Benefits Payable in Terminated Single-Employer Plans; Limitations on Guaranteed Benefits

Image via WikipediSUMMARY: This is a proposed rule to
amend PBGC’s regulation on Benefits
Payable in Terminated Single-Employer Plans. That regulation sets forth rules on PBGC’s guarantee of pension plan benefits, including rules on the phasein of the guarantee. The amendments implement section 403 of the Pension Protection Act of 2006, which provides that the phase-in period for the guarantee of  benefits that are contingent upon the occurrence of an ‘‘unpredictable contingent event,’’ such as a plant shutdown, starts no earlier than the date of the shutdown or other unpredictable contingent event.

DATES: Comments must be received on or before May 10, 2011.

ADDRESSES: Comments should be identified by Regulation Information Number (RIN 1212–AB18), and may be submitted by any of the following methods:

• Federal eRulemaking Portal: http://www.regulations.gov.
• Follow the Web site instructions for submitting comments.
• E-mail: reg.comments@pbgc.gov.
• Fax: 202–326–4224.
• Mail or Hand Delivery: Legislative and Regulatory Department, Pension Benefit Guaranty Corporation, 1200 K Street, NW., Washington, DC 20005–4026.

PBGC will make all comments available on its Web site, http://www.pbgc.gov.

Copies of comments also may be obtained by writing PBGC’s Communications and Public Affairs
Department (CPAD) at Suite 240 at the above address or by visiting or calling CPAD during normal business hours (202–326–4040).

FOR FURTHER INFORMATION CONTACT: John
H. Hanley, Director; Gail A. Sevin, Manager; or Bernard Klein, Attorney;
Legislative & Regulatory Department,
Pension Benefit Guaranty Corporation,
1200 K Street, NW., Washington, DC
20005, 202–326–4224. (TTY/TDD users may call the Federal relay service tollfree at 1–800–877–8339 and ask to be connected to 202–326–4224.)
Complete Federal Register Notice with Full Details

Family Value: When Insurers Deny Claims - WSJ.com

By ANNE TERGESEN

Some families with long-term-care insurance policies—under fire recently for steep premium increases—are encountering claims denials that can prevent or delay the collection of benefits. But there are ways policyholders can avoid such problems.

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  Image by Mark Matcho

HCBS / More Than Meets the Eye: Long-Term Care Provisions in the New Reform Law

Summary

To provide a look at the various provisions of the new health reform law on LTC, a distinguished panel of experts addressed questions such as: What are the provisions of the law pertaining to LTC? How will consumers, providers and states be affected? What are the major components of the CLASS Act, and what are some of the challenges for states and the federal government in implementation? Access the presentations, transcript, event summary, podcast and more.

Author

Bosstick, Suzanne; Akins, Tom; Lamphere, JoAnn

Available Files

• Briefing Off-site link

Speakers

Ed Howard, Alliance for Health Reform, Moderator Diane Rowland, Kaiser Family Foundation, Moderator  Richard Frank, U.S. Dept. of Health and Human Services, Speaker  Suzanne Bosstik, Centers for Medicare and Medicaid Services, Speaker  Tom Akins, N.C. Assoc. of Non-Profit Homes for the Aging, Speaker  JoAnne Lamphere, AARP, Speaker (Click on the camera icon to see a video of the speaker's presentation.)

Transcript, Event Summary and/or Webcast and Podcast

Transcript: More Than Meets the Eye: Long-Term Care Provisions in the New Reform Law (Word Document), 10/1/2010 Full Webcast/Podcast: More Than Meets the Eye: Long-Term Care Provisions in the New Reform Law

The full webcast and podcast for this briefing, as well as videos of individual speakers' presentations, are provided by Kaiser Family Foundation.

Speaker Presentations

Suzanne Bosstick (PowerPoint), 10/1/2010 Tom Akins (PowerPoint), 10/1/2010 JoAnn Lamphere (PowerPoint), 10/1/2010 (If you want to download one or more slides from these presentations, contact us at info@allhealth or click here for instructions.)

Will Congress Repeal Health Care Reform?

by Barbara O'Brian


As soon as Republicans knew they had won a majority of House seats in the midterm elections, GOP leaders vowed to repeal health care reform. Can they do this? And should they?

Frankly, chances that the health care reform bill could be repealed completely are remote, especially since such repeal would have to override President Obama's veto, and the Senate still has a Democratic majority.

