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RESOLUTION NO. 13852
A RESOLUTION APPROVING A SERVICE AGREEMENT
BETWEEN THE CITY OF PUEBLO AND FARM CREDIT
COUNCIL SERVICES, INC., DBA FCC SERVICES, INC.,
RELATING TO WORKERS’ COMPENSATION FOR FISCAL
YEAR 2018
BE IT RESOLVED BY THE CITY COUNCIL OF PUEBLO, that:
SECTION 1.
The Service Agreement between the City of Pueblo and Farm Credit Council Services,
Inc., DBA FCC Services, Inc., relating to third-party administration for the City’s self-insured
workers’ compensation program and Medicare reporting requirement for the year 2018, a copy
of which is attached hereto, having been approved as to form by the City Attorney, is hereby
approved.
SECTION 2.
The President of the City Council is authorized to execute and deliver the Service
Agreement in the name of the City and the City Clerk is directed to affix the seal of the City
thereto and attest same.
SECTION 3.
The officers and staff of the City are directed and authorized to perform any and all acts
consistent with the intent of this Resolution and the attached agreement to effectuate the
transactions described therein.
SECTION 4.
This Resolution shall become effective upon passage and approval.
INTRODUCED December 26, 2017
BY: Ed Brown
City Clerk’s Office Item # M-2
BACKGROUND PAPER FOR PROPOSED
RESOLUTION
COUNCIL MEETING DATE:
December 26, 2017
TO: President Stephen G. Nawrocki and Members of City Council
CC: Sam Azad, City Manager
VIA: Brenda Armijo, Acting City Clerk
FROM: Marisa L. Pacheco – Human Resources Director
SUBJECT: A RESOLUTION APPROVING A SERVICE AGREEMENT BETWEEN THE CITY
OF PUEBLO AND FARM CREDIT COUNCIL SERVICES, INC., DBA FCC
SERVICES, INC., RELATING TO WORKERS’ COMPENSATION FOR FISCAL
YEAR 2018
SUMMARY:
Attached is a Resolution accepting an agreement between the City of Pueblo and FCC
Services, Inc., relating to Workers’ Compensation.
PREVIOUS COUNCIL ACTION:
On December 27, 2016, Resolution No. 13582 was approved by City Council. This Resolution
accepted the service agreement with FCC Services for Fiscal Year 2017.
BACKGROUND:
FCC Services, Inc., will continue to act as third-party administrator for the City’s self-insured
workers’ compensation program and Medicare reporting requirement for 2018 for the annual fee
of $83,472.52 for management of the claims, payable monthly. The Medicare reporting fee will
be $2,750. This is a 4% increase in the contract to cover increasing administrative costs and
cost of living increases for the provider.
FINANCIAL IMPLICATIONS:
The total cost for the service agreement in 2018 is $86,222.52, which is an increase of
$3,210.50 annually over 2017 costs.
BOARD/COMMISSION RECOMMENDATION:
None.
STAKEHOLDER PROCESS:
None.
ALTERNATIVES:
There is no alternative to this request as the City of Pueblo is required to have a service
agreement in order to work with FCC Services, Inc., to perform Workers’ Compensation
consultation and claims administration services.
RECOMMENDATION:
Approval of the Resolution.
Attachments:
FCC Services Agreement
SERVICE AGREEMENT
Between City of Pueblo and FCC Services
In consideration of the mutual covenants herein contained, FCC Services, an independent
contractor, hereinafter referred to as"FCCS", does hereby contract and agree with City of
Pueblo, hereinafter referred to as "Client", as follows:
1. Appointment: Client hereby appoints FCCS, and FCCS hereby agrees to serve,
as Third Party Administrator("Administrator")of Client's Worker's
Compensation program.
2. Term& Termination:
A. Term: The initial term of this Service Agreement shall be for one(1) year
commencing January 1, 2018 through December 31,2018. Unless otherwise
terminated as provided in this Agreement,this Agreement shall automatically
renew on a calendar year basis subject to annual appropriation of funds by
Client; provided, however, FCCS may serve written notice to Client of its
intent to renegotiate any provision of the Agreement no later than September 1
of the then current year of the Agreement. If the parties are unable to reach
agreement after timely receipt of such notice,the Agreement shall terminate
upon expiration of the then current year of the Agreement. Any amendment
shall be reduced to writing and approved by the parties.
