HomeMy WebLinkAbout25A - AGMT EMPLOYEE TRACKING SVCSREQUEST FOR
COUNCIL ACTION
CITY COUNCIL MEETING DATE:
SEPTEMBER 18, 2018
TITLE:
EXECUTE AN AGREEMENT WITH BASIC
HR SERVICES FOR ADMINISTRATION
AND TRACKING SERVICES OF
EMPLOYEE LEAVES OF ABSENCE AND A
BUSINESS ASSOCIATE AGREEMENT
(STRATEGIC PLAN NO. 7,5A)
Y MANAGER
RECOMMENDED ACTION
CLERK OF COUNCIL USE ONLY:
r_\:7C 100A ;
❑ As Recommended
❑
As Amended
❑
Ordinance on 18' Reading
❑
Ordinance on 2nd Reading
❑
Implementing Resolution
❑
Set Public Hearing For
CONTINUED TO
FILE NUMBER
1. Authorize the City Manager and Clerk of the Council to execute an agreement with
BASIC HR Services for an annual reoccurring amount of $16,660 for Family Medical and
Leave Act "FMLA" Administration and other qualified leaves under Federal and State Law
and Tracking Services of these leaves and other employee leaves of absence, for three
(3) years for the period of September 1, 2018 through August 31, 2021 and with two (2)
one year renewals of $17,500 each additional year, not to exceed $85,000 over a five (5)
year period. Subject to non -substantive changes approved by the City Manager and City
Attorney; and
2. Authorize the City Manager and Clerk of Council to execute a business associate
agreement with BASIC to supplement the BASIC "FMLA" Administration agreement and
outline each party's privacy rights and obligations under the BASIC agreement.
DISCUSSION
In alignment with the City Strategic Plan, which promotes innovation and efficiency, staff
recommends adopting an agreement with BASIC; in order to provide a FMLA administration and
tracking services for employee's leave of absence. The agreement will help automate business
processes for greater efficiency, process improvement and compliance with the Department of
Labor. The services will assist the City's Human Resources Department with Federal and State
qualified leave record keeping and notification regulations by recording dates and increments of
time pertaining to qualified leaves of absence taken by eligible employees storing copies of
employee histories, created for purposes of FMLA. The services will also include; providing timely
notices, forms and determination letters to employees; provide consistent, non -biased qualified
leave administration; track employee 12 -month qualifying period and produce reports based on
Employer data; collect medical certification forms; provide a web and phone reporting system for
employees to report their request for leave time that may qualify them for federal and state
qualified leaves and to notify the Employer of those requests; provide a web based dashboard to
designated staff of Human Resources for review and intake review; and review City's Family and
Medical Leave Policy and recommend changes if necessary; to attend an audit held by the
25A-1
BASIC FMLA Tracking
September 18, 2018
Page 2
Department of Labor or a hearing by any governmental agency or bureau, regarding compliance
with qualified
leaves, including any changes or modifications to the City's Family and Medical Leave Policy and
the steps required to comply with the changes.
The City obtained information and quotes through the City's benefits broker, Kennan and
Associates. Interviews were conducted by City staff and ultimately selected, BASIC. Currently,
the process of FMLA Administration and tracking is being done manually with Excel
spreadsheets, which is not an efficient way to track qualified leaves of absence. It also requires,
hours of staff time to run reports, log time, evaluate qualifying time and track leave time. It will
also keep our City in compliance with the Department of Labor and Health Insurance Portability
and Accountability Act of 1996 (HIPPA) compliance. The parties have agreed that any claim or
controversy arising out of or relating to this agreement will be settled by binding arbitration in
Orange County, California.
STRATEGIC PLAN ALIGNMENT
Approval of this item allows the City to meet Goal #7 — Team Santa Ana, Objective #5 (Create a
culture of innovation and efficiency within the organization), Strategy A (Promote the use of new
technology to improve the delivery of services and information to staff and the community).
FISCAL IMPACT
The agreement is for three (3) years from September 1, 2018 to August 31, 2021 at a quoted
cost of $16,660 for fiscal year 2018-2019 and approximately $16,660 per subsequent fiscal
years. There are two (2) one year options for renewal. If all options are exercised, the
agreement would last five (5) years for a total agreement amount not to exceed $85,000. Funds
will be budgeted in the Human Resources Contractual Services Account (no. 08109053-62300)
in fiscal year 2018-2019, fiscal year 2019-2020 and fiscal year 2020-2021 with the following
distribution:
Fiscal Year/Account
Three Year Agreement
Human Resources
Contractual Services
08109053 62300
Estimated Total Amount
FY 2018-2019
$16,660
$16,660
FY 2019-2020
$16,660
$16,660
FY 2020-2021
$16,660
$16,660
Two Year Renewal Option
FY 2021-2022
$17,500
$17,500
FY 2022-2023
$17,500
$17,500
TOTAL Not to Exceed:
$85,000
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BASIC FMLA Tracking
September 18, 2018
Page 3
rYJ�, M
i St en V. Pham
Executive Director
Human Resources Department
Exhibits: 1. Basic Service Agreement
2. Basic Business Agreement
3. Basic Fee Schedule
APPROVE S TO FUNDS AND ACCOUNTS:
Sergio Vidal ?Yid
Assistant Executive Director
Finance and Management Services Agency
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' xa sXuvlces
BASIC FMLA EASE PLUS ADMINISTRATION AGREEMENT
BASIC assists employers In complying with the Family Medical Leave Act, as amended ("FMLA"). City of
Santa Ana ("Employer") employs fifty (50) or more employees for each working day during each of 20 or
more calendar workweeks in the current or preceding calendar year and, therefore, Is subject to FMLA.
For the purpose of this agreement, the term "employee" means the employee of the Employer.
In consideration of the mutual promises set forth In this Basic FMLA Administration Agreement
("Agreement"), effective September 1, 2018, BASIC and the Employer agree to the provisions set forth
below.