House Republicans say they have some tricks up their sleeves, such as refusing to provide funds in the budget to implement health care reform. However, provisions of the law that will expand Medicaid and help subsidize private insurance won't kick in until 2014. Until then, there's not much the House can do to the budget to stop health care reform from going forward, short of defunding the entire Health and Human Services department.

Another "trick" might be to dismantle the bill piece by piece. One provision that many people want to remove is the individual mandate, which will require most Americans to obtain health insurance or pay a tax penalty. This provision also kicks in in 2014, and it's one that Baby Boomers in particular will want to fight to keep.

Here's why: Beginning in 2014, private insurance companies will no longer be able to refuse to insure someone because of a pre-existing condition. But without an individual mandate, there will be no incentive for younger and healthier people to purchase health insurance until the time comes when they need it. This means those left in the insurance "risk pool" will be older, and that drives up the cost of insurance.

By the time we reach 50, nearly all of us have "pre-existing conditions." Some of our conditions are common, and some are not -- mesothelioma, for example, is rarely diagnosed in patients younger than 50. And without Medicare or other good insurance, mesothelioma treatment would be financially devastating.

But without the individual mandate requiring that healthier people share in the cost of insuring all of us, the health insurance premium bills for people aged 50 to 65 will be ruinous. We can scrap health care reform entirely, of course, but keep in mind that if you lose your insurance before you reach Medicare age you may not be able to purchase insurance at all, at any price, if you have a pre-existing condition.

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• The 1099 Logjam and the Future of Health Reform (swampland.blogs.time.com)

Health Care Reform Explained - AARP Bulletin

Image by Getty Images via @daylifeby: Susan Jaffe | from: AARP Bulletin

Confused about the new health care reforms? You’re not alone. The legislation is full of new benefits, rules, penalties and projects, spread out over several years.
To help you understand what the health care law means for you, the AARP Bulletin is answering your questions about:

Access to Coverage

Q. I'm 58 and retired. I understand the new reform law helps employers offer health care coverage to their early retirees ... More
Q. I'm over 50 and have been turned away by insurers because of my health problems ... More
Q. I'm 62. If I retire this year, what type of medical coverage can I get before Medicare kicks in? ... More
Q. My insurance company told me my 23 year old daughter could no longer be on my family plan. I've heard I can insure her now... More
Q. I'm disabled, in my 50s, and over the eligibility line for Medicaid. But I can’t afford health insurance ... More
Q. Does the new health care reform law eliminate annual and lifetime limits on health care coverage in insurance policies? ... More

Access to Care

Q. I'm having trouble finding a primary care doctor now. Will it be harder for me to get one when millions more people ... More
Q. Does the law limit the treatment my doctor can give me? Will some faceless bureaucrat decide I'm "too old" for surgery? ... More
Q. If we use wellness programs, can we get a discount on our insurance costs? ... More
Q. Must insurance companies offer free cancer screenings and other preventive health benefits? ... More
Q. What does health reform do to help people with mental illness get the treatment they need? ... More

Rules and Requirements

Q. Will I be forced to buy insurance? What if I can't afford it? ... More
Q. We own a small business. Will the law force us to provide our part-time employees with health insurance? ... More
Q. What does it mean if my health plan is "grandfathered"? ... More
Q. Will a Muslim be required to buy health insurance? There are lots of rumors on the Internet about this ... More
Q. I heard the IRS is hiring 16,500 agents just to make sure we buy insurance ... More

Savings and Costs

Q. President Obama says health care reform will save us money, but others say we'll pay more in taxes ... More
Q. Will the new law help us afford better insurance? ... More
Q. How does health care reform lower our insurance costs? ... More
Q. My premium for an individual health insurance policy is going up 22 percent. Can they do that?... More
Q. What health care reforms start Sept. 23, 2010, and what's so magical about that date? ... More
Q. Is there a big new tax on home sales that is supposed to raise money to pay for health reform? More

Medicare, Medicaid and Other Insurance

Q. I have many health problems, low income, no insurance and don't qualify for Medicaid. Will the new law help people like me? ... More
Q. I've heard that government payments to Medicare Advantage will be reduced or stopped altogether ... More
Q. Will the new law make it easier to get long-term care health insurance? ... More
Q. I'm a Marine Corps veteran with health coverage through TriCare and the V.A. Will there be changes to my coverage ... More
Q. How does the new law strengthen Medicare while reducing its funds? ... More
Q. Will Medicare provide free services to help quit smoking? ... More
Q. How does the law stop Medicare and Medicaid fraud? ... More