B. Termination. This Agreement may be terminated:
i. By mutual agreement of the parties hereto;
ii. Upon expiration of the then current year of this Agreement if either
party has given the other party written notice of its intent to
terminate at least(60) sixty days prior to the expiration of the then
current year of the Agreement. Such termination may be without
cause and shall be treated as a non-renewal under the provisions of
this Agreement.
iii. Upon dissolution of Client's self-insurance program whether
voluntary or due to cessation of Client's authority to self-insure;
iv. Either party may immediately terminate at any time for material
breach of contract, gross negligence, wanton misconduct, or fraud.
Such termination for cause shall be by written notice specifying the
grounds for termination. Said notice shall be effective when
received except in the case of material breach of contract. In the
case of material breach of contract, said notice shall be effective if
the breach is not cured within (30)thirty days of receipt of written
notice specifying the material breach.
v. No Multi-year Fiscal Obligation on Client. This Agreement is
expressly made subject to the limitations of the Colorado
Constitution. Nothing herein shall constitute, nor deemed to
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constitute, the creation of a debt or multi-year fiscal obligation or
an obligation of future appropriations by Client,contrary to Article
X, § 20 Colorado Constitution or any other constitutional, statutory
or charter debt limitation. In the event Client determines not to
appropriate funds for another term upon the expiration of the
current term of this Agreement, Client shall immediately notify
FCCS and the contract shall be terminated at the end of the current
term. FCCS shall finalize the current term's obligations and submit
a final invoice and Client shall pay the invoice upon receipt,
pursuant to the terms agreed to herein.
C. Services Following Termination:
Should this Agreement be terminated or non-renewed for any reason,
FCCS will cease providing services, terminate Client access to the
claims management system, and turn over to Client all physical claim
files in FCCS's possession, which shall include all open and closed
files. Any electronic claim file Client wishes to have reproduced to a
physical claim file shall incur copying fees commensurate to the fee
schedule in Rule 18 of the Colorado Worker's Compensation Rules of
Procedure.
ii. Upon Client's request FCCS shall provide for continued claims
administration (hereinafter referred to as"Continuation")of all claims
for a period of time not to exceed (6)months after termination and at a
fee equal to a pro rata share of the Annual Service Fee under 9.A. that
is currently in effect if termination occurred during the Term of an
ongoing Agreement; if termination is instead due to a non-renewal
then the Annual Service Fee in effect under 9.A. for that prior
Agreement shall be used. Client shall also pay any and all ongoing
Annual Medicare/Medicaid Reporting Fee, bank fees, and check stock
fees under paragraphs 9.B. & 9.C. that occur as a result of
Continuation. All paragraphs other than 2.A. &2.B.of this Service
Agreement shall apply for this Continuation period.
iii. Should this Agreement be terminated or non-renewed for any reason,
and regardless of whether or not Continuation is requested by Client,
FCCS shall cooperate with any successor administrator in the orderly
transfer of all functions, including providing a runoff list of open claim
files and a(6)six month history of medical bills reviewed, if desired
by Client and any other records reasonable and necessary for a
successor administrator. With respect to such records requested by
Client, Client will reimburse FCCS all direct costs to its vendors to
extract claim and medical bill records from its claim management,
Medicare reporting vendor, and medical bill review systems.
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3. FCCS Responsibilities: During the term of this Agreement, the regular functions
of FCCS as Client's Administrator shall include the following:
A. Claims Administration: In compliance with Client's Quality Service Plan,
internal written protocols,and all applicable laws, rules and regulations,
FCCS will administer all Worker's Compensation claims received from
Client. FCCS will act on behalf of Client to adjust all such actual and alleged
claims on a Life of Service basis, defined as for the duration of the Terms of
this Service Agreement and all prior consecutive Service Agreements between
Client and FCCS. This includes, but is not limited to, managing the
following: investigations,determination of compensability, claim reserves,
payments of all claim benefits and expenses, litigation,pursuit of subrogation
in compliance with Section 3.B. below,settlement negotiations, filing of all
appropriate forms with any agency either required by law or recommended by
industry best practices, documentation of activity, nurse case management,
reporting to Client's Excess insurer, and other claim functions as needed.
Parameters for limits of authority as well as contact protocols shall be
established with and agreed to by Client as documented in the Quality Service
Plan(QSP).