SECTION I: DUTIES OF BASIC
BASIC agrees to assist the Employer in carrying out the duties and responsibilities regarding the FMLA,
Specifically, BASIC agrees:
1. To facilitate implementation of the FMLA program including;
a) To organize initial kickoff meeting with designated staff of the Employer to establish FMLA
processes including timeline, FMLA sample letters, and Data import templates (demographic,
historical and supervisor security);
b) To confirm with the Employer unique employee ID numbers, supervisor security setup, Interactive
Voice Response (IVR) option and languages and mailing of short term disability paperwork;
c) To establish and hold weekly or bi-weekly meetings with designated staff of the Employer to
discuss timeline and outstanding items;
d) To provide web reporting for FMLA intake for the designated staff of the Employer. Standard
script is English only. Customized script, such as wording changes or adding new fields, is an
additional fee. Please see the pricing section for rate;
e) To review FMLA Policy and recommend changes if necessary with the designated staff of the
Employer. To provide FMLA policy if policy does not exist;
f) To provide Ongoing Data load based on BASIC standard template;
g) To provide a one-time supervisor load into FMLA dashboard based on BASIC standard template;
h) To assist in the historical FMLA data loaded into BASIC system. Maximum of 12 months of
employee FMLA history - based on the Employer's plan year;
I) To provide electronic copies of training materials: employee brochure, FMLA FAQ, FMLA
procedures and supervisor user guide for FMLA dashboard; to the designated staff of the
Employer
j) To provide black and white ID card for all employees of the Employer provided in Data file
k) To conduct Supervisor Training on dashboard and FMLA for the designated staff of the Employer.
Two (one-hour) on-line training sessions available. Sessions are recorded and provided to the
Employer within one week after recording. Onsite training is available. Employer is required to
pay for any travel or living expenses Incurred by the staff of BASIC to perform training; and
Ongoing Administration:
1. To provide timely notices to employees, via US Mail, upon a potential qualifying event, of FMLA rights,
obligations and consequences relating to the such employee's annual FMLA entitlement, certification
requirements, the any employee's status as a "key employee," and restoration to the same or an
E25A-5
equivalent job upon return from FMLA leave within five business days after receiving notification of the
potential qualifying event;
2. To provide medical certification forms, via US Mail, to employees that are to be completed by a licensed
health care provider within five business days after receiving notification of the potential qualifying
event;
3. To provide timely notices, via US Mail, to employees of the result of any decision regarding FMLA
qualification based on medical certification from health care provider within five business days after
receiving the certification form;
4. To assist the Employer with FMLA record keeping and notification regulations by recording dates and
increments of time FMLA leave is taken by FMLA eligible employees, storing copies of employee
notices of leave and records and documents relating to certifications, recertification or medical
histories of employees or employees' family member, created for purposes of FMLA. All records will
be held for no less than three years;
5, To provide consistent, non -biased FMLA administration;
5. To track each employee's 12 -month qualifying period and produce standard reports based on
Employer's data;
7. To track and administer federal and state -related leave plans: Family Medical Leave Act (FMLA)
including California Family Rights Act ("CFRA") leave, Pregnancy Disability Leave (°PDL"), and
qualified exigency leave.
8. To provide a web reporting system and optional IVR system for employees to report their absences
which could qualify them for FMLA and to notify the Employer of those absences;
9. To attend any audit held by the Department of Labor or a hearing by any governmental agency or
bureau, regarding the Employer's compliance with FMLA and provide at the audit or hearing records
and documentation demonstrating compliance with FMLA. Employer is required to pay for any travel
or living expenses incurred by the staff of BASIC;
10. To provide the Employer with reports confirming that proper notice has been given to those employees
who qualified for FMLA leave and to provide current and updated information to the Employer regarding
compliance with FMLA, including any changes or modifications to FMLA and the steps required to
comply with the changes;
11. To provide web based dashboard to the designated staff of the Employer for review and intake review;
and
12. To provide the Employer with black and white ID cards for any new hire within two weeks of the new
hire appearing on the data file provided by the employer.
SECTION II: DUTIES OF THE EMPLOYER
The Employer agrees:
To provide to BASIC'S home office, data files in BASIC's format that Includes the following
information, as well as any change that may occur, as It relates to employees:
a. Name, address, home telephone number and office telephone number of each employee;
b. Social Security Number, gender, and marital status of each employee;
C. Whether the employee is married to another employee and the Identity of immediate
family members of employee;
d. Number of hour's employee Is regularly scheduled to work;
e. Whether the employee Is considered a "key employee" as that term is defined by FMLA;
f. Employee's supervisor's name, office telephone and telefax numbers;
g. Employee's date of hire and date of termination of employment;
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$17,500 for each year of the optional renewal terms. The total not to exceed amount for the term of the Agreement
Including all optional renewals is $85,000. After the initial three (3) year period, BASIC may adjust fees, with a ninety
day (90) written notice, based on more than a two percent (2%n) increase in administration, for eligible members.
Any unpaid fee shall be immediately due upon termination of this Agreement.
Each party agrees to maintain, on a confidential basis, all information that the other has designated as
confidential or proprietary ("Confidential Information") and will not disclose that Confidential Information to any third
party (except to consult with their respective attorneys or accountants) unless otherwise required by law. The
parties agree to use the Confidential Information to facilitate the performance or enforcement of this Agreement and
for no other purpose.
SECTION V: INDEMNIFICATION; COOPERATION
The Employer shall be solely responsible for FMLA compliance prior to the effective date of this Agreement
and shall hold BASIC harmless for any action or failure to act in accordance with FMLA prior to such effective date.
BASIC will hold the Employer harmless for any action or failure made by BASIC. It shall not be responsible for any
action or failure caused by the Employer.
If an employee files any type of claim, lawsuit or charge against the Employer and/or BASIC, alleging a
violation(s) of law the Employer and BASIC will cooperate with the other's defense of such claim, lawsuit or charge.
The Employer and BASIC will make available to each other upon request any and all non -privileged documents that
either party has In its possession that relate to any such claim, lawsuit or charge. This provision, however, shall not
preclude the raising of cross claims or third -party claims between the Employer and BASIC, if the circumstances
justify such proceedings. The parties agree that this provision shall survive the termination of this Agreement.
SECTION VI: MISCELLANEOUS PROVISIONS
Each party represents and warrants to the other that execution of and the parties' performance of obligations
under this Agreement have been duly authorized by their respective entities and that this is a valid and legal
Agreement that is binding on each party and enforceable in accordance with its terms.
Each provision In this Agreement is separate. If any provisions of this Agreement are ever held by a court
to be unreasonable, the Parties agree that this Agreement shall be enforced to the extent it is deemed to be
reasonable and in such a manner as to make this Agreement, as modified, legal and enforceable under applicable
laws, and the balance of this Agreement shall not be affected, the balance being construed as severable and
independent.