Full Article

FAQs on Long Term Care Insurance - New York State Partnership for Long-Term Care - Senior Counsel

by Lisa M. Powers

I recently met with a new client, who mentioned he had a long term care insurance policy. He had not brought the policy with him to our consultation so I asked, "Do you know if your policy is a partnership policy?" He answered "Everything my wife and I did in our 57 year marriage has been a partnership." Very touching, but clearly he knew nothing about a policy that he has been paying premiums on for years. I thought it was time to add a link with some information to this site in hopes that others might benefit from it. For those who do not know, a partnership policy for long-term care has special benefits that non-partnership policies do not. The biggest benefit is that if you have a partnership policy and use up all of the benefits under it you can automatically qualify for Medicaid assistance. There are variations, however, and not all policies are alike. Since 2006 we have "total asset protection" policies and "partial asset protection" policies available to us. I have written about this before; your financial advisor may not be the best person to sell you this insurance. You need someone who specializes in long-term care policies so that you receive proper advice tailored to your situation. Once you know the appropriate policy for you you should then go back to your advisor to work out the best method to pay the premiums (here is a good way to bleed out an annuity you purchased before you learned how bad they are for most people).

Long-Term Care Insurance Resources

Long-Term Care Resources include:

MetLife QuickFACTS - February Edition

Image via Wikipedia

QuickFACTS is a monthly fact sheet produced by the MetLife Mature Market Institute. The focus is the emerging market of people 50+. MetLife compiles recent news and developments on multi-generational issues that impact its business and its customers.

Read/Download Newsletter

Investors Recruit Terminally Ill to Outwit Insurers on Annuities - WSJ.com

By MARK MAREMONT And LESLIE SCISM

"Terminal Illness? $2,000 in CASH, Immediately Available."

That was the promise of an advertisement that appeared regularly in 2007 and 2008 in the Rhode Island Catholic, the official newspaper of the local diocese. The money, the ad said, was coming from a "compassionate organization" that wanted to provide "financial assistance" for those near death.

In reality, the ad was a recruiting pitch for a plan hatched by a prominent Rhode Island estate-planning lawyer, who believed he had discovered a way to use an investment product sold by insurance companies to make no-risk bets on the stock market. He recruited dozens of terminally ill people to, in effect, serve as paid fronts for purchases of the product, variable annuities. The lawyer and other investors put tens of millions of dollars into the policies, hoping to reap a profit when the recruits died.

The arrangement, now under investigation by federal prosecutors and snarled in litigation, is the latest twist in a cat-and-mouse game between insurers and sophisticated investors. The investors comb through policies marketed to individuals and figure out ways to convert them into profit-making products for people with no emotional bond to the deceased.
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State senator proposes Medicare bill for stricter sales guidelines - Columbia Missourian

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BY Brian Krebs

Insurance companies could face tougher state rules in selling Medicare under a measure presented to the Senate committee Tuesday.

Sen. Norma Champion, R-Springfield, is sponsoring the bill.

The bill has two main objectives, Champion told the Small Business, Insurance and Industry Committee. While many insurance companies already refund any prepaid premiums upon cancellation, the bill would mandate such action for Medicare supplement policies and any long-term insurance policies. Seniors often want to pay their premiums ahead of time, Champion said.

Catherine Edwards of Area Agency on Aging testified that the bill was a matter of equity and fairness to Missouri seniors.

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Just in Case: How to Buy Disability Insurance - WSJ.com

By ANNA WILDE MATHEWS

Disability-insurance benefits from the workplace and the government are getting harder to come by—and that's putting more pressure on consumers to purchase their own coverage in case a medical condition keeps them from working.

But disability insurance can be confusing. Policies may include conditions that make it tough for people filing claims to actually qualify for the benefits. And some policies may limit payouts for certain diagnoses, particularly mental illness. To protect themselves, consumers considering buying disability coverage need to read the fine print.
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TIME GOES BY | Don't Trust What They Tell You

by Ronni Bennett AKA Crabby Old Lady

About a hundred years ago when Crabby Old Lady was a young woman – girl, actually, no more than a teenager – first living on her own, she overspent on her first credit card. The debt was so large that for the better part of a year, young Crabby lived on cottage cheese and crackers and gave up everything that was not essential until the bill was paid off.