B. Subrogation: FCCS will file a Notice of Lien or any other notice required by
law to put a third party on notice of possible subrogation,make initial contact
with a third party's insurance company and provide the third party insurer's
contact information to Client. Asset reviews will be conducted when
appropriate or upon Client request. It is Client's responsibility to notify FCCS
of their desire to pursue subrogation. If Client requests FCCS to continue
subrogation, additional fees will apply to hire outside counsel to complete
subrogation.
C. Client Access to FCCS's Claims Management System: FCCS will provide to
Client(2)two limited security accesses to the claims management system.
One of them will allow data entry of new claims, and read-only access to the
claims data. The second will provide read-only access to the claims
management system for the use of Client's broker.
D. Bank Account: Maintain an escrow account on Client's behalf to pay claims
losses and Allocated Loss Adjustment Expenses as outlined in this
Agreement. FCCS shall provide to Client a monthly bank statement of this
escrow account. It is expressly understood that FCCS shall not be required to
advance its own funds to pay for any obligation of Client. Client is liable for
any fees, fines, or penalties resulting from any delays in providing funds to
FCCS.
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E. Allocated Loss Adjustment Expenses(ALAE): ALAE are charges for
services provided in connection with specific claims by persons or firms other
than FCCS which are eligible claim expenses under Client's program.
Notwithstanding the foregoing, ALAE will include all expenses incurred in
connection with the investigation, adjustment, settlement, or defense of
Client's claims, even if such expenses are incurred by FCCS. These shall be
paid out of the escrow account and charged against the claim file(s)to which
they pertain.
F. Provision of Reports: FCCS agrees to provide standard reports to Client as
needed and specified by Client. FCCS will provide custom/special reports at
the request of Client for a fee of$150.00 per hour if generated by FCCS and
$225.00 per hour if generated by the claims management system provider
due to special customization requirements. No non-standard reports will be
generated and charged without the prior approval of Client.
G. Medicare Reporting: Provide a comprehensive Medicare reporting solution
utilizing vendor partners who specialize in facilitating the full cycle of
reporting Medicare beneficiary data to Centers for Medicare and Medicaid
Services(CMS)on behalf of Client as more fully outlined in Appendix A.
FCCS shall be responsible for any fines imposed by CMS resulting from a
failure to meet its responsibilities as outlined in Appendix A.
H. Tax Reporting: By the third Friday of each January following the term of
this Agreement, FCCS shall provide Client the necessary information for
Client to issue 1099s to vendors that FCCS uses for the administration and
medical care of claims handled under this agreement.The information FCCS
shall provide to Client includes the vendor name, FEIN, address and total
payment amounts for the taxable year relevant to the 1099. FCCS shall also
retain all documentation evidencing that the information it provides to Client
was supplied by the vendor, including copies of all W-9s related to each
vendor. FCCS shall provide copies of such documentation within five (5)
days of a request by Client.
I . Risk Management& Loss Control Services: Provide various loss control
services totaling not more than 24 hours per year such as: on site loss
prevention inspections at locations with excessive loss frequency(as agreed
upon between Client and FCCS),attend safety meetings at no charge to
Client except for FCCS travel expenses, and advise the Client on internal
procedures and policies to help reduce their risk. Perform such other duties
as requested by the Client to assist in the conduct of the Client's Workers'
Compensation Loss Prevention Program at a rate of$100 per hour.
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4. Client Responsibilities. Client agrees to:
A. Report all claims, incidents, reports or correspondence relating to potential
claims in a timely manner.
B. Reasonably cooperate in the disposition of all claims.
C. Respond to reasonable requests for information in a timely manner.
D. Maintain at Client's expense an escrow account in the amount of$100,000 with
a bank chosen by FCCS to issue claim settlements,benefits,and Allocated Loss
Adjustment Expenses.
E. Promptly pay FCCS's fees when billed and replenish its escrow account
maintained with FCCS for payments made on behalf of Client's claim
adjudication and processing on a weekly basis.
F. Be responsible for maintaining its registration with the COBSW and
designation of the applicable organization as Reporting Agent (RA)or making
any changes to the designated RA as may be required. .Client is responsible for
providing RRE ID information to FCCS and it's CMS reporting vendor partners
as outlined in Appendix A.
G. Ensure that the CMS Data Elements have been provided to FCCS for all data
elements/fields required by the CMS Section 1 l 1 guidelines in a timely manner,
not greater than (4) four days after requested, for accurate reporting to CMS.