Either party's failure to exercise or delay in exercising any power or right under this Agreement shall not
operate as a waiver, or shall any single or partial exercise of any such right or power preclude any other or further
exercise thereof or the exercise of remedies otherwise available in equity or at law.
BASIC will provide evidence of errors and omissions or professional liability insurance coverage to
Employer in the amount of $1,000,000 per occurrence and $1,000,000 of cyber liability insurance coverage prior to
the start of work pursuant to this Agreement. BASIC will maintain such insurance coverages throughout the term
of this Agreement and will provide evidence of such coverages upon reasonable request and when renewed.
Failure to maintain insurance coverages is cause for immediate termination of said Agreement.
This Agreement may be executed in one or more counterparts, each of which will be deemed to be an
original but all of which together will constitute one and the same instrument.
Without written consent of the other party, neither this Agreement nor any of Its benefits or obligations is
assignable.
For purposes of this agreement, a signed copy delivered by facsimile or electronically shall be treated by
the parties as an original of this agreement and shall be given the same force and effect.
An electronic signature captured within a software system will result in a legally binding contract under
applicable state law,
This Agreement shall be governed by and interpreted in accordance with California law.
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h. Employee's hours worked in prior 12 -month period; and
Employee's assigned department.
2. To provide to BASIC'S home office copies of the following information, and any change that may
occur, as it relates to the Employer's workforce and policies:
a. Sick and Personal time, Vacation, Paid Time Off, Health Insurance, and Attendance,
Workers Compensation, Medical Leave and Family Medical Leave Act policies;
b. Number of employees within a 75 -mile radius and number of Full -Time Equivalents
(FTE's);
3. To provide BASIC with up-to-date, pertinent information relating to the balance of time under FMLA
that each employee is eligible to take during the 12 -month qualifying period as of the effective date
of this Agreement. The parties agree that BASIC may rely on and act in accordance with any
information or other Instruction believed by BASIC in good faith to be genuine and properly given;
4. To send out required COBRA forms upon the expiration of the approved FMLA leave if the
employee falls to return to work;
5. To post the required notice of FMLA rights in conspicuous places, as required by the FMLA;
6. To Inform employees whether and how premiums payments are to be made in order to maintain
insurance benefits, the consequences If they fail to do so, and the employee's potential liability to
repay any premiums by the Employer during the employee's unpaid FMLA leave if the employee
fails to return to work after taking FMLA leave, as provided by the FMLA;
7. To inform employees whether, and to what extent, paid time off must be exhausted as part of the
FMLA leave;
a To Inform employees of any requirement for the employee to present a fitness -for -duty certificate
to be restored to employment;
9. To include an FMLA policy in the employee handbook, if the Employer has an employee handbook;
10. To facilitate the return to work process and Inform BASIC of any changes in the previously
approved FMLA leave period;
11. To maintain the FMLA dashboard administrative section, this includes adding, deleting, and
changing supervisor access as changes occur internally; and
12. To review daily, weekly, and/or monthly reports to ensure accuracy of information.
SECTION I: RELATIONSHIP OF PARTIES; TERMINATION
The parties Intend that an independent contractor -employer relationship will be created by this Agreement.
BASIC shall have exclusive control and direction over its work. BASIC is not an agent or employee of the Employer
for any purpose, and the employees are not employees of BASIC. It Is understood that BASIC may, in its sole
discretion, enter Into an agreement for similar services to be performed for other employers not related to the
Employer while this Agreement is In effect with Employer. Further, nothing set forth in this Agreement shall be
construed as creating a partnership, joint venture or agency relationship between Employer and BASIC.
The term of this Agreement shall be for three years from the effective date noted on page one of this
Agreement with two (2) one year options to renew exercisable at the sole discretion of the Employer and subject to
approval by BASIC. This Agreement can be canceled by BASIC or the Employer by providing the other party sixty
(60) days written notice of the termination.
SECTION V: BILLING FOR SERVICES RENDERED; CONFIDENTIALITY
The Employer agrees to pay BASIC for services rendered within thirty (30) days of receipt of written invoice
to Employer. The fees and payment terms are specified in the Fee Schedule that is attached to this Agreement.
Annually, the compensation authorized by this Agreement shall not exceed $50,000 for the first three years and
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1.1 Notices. Any notice to be given hereunder to any Party hereto shall be in writing and
delivered personally or by registered or certified national mail service or by any overnight courier
service, postage or fees prepaid, addressed to the respective Party at the address set forth in this
Agreement.
1.2 Arbitration. Any controversy or claim arising out of or relating to this Agreement or the breach
thereof, will be settled by arbitration in California, specifically Orange County in accordance with
the Commercial Arbitration Rules of the American Arbitration Association, using three arbitrators,
and judgment upon the award rendered by the arbitrators may be entered in any court of competent
jurisdiction. Any legal or financial services required to resolve any controversy or claim relating to
this Agreement shall be paid for by the losing party.
1.3 Amendment: Entire Agreement. The Addendum(s) to this Agreement are incorporated herein by
reference as if set out herein in their entirety. This Agreement, Including the Addendum(s) to this
Agreement constitutes the entire agreement between the Parties hereto relating to the subject
matter hereof, and supersedes all prior or contemporaneous negotiations, agreements,
representations and understandings, whether oral or written, related to the subject matter. This
Agreement may be amended only by mutual written agreement of the Parties and no amendment,
modification, change, waiver or discharge hereof shall be valid unless in writing and signed by an
authorized representative of the Party against which such amendment, modification, change,
waiver, or discharge is sought to be enforced.
1.4 Section Headings. The Section headings herein are for convenience only and are not
intended to affect the meaning or interpretation of this Agreement.
1.5 Counterparts. This Agreement may be executed in several counterparts, all of which
taken together shall constitute one single agreement between the Parties hereto.
1.6 Consents and Approval. Except where expressly provided as being in the sole discretion
of a Party, where agreement, approval, acceptance, consent, confirmation, notice or similar action
by either Party is required under this Agreement, such action shall not be unreasonably delayed or
withheld. An approval or consent given by a Party under this Agreement shall not relieve the other
Party from responsibility for complying with the requirements of this Agreement, nor shall it be
construed as a waiver of any rights under this Agreement, except as and to the extent otherwise
expressly provided in such approval or consent.
