Employee Benefits-Size Matters

Employee Benefits-Size Matters


Regardless of the size of your practice or business, the ever-increasing cost of your Group Health Plan(s) is typically the second or third largest item of your expenses, next to salaries or, in certain circumstances, malpractice insurance. But this is just the “transparent” cost of being an owner.

Knowing (or NOT knowing) more about the “invisible” and multitudinous regulations that you, the employer, are responsible for can be dizzying and expensive if you are not informed. Adding or Terminating Employees from your Plan(s) is critical. If you fail to enroll an eligible employee who has satisfied the Plan(s) waiting period, the carrier has no obligation to accept that individual until your Plan(s) renewal, barring a “Qualifying Life Event”. If an individual is terminating for any reason, they “MUST” be removed from your plan and offered the opportunity to continue and pay for their own coverage, unless or until they return to work at some future date. Typically, the terminated employee would be permitted to continue their coverage for 18 months, but there are some extenuating circumstances that could allow for an extension. You are also responsible for notifying and removing your terminated employee upon the expiration of the allowable extended coverage and we recommend the implementation of Certified Mail to avoid being sued from a disgruntled employee who may make a claim of having never been notified.

Here’s just a few places where size matters:

  • Small Groups of 2-19 are mandated by State Continuation, Large Groups by Federal COBRA
  • Small Groups of 2-99 for Group Health, Large Groups are 100+ by Federal Law but the law allows states to modify that number and NJ and PA have chosen 2-49 for Small Group and 50+ for Large Group, while NY has elected to use 2-99 as Small Group and 100+ as Large Group.
  • Under the ACA, many of the penalties applicable to Large Groups are avoided if you are utilizing Level Funded* or Self-Funded Plans*, which are now available to both Large and Small Groups.

Large Groups will require:

  • ACA Compliance & Reporting                               · Forms 1094-1095 B and C
  • Form 6055                                                               · ERISA 5500 Compliance
  • ERISA SPD & Wrap Reporting                              · COBRA Continuation and Notification

The following are just a few of the many services or plans that can save you and/or your employees money and enhance your renewal experience:

  • Health Savings Accounts (HSAs)                           · Health Reimbursement Arrangements (HRAs)
  • Flexible Spending Accounts (FSAs)                       · Dependent Care FSAs
  • Self-Funded/TPA Plans*                                         · Group Life
  • Short & Long Term Disability                                · Retirement Plans
  • Transit & Parking Plans                                          · COBRA
  • Employee Wellness Programs                                · Voluntary Benefits
  • Employee Handbook                                              · Online Portals, Compliance and Reporting Tools


We would invite you to visit our Employee Benefits web site at www.kirwanbenefits.com and would be privileged to receive your questions or calls.

Healthcare 2017 – Where Are We Now

As we hurtle further into the unknown arena of Healthcare, and an election with the nominees having diametric objectives, we are reminded that for all enterprises to function, hospitals and physicians alike, there must be a profit incentive, which always requires competition.

The American Enterprise Institute has noted that Aetna has lost $430 million since January 2014 on insurance plans sold through Obamacare and is withdrawing from 11 of its 15 states. United Healthcare has lost $1.3 billion on the exchanges and will cut its participation to three states from 34. In 2014, McKinsey said, insurers lost money to the tune of $2.7 billion, posting a -5 percent post-tax margin. In 2015, margins plummeted, to between -9 percent and -12 percent.

This means less coverage and will inevitably result in less competition and soon could result in a third of the exchanges having only one provider and without competition, we can only anticipate higher prices. Currently the national requested increase is estimated to approach in excess of 20%.

According to the Kaiser Foundation, all employees have deductibles that are about 50 percent higher than they were five years ago. Four out of five covered employees pay a deductible, which averages about $1,500 each. Employees who get insurance through a smaller company have deductibles that now average $2,100.

More companies are opting for less choice for their employees. This year, slightly fewer than half of workers are enrolled in so-called preferred provider organization plans, or P.P.O.s, compared with 58 percent in 2014 and then there are the internal offerings from the carriers.

