HomeMy WebLinkAboutMINUTES - 10012013 - SD.1RECOMMENDATION(S):
ACCEPT that this Board Order serves as written acknowledgment by the County Administrator (chief executive
officer) that he understands the current and future cost of health benefit changes for the Deputy Sheriffs' Association
and certain persons retired from classifications represented by the Association, as determined by the County's actuary
in the September 4, 2013 Actuarial Report (Attached).
FISCAL IMPACT:
As shown in the valuation, the result of the health plan changes described herein, if implemented, will create a $21.0
million or 2.04% decrease in the Actuarial Accrued Liability and a $1.9 million or 2.70% decrease in the calculated
Annual Required Contribution.
BACKGROUND:
At its meeting on September 10, the Board of Supervisors accepted an actuarial valuation of future annual costs of
negotiated and proposed changes to Other Post Employment Benefits, as provided by Buck Consultants in a letter
dated September 4, 2013. The Board of Supervisors was informed that Government Code, Section 7507 requires
with regard to local legislative boards, that the future costs of changes in retirement benefits or other post
employment benefits as determined by the actuary, shall be made public at a public meeting at least two weeks prior
to the adoption of any changes in public retirement plan benefits or other post employment benefits. The September
4, 2013 report from Buck Consultants fulfilled that requirement.
Government Code, Section 7507 also requires that if the future costs (or savings) of the changes exceed
APPROVE OTHER
RECOMMENDATION OF CNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE
Action of Board On: 10/01/2013 APPROVED AS RECOMMENDED OTHER
Clerks Notes:
VOTE OF SUPERVISORS
AYE:John Gioia, District I Supervisor
Candace Andersen, District II Supervisor
Mary N. Piepho, District III Supervisor
Karen Mitchoff, District IV Supervisor
ABSENT:Federal D. Glover, District V
Supervisor
Contact: Lisa Driscoll, County Finance
Director, 335-1023
I hereby certify that this is a true and correct copy of an action taken and entered on the
minutes of the Board of Supervisors on the date shown.
ATTESTED: October 1, 2013
David Twa, County Administrator and Clerk of the Board of Supervisors
By: Chris Heck, Deputy
cc: Ted Cwiek, Human Resources Director
SD.1
To:Board of Supervisors
From:David Twa, County Administrator
Date:October 1, 2013
Contra
Costa
County
Subject:Government Code 7507 - Chief Executive Acknowledgement of Future Costs of Benefits - Deputy Sheriffs'
Association
BACKGROUND: (CONT'D)
one-half of 1 percent of the future annual costs of the existing benefits for the body, an actuary shall be present to
provide information as needed at the public meeting at which the adoption of a benefit change shall be considered.
And finally, Section 7507 requires that upon the adoption of any benefit change to which the section applies, the
person with responsibilities of a chief executive officer in an entity providing the benefit, however that person is
denominated, shall acknowledge in writing that he or she understands the current and future cost of the benefit as
determined by the actuary.
As the County Administrator (chief executive officer) and by approving this Board Order, I acknowledge in
writing that I understand the current and future cost of the benefit changes presented to you today, as determined
by the actuary and contained in the September 4, 2013 letter from Buck Consultants (County's actuary).
CONSEQUENCE OF NEGATIVE ACTION:
Delayed implementation of health care rate revisions.
CHILDREN'S IMPACT STATEMENT:
None.
CLERK'S ADDENDUM
Speaker: Rollie Katz, Public Employees' Union Local One, commented on the proposed changes.
ATTACHMENTS
September 4, 2013 - Actuarial Report (7507)
September 4, 2013
Ms. Lisa Driscoll
County Finance Director
Contra Costa County Administrator’s Office
651 Pine Street, 10th Floor
Martinez, CA 94553
RE: Complying with California Government Code Section 7507 Regarding
Changes to the Postretirement Medical Plan Effective as of 1/1/2014
Dear Ms. Driscoll:
This letter documents the estimated changes in future annual costs including
actuarial accrued liability, normal cost, and future cash flows based on changes to
be effective as early as January 1, 2014 for the Contra Costa County Deputy
Sheriffs’ Association (DSA) to the postretirement medical plan. Throughout this
document “medical” refers to both health and dental costs.