1.7 Further Assurances. Each Party covenants and agrees that, subsequent to the
execution and delivery of this Agreement and without any additional consideration, each Party shall
execute and deliver any further legal Instruments and perform any acts that are or may become
necessary to effectuate the purposes of this Agreement.
1.8 Performance of Responsibilities Except as otherwise provided in this Agreement, each
Party covenants that it shall perform its responsibilities under this Agreement in a manner that does
not infringe, or constitute an infringement or misappropriation of, any patent, copyright, trademark,
trade secret or other proprietary rights of any third party; provided, however, that the performing
Party shall not have any obligation or liability to the extent any infringement or misappropriation is
caused by (i) modifications made by the other Party or Its contractors or subcontractors, without
the knowledge or approval of the performing Party;( 11) the other Party's combination of the
performing Party's work product or Materials with Items not furnished, specified or reasonably
anticipated by the performing Party or contemplated by this Agreement; (iii) a breach of this
Agreement by the other Party; (iv) the failure of the other Party to use corrections or modifications
provided by the performing Party offering equivalent features and functionality, or (v)Third Party
Software, except to the extent that such infringement or misappropriation arises from the failure of
the performing Party to obtain the necessary licenses or required consents or to abide by the
limitations of the applicable Third Party Software licenses. Each Party further covenants that it will
not use or create materials in connection with the Services which are libelous, defamatory or
obscene.
1.9 Covenant of Good Faith. Each Party agrees that, in Its respective dealings with the other
Party under or in connection with this Agreement, it shall act in good faith.
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1.10 Severabiiity. In the event that any one or more of the provisions contained herein shall, for any
reason, be held to be invalid, illegal, or unenforceable in any respect, such Invalidity, illegality, or
unenforceability shall not affect any of the other provisions of this Agreement, and this Agreement
shall be construed as if such provision(s) had never been contained herein, provided that such
provision(s) shall be curtailed, limited, or eliminated only to the extent necessary to remove the
invalidity, Illegality, or unenforceability.
1.11 Waiver: No Oral Modification. No waiver by the Service Provider of any breach by Client of any
of the provisions of this Agreement shall be deemed a waiver of any preceding or succeeding
breach of this Agreement. No such waiver shall be effective unless it is in writing signed by the
Parties hereto, and then only to the extent expressly set forth in such writing. No modification of
this Agreement shall be effective unless it is in writing and signed by the Parties hereto, and then
only to the extent set forth in such writing._
1.12 NoAssignment. No benefit or duty under this Agreement shall be subject in any manner to
anticipation, alienation, sale, transfer, assignment, pledge, encumbrance or charge, and any
attempt to do so shall be void.
5T1 le]
Signature: _
Print Name:
Title:
Date:
Employer: See attached
Signature:
Print Name:
Title:
Date:
25A-10
ATTEST:
MARIA HUIZAR
Clerk of the Council
APPROVED AS TO FORM:
SONIA R. CARVALHO
City Attorney
By:CJUUL�
Laura A. Rossini
Senior Assistant City Attorney
RECOMMENDED FOR APPROVAL:
STEVEN V. PHAM
Executive Director of Human Resources
Revised 01114/2016
CITY OF SANTA ANA
Raul Godinez, ll.
City Manager
tl
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HSI(
MR ".• MR SERVICES
FEE SCHEDULE
Per Employee per Month (PEPM) Fee $1.32
Optional Services below (additional fees apply If selected):
• Additional languages for IVR: Add $800 for Spanish (other languages quoted)
• Customized IVR Scripts: $150/hour
• Updating & Script Revisions for IVR: $150/hour
• BASIC has the right to apply additional fees for any service outside the scope of its contracted
services.
• IT development for special processing, custom reports, and data formatting/cleansing-
$125/hour
• Intake script customization or mid -year changes - $125/ hour
• Second and Third Opinion on FMLA: $100 per event and cost of doctor visit
• EDI (,Electronic Data Interchange):
A. Monthly Fees (if applicable): Monthly fees will be assessed on a case by case basis for
each line of service (likely between $50 and $250 per month) for EDI files with the following
issues:
a. Files not provided in BASIC's format
b. Required data is missing/not provided
c. Data is inaccurate or conflicting data Is provided
d. Files transmitted in a non-standard manner
e. Other reasons as determined by BASIC
THE EMPLOYER TO INTIAL WITH ACCEPTANCE OF FEES HERE
Revised 5.25.17
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4bflsl(
BUSINESS ASSOCIATE AGREEMENT
This Business Associate Agreement, is entered into as of September 1, 2018, by and between The City of Santa
Ana (the "Plan" or "Covered Entity"); and Benefit Administration Services International Corporation (the "Business
Associate").
WITNESSETH:
WHEREAS, the Covered Entity previously has entered into an agreement (the "Agreement") with the
Business Associate, whereby the Business Associate has agreed to provide certain services to the Plan;
WHEREAS, to provide such services to the Plan, the Business Associate must have access to certain
protected health information ("Protected Health Information" or "PHI"), as defined in the Standards for Privacy of
Individually Identifiable Health Information (the "Privacy Standards") set forth by the U.S. Department of Health and
Human Services ("HHS") pursuant to the Health Insurance Portability and Accountability Act of 1998, ("HIPAA")
and amended by the Health Information Technology for Economic and Clinical Health Act ("HITECH Act"), part of
the American Recovery and Reinvestment Act of 2009 ("ARRA"), the Genetic Information Nondiscrimination Act of
2008 ("GINA"), and the final regulations to such Acts promulgated in January 2013;
WHEREAS, to comply with the requirements of the Privacy Standards, the Covered Entity must enter into
this Business Associate Agreement with the Business Associate.
NOW, THEREFORE, in consideration of the mutual covenants and agreements hereinafter contained, and
other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, and
Intending to be legally bound hereby, the parties hereto agree as follows:
I. Definitions
The following terms used in this Agreement shall have the same meaning as those terms in the Privacy Rules:
Breach, Data Aggregation, Designated Record Set, Disclosure, Health Care Operations, Individual, Minimum
Necessary, Notice of Privacy Practices, Secretary, Subcontractor, and Use. If other terms are used, but not
otherwise defined under this Business Associate Agreement, such terms shall then have the same meaning as
those terms in the Privacy Rule.
(a) Business Associate. "Business Associate" shall generally have the same meaning as the term "business
associate" at 45 CFR 160.103.
