these threshold amounts.
Increased Taxes – PCORI and Transitional Reinsurance Program
fees will equal approximately $65.00 per year per covered life.
Stand-Alone HRAs – Currently, HRAs that are not linked/integrated
with a health insurance plan will violate PPACA’s prohibition on
annual/lifetime limits.
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
38
More Issues of Concern



Recording Hours of Service – Positions that are currently paid
with stipend, “straight 8’s,” or other daily/weekly equivalent.
Employers should seriously consider adopting more accurate
time-recording measures.
Shared Services – Employees that perform services for multiple
employers or employees that are employed by one entity but assigned
to another entity can pose a problem. The employer liable for
penalties may not be in a position to take action to protect itself.
Non-Discrimination Rules – Still awaiting final rules, but
employers will not be able to discriminate in favor of highly
compensated individuals with respect to eligibility or benefits.
There is some concern that municipalities and districts could fail the
final non-discrimination tests due to the level of benefits received by
highly compensated individuals.
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
39
And Still More Issues of Concern



Employing Retirees or Multiple Part-Timers – Employers that hire
former full-time employees to serve in part-time positions may have to
provide insurance, or risk penalty, due to impact of stability periods.
Budget Issues – PPACA will place more pressure on already
strained finances

Administrative costs associated with monitoring compliance

Risk of penalties and uncertainty, especially if enforcement activities suffer
expected time delay

Affordability requirements will handicap employers’ ability to allay continued
increase in insurance costs by requiring larger employee contributions
Short-term Employees – After 2014, employers will not be allowed to
take into account the fact that an employee will only be employed for a
short and definite duration when determining full-time status. An
employee who is working full-time for a 4-month period would need to be
offered coverage for the final month.
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
40
You Guessed It… More Issues of Concern



Substitute Employees:

If they are variable hour employees, are they averaging 30 hours of
service per week during measurement periods?

Long-term substitutes will not be considered “variable hour” employees,
which means they must be offered coverage within 90 days of the start of
their employment.
Employees Holding Multiple “Part-Time” Positions:

Multiple part-time positions can equal “full-time” under PPACA.

Stipend positions where hours are not currently recorded (coaches).
Affordability:

For lower wage employees, affordability will be a major concern. For
example, someone that makes $10/hour for 130 hours per month, their
monthly contribution cannot exceed $123.50.
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
41
Things You Should Already Be Considering


















Determining “large employer” status
Play-or-pay? (Asses workforce/cost/impact)
Analyzing plans for actuarial value/the 60 - 40 requirement
Analyzing W-2s for 9.5% affordability requirement
Considering single versus family costs
Determining whether current employees constitute “full-time” employees under PPACA
Analyzing the benefits and draw backs of different measurement periods
If playing – determine measurement periods, administrative periods, utilizing different periods for different
classes of employees
Review record systems for tracking ability
Determine how hours will be calculated for non-hourly employees
Evaluate PTO policies
Determine affordability safe-harbor
Determine if your current coverage satisfies MEB and MV requirements
Non-discrimination rules
Notices
Flexibility in handbooks for non-union employers
Review CBAs
Prepare plan amendments
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
42
Questions to Ask Payroll and Health Brokers



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What steps have you taken to support compliance with PPACA
Do you have a standard report that can be run monthly to assist with determining eligibility for health
insurance under PPACA for the first measurement period (coverage offered 1/1/2015)
If not, are you developing such a report? Will there be a beta test? Do you need clients to test the
report for you?
Would you develop the report if parameters and logic were provided? Would there be a cost associated
with this?
Are you offering any type of training for system usage/report running to comply with PPACA?
Are you able to analyze our workforce data and determine the optional measurement period?
How can our payroll system assist with monitoring hours during measurement periods?
Will software be able to provide warnings or alerts for employees that are trending towards 30 hours or have
exceeded 30 hours?
Will your software be able to facilitate compliance with the ACA mandate related to affordable coverage (for
example, a premium cap, rate tiers, etc.) and run related reports?
Will your software have the ability to generate canned reports and to pull hours of service specific to customized
dates (not payroll cycles)
What is the frequency of when reports can be produced while capture current data (i.e. lag time for recent data)?
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
43
Thank you for attending.
Questions?
Karlee S. Bolaños, Esq.
(585) 419-8742
© Harris Beach PLLC, 2013
44