Client shall be responsible for any fines imposed by CMS resulting from failure
to provide to FCCS any data elements/fields required by CMS Section 111
guidelines within(4)four days after request.
5. Oneratine Expenses. Client agrees to be responsible for and pay all of its own
operating expenses other than service obligations of FCCS. Such operating
expenses shall include but not be limited to charges for the following:
a. All costs associated with Client meeting its state security and licensing
requirements;
b. Certified Public Accountants;
c. Attorneys, other than provided for in Section 3.D of this Agreement;
d. Outside consultants, actuarial services or studies and state audits;
e. Independent payroll audits;
f. All applicable regulatory fees, fines, and taxes;
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g. Educational and/or promotional material, industry-specific loss control
material, customized forms, checks and/or stationary, supplies and
extraordinary postage, such as bulk mailing, express mail or messenger
service;
h. NCCI(National Council on Compensation Insurance)charges;
i. Excess and other insurance premiums;
j. Other operating costs as normally incurred by Client.
6. Books and Records.
A. FCCS shall maintain all claim information relating specifically to Client which
is necessary to the performance of FCCS's obligations under this Agreement
(the "Records"). The Records shall remain at all times the sole property of
Client.
B. The Records shall not include any manuals, forms, files and reports,
documents, customer lists, rights to solicit renewals, computer records and
tapes, financial and strategic data, or information which documents FCCS's
processes, procedures and methods, or which FCCS employs to administer
programs other than Client's. The items specified in this paragraph shall at all
times be and remain the sole and exclusive property of FCCS.
C. Unless this Agreement is terminated, FCCS will maintain all closed files on
behalf of Client for a period of(7) seven years after the month of closure, or
for as long as necessary to protect the applicable statute of limitations,
whichever is longer. At the end of this time period, all physical files will be
destroyed. It is the sole responsibility of Client to advise FCCS if files are not
to be destroyed per this policy and to instruct FCCS how they wish such files
to be transmitted elsewhere at Client's expense.
D. During the term of this Agreement, FCCS shall provide Client with copies of
the Records, if so requested by Client. All reasonable costs of reproduction of
the Records shall be borne by Client. In the event this Agreement is terminated
or non-renewed,Client Records will be turned over to Client or to a successor
administrator designated by Client. In the event this contract is terminated or
non-renewed, Electronic Data Transfer to Client or a successor administrator
designated by Client, shall be accomplished upon receipt of a $1,000.00 fee
plus reasonable out of pocket costs necessarily incurred by FCCS to
accomplish such Electronic Data Transfer.
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E. FCCS shall make the Records available for inspection by any duly authorized
representative of Client, or any governmental or regulatory authority having
jurisdiction over FCCS or Client.
7. Indemnification.
A. Indemnification of Client. FCCS agrees that it will indemnify and hold
harmless Client and Client's trustees, directors, officers, employees, agents,
shareholders, subsidiaries, and other affiliates from and against any and all
claims, losses, liability,costs, damages and reasonable attorney's fees
incurred by Client as a result of breach of this Agreement by FCCS, or
misconduct, errors or omissions by FCCS, or by any of FCCS's trustees,
directors,officers, employees, agents, shareholders,subsidiaries, or other
affiliates in connection with the performance of this Agreement.
B. Third Party Errors. FCCS shall not be responsible for any CMS, Client, or
other third party system failures or connectivity issues which may result in
failures to transmit Client's transactions within the CMS required time frames,
unless such failure is a result of FCCS's negligence. FCCS shall not be
responsible for errors or omissions, negligence of, or connectivity issues or
delays by it's CMS reporting vendor partners. FCCS shall not be responsible
for any claim, damages, fines, losses or expenses arising in connection with or
as a result of any errors, omissions,or negligence of a CMS reporting vendor
partner if Client does not respond within (4)four business days of receipt of
an e-mail notification from FCCS about a CMS response regarding Client's
Claim Input information with any applicable corrected information.
S. Miscellaneous.
A. Governing Law. This Agreement shall be governed by and construed in
accordance with the internal laws of the state of Colorado, based on state of
hire, without regard to principles of conflicts of law.
B. Timing of Services. FCCS may exercise its own reasonable judgment, within
the parameters set forth herein and in compliance with state regulations, as to
the time and manner in which it performs the services required hereunder.
Additionally, FCCS will be held to a standard of like administrators
performing like services for customers such as Client.