(b) Covered Electron& Transactions. "Covered Electronic Transactions" shall have the meaning given the term
"transaction"" in 45 CFR §160.103.
(c) Covered€ntity. "Covered Entity" shall generally have the same meaning as the term 'covered entity" at 45
CFR 160.103.
(d) Electronic Protected Health information. "Electronic Protected Health Information" shall have the same
meaning as the term "electronic protected health information" in 45 CFR §160.103.
(e) Genetic Information. "Genetic Information" shall have the same meaning as the term "genetic Information" in
45 CFR §160.103.
(t7 HIPAA Rules. "HIPAA Rules" shall mean the Privacy, Security, Breach Notification, and Enforcement Rules at
45 CFR Part 160 and Part 164.
(g) Indivl ual. "Individual" shall have the same meaning as the term "individual" in 45 CFR §160.103 and shall
include a person who qualifies as a personal representative in accordance with 45 CFR §164.502(g).
(h) Privacy Rule. "Privacy Rule" shall mean the Standards for Privacy of Individually Identifiable Health
Information at 45 CFR Part 160 and Part 164, subparts A and E.
Exhibit 2
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(I) Protected Health Information (PHI). "Protected Health Information (PHI)" shall have the same meaning as the
term "protected health information" in 45 CFR §160.103, limited to the information created or received by
Business Associate from or on behalf of a Covered Entity pursuant to this Agreement.
(%) Repaired By Law. "Required By Law" shall have the same meaning as the term "required by law" in 45 CFR
§164.103.
(k) Secretary. "Secretary" shall mean the Secretary of the Department of Health and Human Services or his
designee.
(I) Standards for Electronic Transactions Rule. "Standards for Electronic Transactions Rule" means the final
regulations issued by HHS concerning standard transactions and code sets under the Administration
Simplification provisions of HIPAA, 45 CFR Part 160 and Part 162.
(m) Security lncidenf. "Security Incident" shall have the same meaning as the term "security Incident" in 45 CFR
§164,304.
(n) Security Rule. "Security Rule" shall mean the Security Standards and Implementation Specifications at 45
CFR Part 160 and Part 164, subpart C.
(®) Subcontractor. "Subcontractor" shall have the same meaning as the term "subcontractor" in 45 CFR §160.103.
(p) Transaction. "Transaction" shall have the meaning given the term "transaction" in 45 CFR §160.103
(q) Unsecured Protected Health information. "Unsecured Protected Health Information" shall have the meaning
given the term "unsecured protected health information" in 45 CFR §164.402.
II. Safeguarding Privacy and Security of Protected Health Information
(a) Permitted Uses and Disclosures. The Business Associate Is permitted to use and disclose Protected Health
Information that it creates or receives on the Covered Entity's behalf or receives from the Covered Entity (or
another business associate of the Covered Entity) and to request Protected Health Information on the Covered
Entity's behalf (collectively, "Covered Entity's Protected Health information") only:
(i) Functions and Activities on the Covered Entity's Behalf. To perform those services referred to In the
services agreement.
(ii) Business Associate's Operations. For the Business Associate's proper management and administration
or to carry out the Business Associate's legal responsibilities, provided that, with respect to disclosure of the
Covered Entity's Protected Health Information, either:
(A) The disclosure is Required by Law; or
(B) The Business Associate obtains reasonable assurance from any person or entity to which the Business
Associate will disclose the Covered Entity's Protected Health Information that the person or entity will:
(1) Hold the Covered Entity's Protected Health Information in confidence and use or further disclose
the Covered Entity's Protected Health information only for the purpose for which the Business
Associate disclosed the Covered Entity's Protected Health Information to the person or entity or as
Required by Law; and
(2) Promptly notify the Business Associate (who will in turn notify the Covered Entity In accordance
with the breach notification provisions) of any instance of which the person or entity becomes aware in
which the confidentiality of the Covered Entity's Protected Health Information was breached.
(C) To de -identify the Information in accordance with 45 CFR 164.514(a) — (c) as necessary to perform
those services required under the Agreement.
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(iii) Minimum Necessary. The Business Associate will, in Its performance of the functions, activities, services,
and operations specified above, make reasonable efforts to use, to disclose, and to request only the minimum
amount of the Covered Entity's Protected Health Information reasonably necessary to accomplish the intended
purpose of the use, disclosure or request, except that the Business Associate will not be obligated to comply
with this minimum -necessary limitation if neither the Business Associate nor the Covered Entity is required to
limit Its use, disclosure or request to the minimum necessary. The Business Associate and the Covered Entity
acknowledge that the phrase "minimum necessary' shall be interpreted in accordance with the HITECH Act.
(b) Prohibition on Unauthorized Use or Disclosure. The Business Associate will neither use nor disclose the
Covered Entity's Protected Health Information, except as permitted or required by this Agreement or in writing by
the Covered Entity or as Required by Law. This Agreement does not authorize the Business Associate to use or
disclose the Covered Entity's Protected Health Information in a manner that will violate Subpart E of 45 CFR Part
164 if done by the Covered Entity.
(c) information Safeguards.
(i) Privacy of the Covered Entity's Protected Health information. The Business Associate will develop,
Implement, maintain, and use appropriate administrative, technical, and physical safeguards to protect the
privacy of the Covered Entity's Protected Health Information. The safeguards must reasonably protect the
Covered Entity's Protected Health Information from any Intentional or unintentional use or disclosure in violation
of the Privacy Rule and limit incidental uses or disclosures made to a use or disclosure otherwise permitted by
this Agreement.
(ti) Security of the Covered Entity's Electronic Protected Health Information. The Business Associate will
develop, implement, maintain, and use administrative, technical, and physical safeguards that reasonably and
appropriately protect the confidentiality, Integrity, and availability of Electronic Protected Health Information that
the Business Associate creates, receives, maintains, or transmits on the Covered Entity's behalf as required by
the Security Rule. The Business Associate will comply with Subpart C of 45 CFR Part 164 with respect to
Electronic Protected Health Information, to prevent use or disclosure of protected health information other than
as provided for by the Agreement,
(iii) No Transfer of PHI Outside United States. Business Associate will not transfer Protected Health
Information outside the United States without the prior written consent of the Covered Entity. In this context, a
"transfer" outside the United States occurs if Business Associate's workforce members, agents, or
subcontractors physically located outside the United States are able to access, use, or disclose Protected
Health Information.