Even though she told no one about her trouble, Crabby was deeply embarrassed at her stupidity. In fact, you are the first people who know of this.

That period was so painful, both financially and emotionally, Crabby swore never to allow it to happen again. Since then, she has used credit cards only as a convenience and except for a few emergencies through the years (when credit saved her ass), she has never owed more than she can pay in full each month. Her credit rating is so good that when she needed a short-term bridge loan three years ago to cover the time gap between purchasing a home here in Maine and the closing on her apartment in New York, the banker said, “You have an awesome credit score, Crabby.”

It doesn't take much these days to harm a credit rating, and it's not like Crabby has a rich family or a sugar daddy to call on when things go wrong or there is an emergency. So she guards that score closely. With it, she knows when there is need, as with the bridge loan, she can get the money easily and quickly.

When Crabby switched to a new Medicare Part D (prescription drug) provider in December, she elected to have the premium deducted from her Social Security benefit which is deposited electronically to her bank account each month. On Wednesday, when the January deposit was made, there was no deduction. Crabby Old Lady's personal financial alarm bell went ding, ding, ding.

When she explained her concern to the provider's customer service representative, she told Crabby that it would take up to four months (!) for Medicare and, separately, Social Security to approve the premium deduction. And meanwhile? Crabby asked. Would the provider, having received no payment, cancel her coverage and report nonpayment to the credit agencies?

To forestall that, the representative said, it would be necessary for Crabby to pay the insurance company herself until the deductions begin.

More alarm bells went off. In a flash, the following went through Crabby's mind:

* She was not told, when she enrolled in the Part D program, that she would be required to make the payments by check for several months.

* Because Crabby opted for the deduction, she did not receive premium coupons.

* She doesn't trust the provider to give her the correct mailing address for the premium payment and it could easily be routed to the wrong place. The provider might cancel her coverage for non-payment.

* Even with correct payment, it was likely, four months hence, that Social Security would deduct premiums for all of the four months.

* It would take months, if not years, of hassle to get either Social Security or the insurance company to return the double payments.

* Crabby's pristine credit score could be trashed.

When she expressed all this, the representative told her she works for a third-party service and could help Crabby no further. Crabby waited the standard 15 minutes after she was transferred to the insurance company.

New representative, same questions, different answers: It takes only two months for approval from Social Security and Medicare. No, she should not make payments herself. Her coverage “should” not be canceled during the wait for approval.
“Should” not be canceled? Is that certain? Crabby asked.

Probably reading from a script, the representative again said, “Your coverage should not be canceled.”

“Find me a supervisor,” said Crabby.

Standard 15-minute wait.

New representative, same questions, some different answers: It takes 90 days for approval from Social Security and Medicare. Do not make payments. Coverage will not be canceled and non-payment will not be reported to credit agencies.

Which of all these answers, Crabby wonders, is correct?

Taking Murphy's Law into consideration, Crabby made careful notes of these three conversations so she will have the (conflicting) information if trouble ensues. And there would be trouble for sure if Crabby had listened to the first representative and mailed payments - the first of which, this month, is already overdue and would be subject to a late fee.

You might think, as does Crabby, that this is an old story – screw ups from large companies that are liable to cost you money and if not that, certainly waste time. (In Crabby's case, she used up about an hour of her monthly cell phone minutes allotment.) But it becomes more serious when it concerns the health of old people.

Sometimes third-parties – spouses, adult children, friends, etc. - handle personal business matters for elders. Some elders have cognitive difficulties. Some may not have a firm grasp of English. In any of these circumstances, misunderstandings are bound to happen and undoubtedly some number of people lose coverage along with their prescriptions, incur additional costs or spend months sorting out problems only because the company is not clear about its policies.

All it would have taken to prevent confusion, Crabby's irritation and lost time was a short paragraph in the insurance provider's form letter of acceptance explaining the delay in the premium deduction and how it should be handled. That three representatives each had different answers is unacceptable. Isn't there a minimum standard of competence to be expected?