C. Successors in Interest. This Agreement shall be binding upon, and inure to
the benefit of, the successors in interest and permitted assigns of the parties
hereto.
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D. Severability. The invalidity or unenforceability of any particular provision of
this Agreement shall not affect the other provisions hereof, and this
Agreement shall be construed in all respects as if the invalid or unenforceable
provision had been revised to the minimum extent necessary to make it valid
and fully enforceable under applicable law.
E. Paragraph Headings. All paragraph headings in this Agreement are for
reference purposes only and shall not affect in any way the meaning or
interpretation of this Agreement.
F. Waiver. The failure of any party to enforce any provisions of this Agreement
shall not constitute a waiver by such party of any provision. A past waiver of
a provision by either party shall not constitute a course of conduct or a waiver
in the future with respect to that same provision.
G. Entire Agreement/Amendment. This Agreement sets forth the full and final
understanding of the parties hereto with respect to the matters described
herein, and supersedes any and all prior agreements and understandings
between them, whether written or oral. This Agreement may be amended
only by written document executed by Client and FCCS.
H. Relationship of Parties: With respect to the services provided by FCCS in this
Agreement, FCCS is considered an independent contractor. Nothing in this
Agreement shall be construed to create a relationship of employer/employee,
partners or joint ventures between Client and FCCS. This Agreement is non-
exclusive,and FCCS shall have the right to perform services on behalf of other
individuals, firms, corporations, and entities.
I. Change in Circumstances: In the event the adoption of any statute, rule or
regulation materially changes the nature of the relationship between the
parties hereto or the legal or economic premises upon which this Agreement is
based, the parties hereto shall undertake good faith negotiations to amend this
Agreement to account for such changes in a reasonable manner.
J. Dispute Resolution: [f an irreconcilable difference of opinion or claim should
arise between Client and FCCS as the interpreters of any matter relating to this
Agreement and the parties are unable to resolve the dispute within fifteen (15)
days from the date the dispute arises, either party within fifteen (15) days
thereafter may submit the dispute to mediation before the Judicial Arbiter
Group in Denver, Colorado. This provision shall survive termination of the
Agreement.
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K. Notice Provision. All notices, requests, and other communications required
under this Agreement shall be in writing and delivered by hand or mailed,
registered or certified, return receipt requested, postage paid, or sent via a
nationally recognized overnight courier to the other party at the following
address:
Client: City of Pueblo
301 W. B Street
Pueblo, CO 81003
Attn: Marisa Pacheco
With copy to: HUB International—Pueblo office
FCCS: FCC Services
7951 E. Maplewood Avenue#3-225
Greenwood Village, CO 80111
Attn: Mike Layman
L. Insurance. FCCS will purchase and maintain insurance coverage for its
performance of the services contemplated in this Agreement. Minimum
policy limits are as follows:
Workers' Compensation—statutory limits
Professional Liability-$5,000,000
General Liability-$1,000,000/$2,000,000
Umbrella-$5,000,000
M. Non-Solicitation of Employees. During the term of this Agreement and for six
(6)months thereafter, Client and FCCS mutually agree not to recruit, solicit or
hire any employee of the other without written permission; provided, however,
this provision shall have no application to individuals hired through the Civil
Service System of Client.
N. Undocumented Workers. Pursuant to Colorado Revised Statutes ("C.R.S.") §
8-17.5-101,et. seq., FCCS shall not: (a)knowingly employ or contract with
an illegal alien to perform work under this Agreement; or(b)enter into a
contract with a subcontractor that fails to certify to FCCS that the
subcontractor shall not knowingly employ or contract with an illegal alien to
perform work under this Agreement. FCCS further represents, warrants, and
agrees that: (1) FCCS has confirmed the employment eligibility of all
employees who are newly hired for employment in the United States to
perform work under this Agreement, through participation in either the E-
Verify Program (defined in C.R.S. § 8-17.5-101(3.7))or the Department
Program established pursuant to C.R.S. § 8-17.5-102(5)(c); (2) FCCS shall not
use either the E-Verify Program or the Department Program procedures to
undertake pre-employment screening of job applicants while this Agreement
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is being performed; (3) if FCCS obtains actual knowledge that a subcontractor