We recently concluded an annual renewal review for one of our NJ mid-market medical group clients (about 100 employees), who received a 14% increase from their long time provider, Aetna. Alas, longevity provides no immunity. After seeking any number of quality alternative carrier quotes, the best price offering was Horizon “BUT”. One of their new offerings has a two-Tiered Provider arrangement, resulting in what initially appears to provide a substantial savings by guiding the insured to the Tier One physician, the insured has “no deductible”. However, if you elect or need the Tier Two provider, you will be faced with a deductible, which changes the cost dynamic, depending upon the largess of the employer, who may be willing to provide an HRA-Health Reimbursement Arrangement as an incentive.

Noting that the client is a medical practice, who also happens to be a Tier Two Group, they were able to determine that while the practice reimbursement appeared to be identical for Tier One and Two Groups, you can understand their concern about the potential loss of patients not able or willing to pay for a deductible, their concern turned toward their desire to support such a program.

In retrospect, and without opining upon Horizon’s offering, they are simply confirming the aforementioned cited statistics of surviving in the market.

If you think we can assist your group and would like to know more about us, I would invite you to visit our new web site of services at www.KirwanBenefits.com or our dedicated HSA web site at www.KirwanHSA.com.

Written for the Union County Medical Society

Large Group, Small Group, IRS Codes

ACA, ALE’s, FTE, 6055, 6056, 1094C, 1095C
Are you and your Accountant Confused Yet?

As we prepare for the full effects of the 2016 ACA regulations to go into play, we will once again be faced with yet additional rules, regulations and potential penalties.

You will recall that in an effort to mobilize the country into assuring that “all Americans” would meet the requirement of having coverage, penalties were to be imposed on:

*2015-Individuals who did not comply pay the greater of 2% of your household income or $325 per person ($162.50 per child under age 18). Certain exemptions may be available.
*2016-Individuals who did not comply pay the greater of 2.5% of your household income or $695 per person ($347.50 per child under age 18). Certain exemptions may be available.

Small Employers
*2015-For Groups with fewer than 50 fulltime employees, who offer coverage, must meet a number of minimum affordability requirements.

Large Group
*2015-Employers with 50 ALE’s-Applicable Large Employer (averaged at least 50 fulltime employees, including FTE fulltime equivalent employees) will be subject to 4980H penalties. Transitional relief will be available in determining ALE’s status, which will include 28 different ways, but we encourage our readers to begin tracking the hours of “every” individual who appears on your payroll as soon as possible, regardless of hours.

*2016-Small Group definition will be expanded to include Groups with fewer than 100 employees and, in addition to the 2015 requirements, those employers with 50 ALE’s-Applicable Large Employer (averaged at least 50 fulltime employees, including FTE fulltime equivalent employees) will be subject to 4980H penalties.

Important Information Reporting Filing Forms for 2016 under Section 6056 (6055 for self-insured/MEWA’s and consortiums) FOR 2015 are Forms 1094-C and 1095-C.

The Kirwan Companies, Ltd, and ACCA-Affordable Care Consulting Associates, Inc., are Employee Benefits Specialists uniquely positioned in working with physician groups for well over 30 years, and can assist you in maneuvering through the maze of ACA requirements, including making comparisons between your current Group Plan versus the use of either a MEWA (Multiple Employee Welfare Arrangement) or, if you are a group of at least 30 covered employees, we can prepare a Cost/Benefit Analysis by creating a specific Consortium plan specifically designed for your group. Members may call us directly for your free consultation and analysis.

The Supreme’s Hear King v. Burwell

How will the Supreme Court rule on the Obamacare “Federal Tax Subsidies”?

As you may be aware, according to the strict language of the law pertaining to subsidies, only Health Insurance purchased through an “Exchange established by the State under section 1311” of the ACA, Section 36B IRC, are eligible for subsidies.

Currently there are 34 States that have declined to establish their own exchanges and, by default, the Federal government established a Federal Exchange, which according to the language in the law, is not eligible to provide Subsidies.

This IRS Rule, allowing for Federal expansion, triggers other ACA Mandates and Penalties.

➢ For individuals, eligibility for subsidies triggers the “Individual Mandate Tax Penalty”*-, for which they would have otherwise been exempt, thereby increasing the number of people in those states subject to the tax penalty, in addition to now paying for coverage they may not otherwise be able to afford, not withstanding the High Deductibles imposed in most plans, that are likewise unaffordable.
➢ For employers, subsidies trigger the “assessable payments” of the Employer Mandate, specifically against Large Employers (currently), i.e. 100+ employees. In this case, if even one (1) employee applies for and receives a subsidy by virtue of going to the Exchange for coverage, the employer penalty is assessed. Like the case for Individuals, lacking a subsidy, there would be no employer assessment.