(iv) Policies and Procedures. The Business Associate shall maintain written policies and procedures, conduct
a risk analysis, and train and discipline its workforce.
(d) Subcontractors and Agents. In accordance with 45 CFR 164.502(e)(1)(11) and 164.308(b)(2), if applicable, the
Business Associate will ensure that any of Its Subcontractors and agents that create, receive, maintain, or transmit
Protected Health Information on behalf of the Business Associate agree to the same restrictions, conditions, and
requirements that apply to the Business Associate with respect to such Information.
(e) Prohibition on Sale of Records. As of the effective date specified by HHS in final regulations to be Issued on
this topic, the Business Associate shall not directly or Indirectly receive remuneration in exchange for any Protected
Health Information of an individual unless the Covered Entity or Business Associate obtained from the individual, in
accordance with 45 CFR §164.508, a valid authorization that includes a specification of whether the Protected
Health Information can be further exchanged for remuneration by the entity receiving Protected Health Information
of that individual, except as otherwise allowed under the HITECH Act.
(f) Prohibition on Use or Disclosure of Genetic Information. Business Associate shall not use or disclose
Genetic Information for underwriting purposes in violation of the HIPAA rules.
(g) Penalties For Noncompliance. The Business Associate acknowledges that it is subject to civil and criminal
enforcement for failure to comply with the privacy rule and security rule under the HIPAA Rules, as
amended by the HITECH Act.
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Compliance with Electronic Transactions Rule
If the Business Associate conducts in whole or part Electronic Transactions on behalf of the Covered Entity for
which HHS has established standards, the Business Associate will comply, and will require any Subcontractor or
agent it involves with the conduct of such Transactions to comply, with each applicable requirement of the
Electronic Transactions Rule, The Business Associate shall also comply with the National Provider Identifier
requirements, if and to the extent applicable.
IV. Obligations of the Covered Entity
The Covered Entity shall notify the Business Associate of:
(a) Any limitation(s) in its notice of privacy practices of the Covered Entity in accordance with 45 CFR §164.620, to
the extent that such limitation may affect the Business Associate's use or disclosure of Protected Health
Information;
(b) Any changes In, or revocation of, permission by the Individual to use or disclose Protected Health Information,
to the extent that such changes may affect the Business Associate's use or disclosure of Protected Health
Information; and
(c) Any restriction to the use or disclosure of Protected Health Information that the Covered Entity has agreed to in
accordance with 45 CFR §164.522, to the extent that such restriction may affect the Business Associate's use or
disclosure of Protected Health Information.
V. Permissible Requests by the Covered Entity
The Covered Entity shall not request the Business Associate to use or disclose Protected Health Information in any
manner that would not be permissible under the Privacy Rule if done by the Covered Entity.
VI, Individual Rights
(a) Access. The Business Associate will, within twenty-five (25) calendar days following the Covered Entity's
request, make available to the Covered Entity or, at the Covered Entity's direction, to an individual (or the
individual's personal representative) for inspection and obtaining copies of the Covered Entity's Protected Health
Information about the individual that is in the Business Associate's custody or control, so that the Covered Entity
may meet its access obligations under 45 CFR §164.624. Effective as of the date specified by HHS, if the Protected
Health Information is held electronically in a designated record set In the Business Associate's custody or control,
The Business Associate will provide an electronic copy in the form and format specified by the Covered Entity if it is
readily producible in such format; if it is not readily producible in such format, the Business Associate will work with
the Covered Entity to determine an alternative form and format as specified by the Covered Entity to meet its
electronic access obligations under 45 CFR 164.624.
(b) Amendment. The Business Associate will, upon receipt of written notice from the Covered Entity, promptly
amend or permit the Covered Entity access to amend any portion of the Covered Entity's Protected Health
Information in a designated record set as directed or agreed to by the Covered Entity, so that the Covered Entity
may meet its amendment obligations under 45 CFR §164,526.
(c) Disclosure Accounting. The Business Associate will maintain and make available the information required to
provide an accounting of disclosures to the Covered Entity as necessary to satisfy the Covered Entity's obligations
under 45 CFR §164.528.
(1) Disclosures Subject to Accounting. The Business Associate will record the Information specified below
("Disclosure Information') for each disclosure of the Covered Entity's Protected Health Information, not
excepted from disclosure accounting as specified below, that the Business Associate makes to the Covered
Entity or to a third party.
(II) Disclosures Not Subject to Accounting. The Business Associate will not be obligated to record
Disclosure Information or otherwise account for disclosures of the Covered Entity's Protected Health
Information If the Covered Entity need not account for such disclosures under the HIPAA Rules.
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(111) Disclosure Information. With respect to any disclosure by the Business Associate of the Covered Entity's
Protected Health Information that is not excepted from disclosure accounting under the HIPAA Rules, the
Business Associate will record the following Disclosure Information as applicable to the type of accountable
disclosure made:
(A) Disclosure Information Generally. Except for repetitive disclosures of the Covered Entity's Protected
Health Information as specified below, the Disclosure Information that the Business Associate must record
for each accountable disclosure Is (1) the disclosure date, (2) the name and (if known) address of the entity
to which the Business Associate made the disclosure, (3) a brief description of the Covered Entity's
Protected Health Information disclosed, and (4) a brief statement of the purpose of the disclosure.
(B) Disclosure Information for Repetitive Disclosures. For repetitive disclosures of the Covered Entity's
Protected Health Information that the Business Associate makes for a single purpose to the same person
or entity (Including the Covered Entity), the Disclosure Information that the Business Associate must record
Is either the Disclosure Information specified above for each accountable disclosure, or (1) the Disclosure
Information specified above for the first of the repetitive accountable disclosures; (2) the frequency,
periodicity, or number of the repetitive accountable disclosures; and (3) the date of the last of the repetitive
accountable disclosures.
(iv) Availability of Disclosure Information. The Business Associate will maintain the Disclosure Information
for at least 6 years following the date of the accountable disclosure to which the Disclosure Information relates
(3 years for disclosures related to an Electronic Health Record, starting with the date specified by HHS). The
Business Associate will make the Disclosure Information available to the Covered Entity within twenty-five (25)
calendar days following the Covered Entity's request for such Disclosure Information to comply with an
individual's request for disclosure accounting. Effective as of the date specified by HHS, with respect to
disclosures related to an Electronic Health Record, the Business Associate shall provide the accounting directly
to an individual making such a disclosure request, if a direct response is requested by the individual. To the
extent the Business Associate is to carry out one or more of Covered Entity's obligation(s) under Subpart E of
45 CFR Part 164, comply with the requirements of Subpart E that apply to the covered entity in the
performance of such obligation(s); and make its Internal practices, books, and records available to the
Secretary for purposes of determining compliance with the HIPAA Rules.