Certain members of Congress, teaparty members and assorted anti-government types have warned, during the debate on health care reform, that government-run health care would be rife with bureaucratic red tape. Crabby understands this is anecdotal evidence but in every dealing she has had with Medicare and Social Security representatives, the issues have been thoroughly and completely explained and nothing has ever gone wrong. The kind of minor mess Crabby experienced yesterday (and worse sometimes) is common with every private insurance provider she has dealt with.
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TIME GOES BY | The Health Care Reform Sell Out

by Ronni Bennett

The elderblogger giveth and she taketh away. No sooner had I posted what I believed - with reservations - is a compelling reason to be generally hopeful about the Senate health care reform bill than Senate Leader Harry Reid caved to the perennial flip-flopper, Senator Joe Lieberman of Connecticut who demanded removal of the Medicare buy-in for uninsured people age 55 to 64.

After leaving a meeting in Reid's office, Lieberman told reporters Monday evening:

“Harry said, ‘We will do what we can do to secure this.' “He said, ‘I have got some work to do with other members of the caucus.’ But he said, ‘My own feeling is we need you to get to 60 and so I am going to do my best.’”

I'm disgusted with them all, but am particularly incensed today at Senator Lieberman who has never had a political philosophy to call his own, only whatever will allow him to maintain his power along with the spotlight he so nakedly craves. Listen to him in an interview from September this year claiming credit for devising the Medicare buy-in idea:

What changed since then? Lieberman represents the third wealthiest state in the nation, measured by median income, which is also home to a large portion of the insurance industry. Who do we suppose got to Lieberman in the past three months??? As The New York Times notes:

”During his 2006 re-election campaign, Mr. Lieberman ranked second in the Senate in insurance industry contributions. Connecticut is a hub of the insurance business, with about 22,000 jobs specifically in health insurance, according to an industry trade group.”

To make Lieberman's reversal on the Medicare buy-in provision taste even worse, White House chief of staff, Rahm Emanuel, is said to have personally urged Reid to cut a deal with Lieberman and “get it done. Just get it done.” Later, a White House spokesperson denied the report although two sources confirm it.

Even good guy senators have caved.

"'How could I not vote for the bill?' [West Virginia Senator Jay] Rockefeller said. 'I have to consider who is looking to me for results and what can I give to them. This makes it easy for me to vote for it.'

“Sen. Paul Kirk, D-Mass., also seemed ready to accept the compromise. In the closed-door meeting, he called for everyone else to go along too, invoking the name of his predecessor, the late Sen. Edward Kennedy, and his desire to pass health care reform.”

This is not compromise, it is capitulation to the corporate forces that desperately want to maintain the health care status quo. The White House has been so weak on promoting reform that would make a real difference in the lives of citizens that it is apparent they just want a bill, any bill, by the end of the year and they will crow about reform whether it is or not.

Without a public option and without the Medicare buy-in, there will be, just like now, no choice but private coverage. And get this: No one knows who, but someone snuck a nasty little surprise into the Senate bill that hasn't got nearly the news coverage it should:

”As currently written, the Senate Democratic health care bill would permit insurance companies to place annual limits on the dollar value of medical care, as long as those limits are not 'unreasonable.' The bill does not define what level of limits would be allowable, delegating that task to administration officials.

“Adding to the puzzle, the new language was quietly tucked away in a clause in the bill still captioned 'No lifetime or annual limits'...

"'We don't know who put it in, or why it was put in,'" said Stephen Finan, a policy expert with the [American Cancer Society's] advocacy affiliate...

“Finan said the change in the Senate bill essentially invalidates the legislation's ban on lifetime limits. 'If you can have annual limits, saying there's no lifetime limits becomes meaningless,' he said. A patient battling aggressive disease in its later stages could conceivably exhaust insurance benefits in the course of a year.”

So now, without a public option or Medicare buy-in, there is no reason to believe insurance will be any less expensive under the reform package, patients will still face a cutoff of coverage in the middle of treatment for catastrophic illnesses and any American who refuses to buy corporate coverage will be fined by the IRS. I'm taking bets on how soon the clause eliminating pre-existing conditions as a reason to refuse coverage will be gone from the bill.