What results might evolve from prohibiting the Federal Exchanges from providing subsidies?

Clearly, those of modest to low/no income would incur a significant financial hardship and, perhaps even a loss of coverage, resulting in a substantial reduction of plans/insured’s and revenue to the carriers, who would then need to re-evaluate the premiums charged to their respective “book of business”.

Given the already significant reduction in revenue to both the hospitals and private practitioner(s), who are seeking sanctuary at the hospital’s, could we expect even further reimbursement reductions by the carriers, resulting in even further cutbacks in our already overburdened and under served healthcare system?

Alternatively, being an entrepreneurial country, would that well known American spirit called “competition” force carriers to be more efficient by allowing for cross state purchasing of insurance, i.e. open borders for consumer/employer purchasing of coverage. We are acutely aware of the already excessive monies expended on building and, even more frightening, maintaining our insecure Exchange.

If we were able to provide for a more realistic reimbursement to our “entrepreneurial” physicians, ACO style, would we then be able to not only reduce the number of our physicians leaving private practice, but more importantly, significantly incentivize and encourage our new physicians to entire and expand their own private practice services and negate the immediate and prospective shortages we will continue to experience. After all, what is the saturation point of absorbing physicians into the hospital mode?

Transformation of our HealthCare System under ACA

According to FACTCHECK, per capita health care costs have been rising at just under 3 percent a year over the last four years, but that’s less than half the average annual growth in the preceding eight years.

The Centers for Medicare & Medicaid Services calls the effect of the ACA on the slowdown “minimal.” and cites the following reasons:

  • The economic slowdown and subsequent sluggish recovery
  • Drops in some prescription drug costs brought about by the expiration of patents on several costly medications including Lipitor, Plavix and Singulair, which are now available in low-cost generic versions, and
  • A one-time reduction in Medicare payment levels to skilled nursing facilities

Medicare began paying physicians employed with hospitals more than independent practice physicians due to an arbitrage between Medicare’s Inpatient (Part A) and outpatient (Part B), resulting in hospital outpatient billings among their highest profit centers and incentivizing hospitals to go on a buying binge to purchase doctor practices. This is in addition to the formation of “networks” to take advantage of incentives provided under the ACA.

SK&A highlights the shift of influence in healthcare delivery from 2011 to 2014 in the U.S, as rapidly evolving towards Integrated Health Systems (IHS), causing a dynamic shift in how decisions are made, with more healthcare providers (HCPs) joining large integrated networks, physicians are becoming less influential in purchasing and decision making.

Comparing our tri-state statistics, showing the employment rate of HCPs moving to IHSs from 11/2011 to 3/2014, NJ 16% to 26%, a 63% increase, NY 28% to 38%, a 36% increase and PA 41% to 53%, a 29% increase to an already major transformation.

As we go to the presses, a current report shows that over 1 million Obamacare enrollees received the wrong subsidy, as the purported system for verification of income is flawed, if not, non-existent.

Note: The claw back rule is limited to $2,000 and the only current system for government recovery is when/if the individual has overpaid on his/her taxes.


  • 85% of enrollees are getting aid from the government
  • Average subsidy for exchange enrollees in 2014 is $4,410.
  • 2015-2024, more than $1 trillion will be spent on subsidies

So will the transformation of the private practice physician to hospital based improve our health care delivery system? Will it reduce the cost to the consumer or simply shift the profits from the independent practitioner to the hospitals, networks and/or ACO’s or, will the ACA ultimately increase the cost to employers and employees beyond their capacity to support our current system BEFORE we nationalize!