(d) Restriction Agreements and Confidential Communications. The Covered Entity shall notify the Business
Associate of any limitations in the notice of privacy practices of Covered Entity under 45 CFR §164.520, to the
extent that such limitation may affect the Business Associate's use or disclosure of Protected Health Information.
The Business Associate will comply with any agreement that the Covered Entity makes that either (1) restricts use
or disclosure of the Covered Entity's Protected Health Information pursuant to 45 CFR §164.522(a), or (ii) requires
confidential communication about the Covered Entity's Protected Health Information pursuant to 45 CFR
§164.522(b), provided that the Covered Entity notifies the Business Associate in writing of the restriction or
confidential communication obligations that the Business Associate must follow. The Covered Entity will promptly
notify the Business Associate in writing of the termination of any such restriction agreement or confidential
communication requirement and, with respect to termination of any such restriction agreement, instruct the
Business Associate whether any of the Covered Entity's Protected Health Information will remain subject to the
terms of the restriction agreement. Effective February 17, 2010 (or such other date specified as the effective date
by HHS), the Business Associate will comply with any restriction request If: (1) except as otherwise required by law,
the disclosure is to a health plan for purposes of carrying out payment or health care operations (and is not for
purposes of carrying out treatment); and (ii) the Protected Health Information pertains solely to a health care item or
service for which the health care provider involved has been paid out-of-pocket in full.
VII. Breaches and Security Incidents
(a) Reporting.
(1) Impermissible Use or Disclosure. The Business Associate will report to Covered Entity any use or
disclosure of Protected Health Information not permitted by this Agreement not more than twenty-five
(25) calendar days after Business Associate becomes aware of such non -permitted use or disclosure.
(11) Privacy or Security Breach. The Business Associate will report to the Covered Entity any use or
disclosure of the Covered Entity's Protected Health Information not permitted by this Agreement of which it
becomes aware, including breaches of Unsecured Protected Health Information as required by 45 CFR
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164.410, and any Security Incident of which it becomes aware. The Business Associate will make the report to
the Covered Entity's Privacy Official not more than twenty-five (25) calendar days after the Business Associate
becomes aware of such non -permitted use or disclosure. If a delay is requested by a law-enforcement official in
accordance with 45 CFR §164.412, the Business Associate may delay notifying the Covered Entity for the
applicable time period. The Business Associate's report will at least:
(A) Identify the nature of the Breach or other non -permitted use or disclosure, which will include a brief
description of what happened, including the date of any Breach and the date of the discovery of the
Breach;
(B) Identify the Covered Entity's Protected Health Information that was subject to the non -permitted use or
disclosure or Breach (such as whether full name, social security number, date of birth, home address,
account number or other information were involved) on an Individual basis;
(C) Identify who made the non -permitted use or disclosure and who received the non -permitted use or
disclosure;
(D) Identify what corrective or Investigational action the Business Associate took or will take to prevent
further non -permitted uses or disclosures, to mitigate harmful effects and to protect against any further
Breaches;
(E) Identify what steps the Individuals who were subject to a Breach should take to protect themselves; and
(F) Provide such other Information, including a written report and risk assessment under 45 CFR §164.402,
as the Covered Entity may reasonably request,
(iii) Security Incidents. The Business Associate will report to The Covered Entity any Security Incident of
which the Business Associate becomes aware. The Business Associate will make this report once per month,
except If any such Security Incident resulted in a disclosure not permitted by this Agreement or Breach of
Unsecured Protected Health Information, Business Associate will make the report in accordance with the
provisions set forth above,
(b) Mitigation. The Business Associate shall mitigate, to the extent practicable, any harmful effect known to the
Business Associate resulting from a use or disclosure in violation of this Agreement.
VIII. Term and Termination
(a) Tenn. The term of this Agreement shall be effective as of the date specified below, and shall terminate when all
Protected Health Information provided by the Covered Entity to the Business Associate, or created or received by
the Business Associate on behalf of the Covered Entity, is destroyed or returned to the Covered Entity, or, if It Is
infeasible to return or destroy Protected Health Information, protections are extended to such information, in
accordance with the termination provisions in this section.
(b) Right to Terminate for Cause. The Covered Entity may terminate this Agreement if it determines, in its sole
discretion that the Business Associate has breached a material term of this Agreement, and upon written notice to
the Business Associate of the breach, the Business Associate fails to cure the breach within thirty (30) calendar
days after receipt of the notice. Any such termination will be effective Immediately or at such other date specified in
the Covered Entity's notice of termination.
(c) Treatment of Protected Health Information on Termination.
(i) Return or Destruction of Covered Entity's Protected Health Information as Feasible. Upon
termination or other conclusion of this Agreement, the Business Associate will, if feasible, return to the Covered
Entity or destroy all of the Covered Entity's Protected Health Information in whatever form or medium, Including
all copies thereof and all data, compilations, and other works derived there from that allow Identification of any
Individual who Is a subject of the Covered Entity's Protected Health Information. This provision shall apply to
Protected Health Information that is In the possession of Subcontractors or agents of the Business Associate.
Further, the Business Associate shall require any such Subcontractor or agent to certify to the Business
Associate that It returned to the Business Associate (so that the Business Associate may return it to the
Covered Entity) or destroyed all such information which could be returned or destroyed. The Business
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Associate will complete these obligations as promptly as possible, but not later than thirty (30) calendar days
following the effective date of the termination or other conclusion of this Agreement.
(Ii) Procedure When Return or Destruction Is Not Feasible. The Business Associate will identify any of the
Covered Entity's Protected Health Information, Including any that the Business Associate has disclosed to
Subcontractors or agents as permitted under this Agreement, that cannot feasibly be returned to the Covered
Entity or destroyed and explain why return or destruction is infeasible. The Business Associate will limit its
further use or disclosure of such information to those purposes that make return or destruction of such
Information infeasible. The Business Associate will complete these obligations as promptly as possible, but not
later than thirty (30) calendar days following the effective date of the termination or other conclusion of this
Agreement.