performing work under this Agreement knowingly employs or contracts with
an illegal alien, FCCS shall: notify the subcontractor and Client within three
days that FCCS has actual knowledge that the subcontractor is employing or
contracting with an illegal alien; and terminate the subcontract with the
subcontractor if within three days of receiving the notice required pursuant to
the previous provision, the subcontractor does not stop employing or
contracting with the illegal alien; except that FCCS shall not terminate the
contract with the subcontractor if, during such three days,the subcontractor
provides information to establish that the subcontractor has not knowingly
employed or contracted with an illegal alien; and (4) FCCS shall comply with
any reasonable request by the Colorado Department of Labor and
Employment made in the course of an investigation under C.R.S. § 8-17.5-
102. If FCCS fails to comply with any requirement of this paragraph or C.R.S.
§ 8-17.5-101 et. seq.Client may terminate this Agreement for a breach of this
paragraph.
O. Force Majeure. Each party will be excused from performance for any period
during which, and to the extent that, it is prevented from performing any
obligation or service, in whole or in part, as a result of causes beyond its
reasonable control, and without its fault or negligence, including without
limitation, acts of God, riots, and acts of war. Any such excuse for delay shall
last only as long as the event remains beyond the reasonable control of the
delayed party. However,the delayed party shall use commercially reasonable
efforts to minimize the delays caused by any such event. This section shall
not apply to those performances required by each party in accordance with
CMS reporting requirements as outlined herein or to any statutory filing
requirements with the Colorado Department of Labor and Employment.
P. Authority of Signers. Each person signing this Agreement on behalf of a
party represents and warrants that he or she has the requisite power and
authority to enter into, execute, and deliver this Agreement on behalf of such
party and that this Agreement is a valid and legally binding obligation of such
party enforceable against it in accordance with its terms.
9. Compensation.
A. Annual Service Fee: $83,472.50 for management of the claims on a Life of Service
basis, access to the claims database,and reporting capabilities.
1. The above pricing assumes Client shall enter all First Reports of Injury (FROI)
directly into the claims management system using the webtool. A $25.00 fee per
FROI entered by FCCS into the claims management system shall be billed to the
claim file as an Unallocated Loss Adjustment Expense(ULAE)cost for any such
data entry that occurs when the claims management system and webtool are both
operational.
2. Whenever a claim involves subrogation actions, an additional fee of 10% of the
recovery shall be billed to the claim file as Allocated Loss Adjustment Expense
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(ALAE), not to exceed$1,150.00 per claim.
3. Any Tenn in which the total claims received during the Service Agreement Term
increases by greater than 10% compared to the average yearly claim count shall
incur a$650.00 fee per claim above that average. FCCS shall provide an invoice
and documentation of this additional fee within 90 days of the end of the Term.
The average yearly claim count shall be defined as 121 for this year.
B. Annual Medicare/Medicaid Reporting Fee: $2,750 fee for the license.
C. Billing Cycle:
i. Items 9.A.1. and 9.B shall be billed to Client monthly in one collective
invoice in the amount of$7,185.21
ii. Bank fees shall be billed to Client monthly in a separate invoice.
iii. Items 9.A.2. & 9.A.3. shall be billed as they are incurred.
iv. Whenever check stock costs are incurred, they shall be billed to Client in a
separate invoice.
v. Payment of all invoices by Client are due upon receipt.
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Appendix A
1. FCCS will maintain all required SCHIP("Act")data elements provided by Client in
FCCS' claims database effective October 1,2009.
2. FCCS will contract on behalf of Client with vendor partners who specialize in
providing an automated solution to comply with CMS 111 reporting requirements.
This automated solution will:
a. Verify Medicare eligibility of all claimants every month.
b. Report new or existing claims as required under the Act during the designated
reporting period Client provides.
c. Report closed claims as required under the Act during the designated
reporting period Client provides.
3. FCCS will maintain the Client's RRE ID number supplied by Client in its database.
4. FCCS will update Client's database for any Medicare eligible claim so the automated
solution is launched properly.
5. FCCS will notify Client of any errors in data supplied by Client within 24 hours so
Client can provide correct information to FCCS within four(4)business days to avoid
fines from CMS for data transmission errors.
•
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Executed this 26th day of December , 2017.
FCC Services:
9774(// -----
B � //- / /7
Mike Layman, C ims Manager DATE
City of Pueblo, a Municipal Corporation
4.- ..---- ,
Attest: B : L `
Rain() City Clerk President of the City Council
Date: December 26, 2017 Date: December 26, 2017
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