PPACA-ACA-aka Obamacare Rules-Part II

It has been three months since my last update and, regrettably, there is insufficient space on this page to provide you with all of the changes and executive orders that have transpired, so I will attempt to provide you with the most material changes and updated information:

  • 11/14/13 “People who have plans that pre-date the Affordable Care Act can keep those plans if they haven’t changed”. As we all know, the carriers eliminated that option. The executive extension will now include plans that have changed since the law took effect and the carriers can extend current plans that would otherwise be cancelled but the State Insurance Commissioners still have discretion.
  • 12/19/13 Delay the Individual Mandate for those who lost (cancelled) their coverage due to Obamacare.
  • 12/28/13 Massachusetts Site struggling, only 2800 enrollees.
  • 12/31/13 Supreme Court Justice Sotomayor halts birth control mandate.
  • Obamacare contains 20 new or higher taxes on American families and/or small business. Email us if you would like to have a copy of this list.
  • 1/31/13 WSJ Reports-Nearly 50% of the 114 hospital & doctor groups in ACO slowed Medicare spending in 2012, BUT only 29 saved enough money to qualify for bonus payments according to CMMS.
  • 2/8/14 WSJ Reports-“CIGNA latest Insurer to Expect Loss on Exchange (Humana & Aetna also expect losses)”, citing significantly less enrollees than expected and trending to older enrollees.
  • 2/10/14 Businesses with more than 50 employees but fewer than 100 will have an extra year to phase in health care coverage of employees who work more than 30 hours a week.
  • Employers with more than 100 employees will be subject to employee-coverage rules under the Affordable Care Act beginning in January 2015. The mandate to provide insurance had already been delayed one year
  • Businesses with more than 100 employees must offer coverage to 70% of their full-time employees in 2015 and 95% of their employees in 2016. Employers will need to certify on a form that they did not drop employees to avoid providing coverage, under penalty of perjury.
  • Employers continue to be subject to a $3000 penalty for each worker who buys coverage on a “State” Exchange AND qualifies for a subsidy.
  • Health Care Coverage Gap-2010 Supreme Court ruled that the States could decide if they wanted to expand their Medicaid coverage and 24 States refused, thereby eliminating subsidies, fewer insured and eliminating hospital payments previously received to cover the cost of uninsured.
  • New “Copper Plans” being proposed-Lower premiums with even higher “out-of-pocket” costs, a departure from the minimum essential requirement. Backing the proposal is, The Council for Affordable Health coverage, Aetna and CIGNA.

As the weather may permit, we intend to resume our dinner meetings next month for the physicians of Union County to learn more about the ACA and how it will impact you and your practice and the new savings and benefits available through membership in the Union County Medical Society.

If you have any questions, please contact your representative or feel free to contact our office to provide you with further guidance.

PPACA-ACA-aka Obamacare Rules

As we are all acutely aware, the ACA-Affordable Care Act has gone into startup mode but are you prepared and will you be in compliance?

We have all heard about the “in excess of 2700 pages” of the HealthCare bill, explaining and detailing the inner-workings of this new program and now we are now expected to begin communicating these benefits to our employees and we would like to assist you in both your understanding and obligations pertaining to at least a few of these 2014 requirements, as follows:

  • Effective with your Group Insurance Renewal, you MUST provide “all eligible employees”, regardless of hours, with the carriers SMD-Summary Plan Description.
  • Waiting Periods in excess of 90 days will NO LONGER be available unless you request a change to your current waiting period prior to 12/31/2013. However, upon the occasion of your subsequent renewal, you will be required to have a Waiting Period that will not exceed 90 Days.
  • Individuals are now beginning to be able to access the new Health Insurance Marketplace, where they will be able to shop for alternative plan coverage, effective for 1/1/2014, with the possibility of receiving financial assistance by way of tax credits, depending income upon eligibility based upon their tax filing status.
    • Effective May of 2013, the DOL required employers (refer to FSLA section 18B for qualification) to provide written notification to “ALL” employees by 10-1-13, even if you do not offer coverage, by properly distributing Federal Form OMB #1210-0149, which is intended to provide a General Overview of the Exchange Marketplace:
    • If you have an offer of health insurance from your employer that meets the minimum standards, you will NOT be eligible for a tax credit.
    • If the cost of an employer plan that covers you (and not any other members of your family) is more than 9.5% of your household income and/or doesn’t meet the “minimum value” standard, you may be eligible for a credit.
    • If you purchase a plan through the Marketplace, you may:
      • lose your employer contribution (if any)
      • payments made for coverage purchased through the Marketplace are made on an “After-Tax” basis, contrasted with,
      • payments made through Employer based Section 125 Plan premiums are typically “Pre-Tax”

Note for Employers: This reduction (or lack of reduction) of employee premiums directly impacts what we pay for Social Security, Worker’s Comp, Unemployment & SUI Insurance, as well as Retirement Plan contributions, amounting to a 10%-14% cost differential.