But, hey, that's okay. As President Bush pointed out, there is no health care problem in the United States; people can just go to emergency rooms.
TIME GOES BY | The Health Care Reform Sell Out

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Aging boomers face caregiver shortage - Personal Finance blog - Money Magazine's More Money

Image by Getty Images via Daylife

Posted by Lisa Gibbs

More or less buried in the massive debate over what our health care system should look like is a provision to create a national long-term care insurance program. The Community Living Assistance Services and Supports (CLASS) Act would allow people to pay an average $65 a month and, after five years, be eligible for between $50 to $100 a day in benefits. Insurers oppose the CLASS Act — clearly, it would cut into their sales of long-term care insurance, which haven’t been all that great to begin with. Other criticisms of the act: The government doesn’t need to be expanding programs even further than it already is, and low benefits would give people a false sense of security.

While $100 is better than nothing, I can tell you from experience that it doesn’t cover very much. It would pay for about six hours of daily care from the home aides I hired recently to help my mother recover from surgery. It certainly wouldn't cover assisted living or nursing homes, which run into the tens of thousands of dollars per year.

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Mods say no to CLASS act - Live Pulse - POLITICO.com

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from Politico Live Pulse

A group of moderate senators wrote to Harry Reid today asking him not to include the CLASS Act, which would create a long-term insurance program for the disabled, in the merged bill.

Sens. Conrad, Lieberman, Lincoln, Landrieu, Bayh, Warner and Ben Nelson wrote that they are concerned the provision would increase long-term deficits.

It's another example of moderate, Democratic fiscal hawks raising concerns about worthwhile, but budget busting proposals.

Cost Issues Surround Long Term Care Insurance, Nursing Homes - Kaiser Health News

As Congress considers a proposed long-term care insurance program as part of health overhaul plans, nursing homes costs are going up.

The Washington Post reports on the Community Living Services and Support (CLASS) Act, which would create a government insurance program for long-term care: "The idea has been around for years, and the late Sen. Edward M. Kennedy (D-Mass.) pushed to have the measure included in the health-care overhaul package that passed the Senate health committee in July. A similar measure was also adopted by voice vote in one of the three House committees handling health care. ... The idea is to create long-term care insurance that would be available to anyone, including those who are already disabled. People would be automatically enrolled, unless they chose to opt out, and would pay a premium in exchange for the opportunity to receive cash benefits to cover the cost of home care, adult day programs, assisted living or nursing homes after they had been enrolled for at least five years."
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Health Business Blog » US health care reform: Massachusetts or California style?

Image by Steve Rhodes via Flickr

by David E. Williams

In an excellent piece published today (Analysis: Can What Killed California Health Reform Strike Again?) Jordan Rau ponders the fate of federal health reform. The feds are following a similar model to what we have in Massachusetts: introducing employer and individual mandates along with subsidies and insurance regulation to achieve near universal coverage that’s somewhat affordable. As Rau points out, a year after Massachusetts enacted health reform California started down a similar path with leadership from Governor Schwarzenegger. However, California reform failed and Rau detects a number of similarities with the current debate at the federal level.

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AMNews: Sept. 28, 2009. Challenges to medical liability caps go before Georgia, Maryland high courts ... American Medical News

Doctors say the cases threaten to destabilize liability climates and highlight the need for tort reform to be part of federal health system reform.

High courts in Georgia and Maryland will decide the fate of caps on noneconomic damages in medical liability cases in each state, two of the latest attempts to undo such award limits.

The Georgia Supreme Court case stems from a February trial court decision rejecting the constitutionality of the state's $350,000 cap. Oral arguments began Sept. 15 in Atlanta Oculoplastic Surgery v. Nestlehutt.

Maryland's Court of Appeals is set to hear arguments Nov. 5 on whether the state's caps apply only to cases that are arbitrated.
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AMNews: Sept. 24, 2009, 2009. United, WellPoint accused of creating artificial grassroots lobbying efforts ... American Medical News

A California consumer group has asked the state's attorney general to investigate whether two health plans illegally encouraged employees to lobby on company time.

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Private Health Coverage Declined, Became Less Secure in 2008 — Center on Budget and Policy Priorities

The Census Bureau reported today that 46.3 million U.S. residents lacked health insurance in 2008, an increase of 632,000 over the previous year. [1] Nearly 6.6 million more people were uninsured in 2008 than in 2001, when the previous recession hit bottom. The proportion of the population without health insurance climbed to 15.4 percent in 2008, slightly above (but not statistically different from) the 15.3 percent rate in 2007 and considerably above the 14.1 percent figure in 2001.

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