(Iii) Continuing Privacy and Security Obligation. The Business Associate's obligation to protect the privacy
and safeguard the security of the Covered Entity's Protected Health Information as specified in this Agreement
will be continuous and survive termination or other conclusion of this Agreement.
IX. Miscellaneous Provisions
(a) Definitions. All terms that are used but not otherwise defined in this Agreement shall have the meaning
specified under HIPAA, including its statute, regulations and other official government guidance.
(b) Inspection of Internal Practices, Books, and Records. The Business Associate will make its internal
practices, books, and records relating to its use and disclosure of the Covered Entity's Protected Health Information
available to the Covered Entity and to HHS to determine compliance with the HIPAA Rules.
(c) Amendment to Agreement. This Agreement may be amended only by a written instrument signed by the
parties. In case of a change in applicable law, the parties agree to negotiate in good faith to adopt such
amendments as are necessary to comply with the change in law.
(d) No Third -Party Beneficiaries. Nothing in this Agreement shall be construed as creating any rights or benefits
to any third parties.
(e) Regulatory References. A reference in this Business Associate Agreement to a section in the Privacy Rule
means the section as in effect or as amended.
(f) Survival. The respective rights and obligations of the Business Associate Agreement shall survive the
termination of this Agreement.
(g) Interpretation. Any ambiguity in this Agreement shall be resolved to permit the Covered Entity to comply with
the HIPAA Rules.
(h) Notices. All notices hereunder shall be in writing and delivered by hand, by certified mail, return receipt
requested or by overnight delivery. Notices shall be directed to the parties at their respective addresses set forth in
the first paragraph of this Business Associate Agreement or below their signature, as appropriate, or at such other
addresses as the parties may from time to time designate In writing.
(1) Entire Agreement, Modification, This Business Associate Agreement represents the entire agreement
between the Business Associate and the Covered Entity relating to the subject matter hereof. No provision of this
Business Associate Agreement may be modified, except in writing, signed by the parties.
Q) Indemnification. Each Party agrees to indemnify, defend and hold harmless each other Party, Its affiliates and
each of their respective directors, officers, employees, agents or assigns from and against any and all actions,
causes of actions, claims, sults and demands whatever, and from all damages, liabilities, costs, charges, debts and
expenses whatever (including reasonable attorneys' fees and expenses related to any litigation or other defense of
any claims), which may be asserted or for which they may now or hereafter become subject arising in connection
with (1) any misrepresentation, breach of warranty or non -fulfillment of any undertaking on the part of the Party to
the Agreement and (ii) any claims, demands, awards, judgments, actions, and proceedings made by any person or
organization arising out of any way connected with the Party's performance.
(k) Assistance In Litigation or Administrative Proceedings. The Business Associate shall make Itself, and any
subcontractors, employees or agents assisting the Business Associate in the performance of Its obligations under
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this Agreement, available to the Covered Entity, at no cost to the Covered Entity, to testify as witnesses, or
otherwise, in the event of litigation or administrative proceedings being commenced against the Covered Entity, Its
directors, officers; or employees based upon a claimed violation of HIPAA, the HIPAA regulations, or other laws
relating to security and privacy, except where the Business Associate or its subcontractors, employees, or agents
are named as an adverse party.
(1) Binding Effect. This Business Associate Agreement shall be binding upon the parties hereto and their
successors and assigns. For purposes of this agreement, a signed copy delivered by facsimile or electronically
shall be treated by the parties as an original of this agreement and shall be given the same force and effect.
(m) Governing Law, Jurisdiction, and Venue. This Agreement shall be governed by the law of California except
to the extent preempted by federal law.
(n) Severability. The invalidity or unenforceability of any provisions of this Agreement shall not affect the validity or
enforceability of any other provision of this Agreement, which shall remain in full force and effect.
(o) Construction and Interpretation. The section headings contained in this Agreement are for reference
purposes only and shall not in any way affect the meaning or interpretation of this Agreement. This Agreement has
been negotiated by the parties at arm's-length and each of them has had an opportunity to modify the language of
the Agreement. Accordingly, the Agreement shall be treated as having been drafted equally by the parties and the
language shall be construed as a whole and according to Its fair meaning. Any presumption or principle that the
language Is to be construed against any party shall not apply. This Agreement may be executed in counterparts,
each of which shall be deemed to be an original, but all of which, taken together, shall constitute one and the same
agreement.
(p) Electronic Signature. An electronic signature captured within a software system will result in a legally binding
contract under applicable state law.
In Witness Whereof, the parties hereto have caused this Agreement to be executed as of the date first
above written.
BUSINESS ASSOCIATE: COVERED ENTITY:
BASIC Employer: See Attached.
Signature, Signature: _
Print Name: Print Name:
Title: _ Title:
Date: Date:
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ATTEST: CITY OF SANTA ANA
MARIA HUIZAR Raul Godinez, II.
Clerk of the Council City Manager
APPROVED AS TO FORM:
SONIA R. CARVALHO
City Attorney
By:C c,,— A,y-� � —
Laura A. Rossini
Senior Assistant City Attorney
RECOMMENDED FOR APPROVAL:
STEVEN V. PHAM
Executive Director of Human Resources
(Revised 6.18.14)
9
25A-21
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�. Gil
NQ SFAVICE5
FEE SCHEDULE
Per Employee per Month (PEPM) Fee $1.32
Optional Services below (additional fees apply if selected):
• Additional languages for IVR: Add $800 for Spanish (other languages quoted)
• Customized IVR Scripts: $150/hour
Updating & Script Revisions for IVR: $150/hour
• BASIC has the right to apply additional fees for any service outside the scope of its contracted
services,
• IT development for special processing, custom reports, and data formatting/cleansing-
$125/hour
• Intake script customization or mid -year changes - $125/ hour
• Second and Third Opinion on FMLA: $1100 per -event and cost of doctor visit
• EDI (Electronic Data Interchange):
A. Monthly Fees (if applicable): Monthly fees will be assessed on a case by case basis for
each line of service (likely between $50 and $250 per month) for EDI files with the following
issues:
a. Files not provided in BASIC's format
b. Required data is missing/not provided
c. Data is Inaccurate or conflicting data is provided
d. Files transmitted in a non-standard manner
e. Other reasons as determined by BASIC
THE EMPLOYER TO INTIAL WITH ACCEPTANCE OF FEES HERE
Revised 5,25.17
=711171X]
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