Currently, there is no penalty for non-compliance with Form OMB #1210-0149, however, we would strongly recommend that you at least maintain a detailed list of to whom and when you provided this notification and, preferably, request a written acknowledgement and maintain in your files to avoid future potential fines or litigation for non-compliance.

While the Employer Mandate has been postponed until 2015, effective March 31, 2014, the Individual Mandate will go into effect. If any of your employees find themselves going to the Exchange, this could impact not only your pocket book by way of penalties (large groups) but, if your group falls under the required 75% participation rate, you and your remaining group participants may no longer qualify for your Group Insurance Plan and be forced to purchase individual overage or rely upon the State Exchange/Marketplace (or SHOP for an Employer Plan).

We are pleased to inform you that we have taken the requisite training and licensing to be certified agents on the “Insurance Exchange” and “Small Business Health Options Program”, as well as continuing to be in the vanguard of being able to offer our “all available health plans” available in the State.

If you have any questions, please contact your representative or feel free to contact our office to provide you with further guidance.

However, we would strongly recommend that you at least maintain a detailed list of to whom and when you provided this notification and, preferably, request a written acknowledgement and maintain in your files to avoid future potential fines for non-compliance.

If you have any questions, please contact your representative or feel free to contact our office to provide you with further guidance.

Will the Last Patient to Leave, Please Turn Off the Lights!

This was a familiar refrain to the doc’s, in Pennsylvania in particular, in the late 80’s and early 90’s, which like so much of history, appears to be repeating itself.

Whether due to Obamacare or, perhaps “nobody cares”, the finest healthcare system in the world is changing and, much like the aforementioned, the hospitals are at it again, buying up the valued practices of our best and trusted physicians who, economically, can no longer “afford to care”.

The significant reduction in physician reimbursements, the vast expanse of medical codes from some 12,000 to over 130,000, along with the cost for computerization of medical records is resonating negatively for the private physician. Additionally, for the consumer, the expansive requirements for Preventive Care, the guaranteed acceptance for medical coverage without exemption or penalty for pre–existing conditions (less of an issue in NJ due to existing State mandates) and having insurance that will require less outof–pocket costs for co–pays and deductibles, while all very appealing, can only significantly increase the overall cost of healthcare.

All of these costs will “be shared”, unwittingly adding an additional burden to the consumer, where currently, health plans may charge younger people up to five times less than what they charge older people based upon lower anticipated utilization of services. However, beginning in 2014, older people can only be charged three times more than younger people and with the anticipated enrollment of those in need of care and coverage, particularly for the more critical and previously uninsured, it is only reasonable to assume a greater cost burden to bear by all.

The “Insurance Exchanges” are to be effective October 1 of this year but it appears that this will be moved into 2014, due to a whole host of reasons. Federal subsidies will be available to those in need of individual coverage, subject to documentation of income, and employers will be required to provide certain employees currently participating in the employers’ group health insurance plan with vouchers to opt out of the employers plan to be used exclusively through the exchanges.

The ACA and State Law have mandated the minimization of health plan profits and administrative costs by requiring that 80%–85% of all premiums collected be spent on medical costs. Much like in the case of the physician, your health insurance broker continues to experience a reduction in commission and once the “Insurance Exchanges” are up and running, the reduction and/or elimination of your valued broker could be next.

Please contact us if you would like to learn more about how these changes may impact your group, or you personally. Additionally, for your further interest, we will be offering monthly dinner meetings, limited to invited guests, on this topic in varying locations on behalf of our participating County Medical Societies.

Enhancing The Bottom Line

As business owners, we are acutely aware of the shrinkage we are all experiencing in our revenues, and with our seemingly never ending accelerating expenses, particularly in our assorted insurance expenses, malpractice and health insurance being the most egregious.

While we patiently await the outcome of the Supreme Court’s response this June in the matter of the future of our Healthcare and its’ impact on our lives and respective professions, we are experiencing an accelerated interest in Consumer Driven Health Insurance products, combined with a plethora of “Ancillary” products, which are designed to “plug in the holes”.

These “Ancillary” products are quickly becoming attractive to the employer who may offer these important “fill ins” to their employees, on a discounted and pre-tax basis, while incurring no cost to the employer, other than sponsoring such a program.

There is no secret that these product offerings are designed to reduce the overall costs of the benefits, passing both the expense and, most importantly, the responsibility of the participant to apply greater diligence to the personal management of their medical needs.

It is my professional and personal belief, that, as the Health Insurance industry evolves over the next few years, commissions, like fees, will be either significantly reduced or eliminated by the carriers, leaving the consumer adrift as the conventional agent, operating on a commissionable basis, will be required to become a Registered Investment Advisor (RIA), offering professional guidance and services on a “fee for services” basis, or be forced to leave the business.

In an effort to further diversify our services and assist our physician clients and their respective County Medical Societies regarding their membership retention, recruiting and services, we have formed a marketing corporation, My Professional Member Services Association (myPMSA), to provide our clients with an independent resource.

Finally, to assist in providing discounted insurance products, such as Disability, Business Overhead, Individual and/or Group Long Term Care Insurance, as well as Discounted Professional Services with our participating legal and accounting partners, we will be attempting to seek the approval of the respective interested Societies Executive Boards for their consent to extend these benefits to their members.

Please inquire with your Society to find out if these services have been discussed with your Board members, or contact our office directly for further guidance.

NJAHU State of the State 2012-Healthcare Symposium

Savoy Associates

Wendy Ebner, Pres., NJAHU

4 AAA Drive, Suite 205

Hamilton, NJ 08691

Dear Wendy,

I am an independent broker working through Savoy Associates, as well as being an RIA and I have specialized in working directly with the independent physicians and State and Local County Medical Societies in New Jersey for the last three decades, and I am deeply concerned about our collective industries.

I was in attendance at the aforementioned Symposium and I was particularly interested in the session pertaining to Accountable Care, with Drs. Tallia & Popiel and Messrs. Forrester and Berardo.

Regrettably, we were not offered the opportunity to ask any questions but I would very much appreciate your intervention in communicating with the panel to obtain their respective responses to the following questions:

  • I recall Mr. Aron, our moderator, calling upon Dr. Popiel to provide the audience with a brief description of what ACO, Accountable Care Organizations, are and his response was essentially to inform us that it was the method to be used to determine the reimbursement to the physician, which would be based upon the health of the population/patients under his/her care.

    Given that understanding, I would like to know how the pricing could possibly be determined, as it would necessarily have to be differentiated by locality, i.e., town, city, state, etc. and who would be setting the reimbursement rates, the carriers, State Insurance Department, the Federal Government?

  • If the pricing/reimbursement becomes too diverse, i.e. more favorable reimbursements in “better/more affluent geographic areas”, how will the potential physician migration to the possibly higher reimbursement areas be controlled and who will be left to service the lower reimbursement/higher needs areas, potentially the very people who the Healthcare Reform was to assist, those with lesser means and worse projected outcomes, i.e. lower reimbursements.

    This begs the question of how end of life issues may be handled, as it may pertain to “the bottom line”.

    Could you please address this issue, as well as who will be making the important final testing decisions that may not only assist those in need of critical care but what funds, time and/or testing will be allocated in an effort to maintain a healthy life style.

  • Attentively listening to Dr. Popiel’s explanation of ACO’s, he indicated that the physician/caretaker would ultimately be held responsible for the life results of the patience care.

    I was able to catch up with Dr. Popiel immediately following the presentation and, in addition to the above questions, I asked him how the elongation of the Risk of Malpractice would be assessed, as I have personally known of my own physician clients who were caught up in malpractice issues from many previous years ago when they were residents, for which they had very little, if any, involvement, that resulted in significant malpractice pricing issues, particularly for certain specialties like Ob/Gyn, Neurology etc..

    Much to my surprise, Dr. Popiel informed me that they have not yet even addressed this issue.

    Other than the obvious concern for the physician, this unanticipated cost could be astronomical, particularly in light of today’s extraordinarily litigious society, driving even more physicians/caretakers out of the market and exponentially increasing the costs of Healthcare for all.

    How can this very important pricing issue be non-addressed? My cynical thought process leads me to an obvious but hopefully non-negotiable answer that would leave the Federal Government in charge of all Healthcare, God Forbid!

Your kind and empowered assistance in seeking the panel’s responses would be much appreciated and hopefully passed along to the members of the NJAHU and the associated concerned.


Michael G. Kirwan, CLU, ChFC, RIA

Registered Investment Advisor

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