The baseline results used for the actuarial comparison of the current plan that
presented herein reflect the County’s GASB 45 liability as presented in a prior 7507
report dated June 20, 2012, prepared by the prior Buck actuary, reflecting the
Contra Costa County California Nurses Association changes as of November, 1,
2012. The June 20, 2012 report was the most recently updated valuation for the
County’s postretirement medical plan. It was developed using census data as of
January 1, 2012, and reflected the Contra Costa County CNA changes as of July 1,
2012.
The impact of the changes for the DSA to be effective January 1, 2014, has been
estimated using more refined calculation methodologies than were used in overall
baseline results in order to better capture the change in future employer subsidy
amounts. In addition, the Annual Required Contribution is presented using an
updated amortization basis, as discussed below.
General Description of the Contra Costa County DSA Postretirement Medical
Benefits Prior to Currently Negotiated Benefit Changes
For Employees Represented by the Contra Costa County DSA:
County contributions for 2011 were based on an 87%/13% split of the Kaiser
Bay Area Pre-Medicare retiree rates. In 2012, inflation in these rates was split
80% County/20% retiree and prior to the change measured in this calculation,
and for 2013 the inflation was split 75% County/25% retiree, with that same 75%
County/25% retiree split intended to continue for future years.
Ms. Lisa Driscoll
September 4, 2013
Page 2
Baseline Valuation Results Before Plan Changes
Table 1 summarizes the Actuarial Accrued Liability (AAL) as of January 1, 2012, as
calculated for all participants under the current benefit schedule. The AAL is
defined as the actuarial present value of benefits attributed to employee service
rendered up to a particular date.
The table also shows the Normal Cost (NC), which is the amount of benefit to be
earned by the active employees for service in calendar year 2012.
Table 1
CCC Postemployment Health Benefits Plan
Actuarial Accrued Liability and Normal Cost as of January 1, 2012
GASB Statement 45 requires the calculation of an Annual Required Contribution
(ARC) consisting of the Normal Cost and a not greater than 30 year amortization of
the Unfunded Actuarial Accrued Liability (UAAL). The UAAL is the Actuarial
Accrued Liability (AAL) less any assets held for the plan.
Table 2 on the following page shows the calculated ARC for the fiscal year ending in
2012 under the current health benefit plan using the 6.32% discount rate
assumption, and updated amortization basis.
Before Plan Changes
Actuarial Accrued Liability
at a 6.32%
Discount Rate
Normal Cost
at a 6.32%
Discount Rate
Active Employees $432,153,000 $27,209,000
Retirees 594,915,000 0
Total $1,027,068,000 $27,209,000
Ms. Lisa Driscoll
September 4, 2013
Page 3
Table 2
CCC Postemployment Health Benefits Plan
Annual Required Contribution for Fiscal Year Ending 2012
Before Plan Changes
Total AAL $1,027,068,000
Assets* 65,491,000
UAAL $961,577,000
Annual Required Contribution
Normal Cost $27,209,000
30 Year Amortization of UAAL 43,342,000
ARC $70,551,000
* Assets as of 1/1/2012
The baseline amounts above reflect the liability associated with the subsidization of
retiree premiums by active employees as required by GASB 45. This subsidization
occurs in the Contra Costa County sponsored medical benefits because the under
age 65 medical costs for retirees are much higher than for active employees at the
same ages, but the retiree premium rates are the same as the active rates due to
pooling of the costs in the underwriting process. According to the baseline
calculations from the prior 7507 report dated June 20, 2012, approximately $111
million of the liability is caused by this rate subsidy, or 10.8% of the total liability
under the 6.32% discount rate assumption.
The calculation does not reflect any subsidization for retirees who participate in the
CalPERS health care program, where we have determined that that the CalPERS
would offer the same premium rate if only the Contra Costa County non-Medicare-
eligible retirees were covered under the CalPERS arrangement. The calculation
also does not reflect any subsidization for dental premium costs which do not vary
significantly by age.
Table 3 below shows the updated ARC for the fiscal year ending in 2012 under the
new health benefit provisions to begin as early as January 1, 2014, for employees
represented by the Contra Costa County DSA using the same 6.32% discount rate
assumption and updated amortization basis.
Here is a brief summary of the Contra Costa County DSA changes:
Retired Employees
• Premium Cost Sharing. Effective January 1, 2014, the County will pay a
monthly premium subsidy for each health plan that is equal to the actual
dollar monthly premium subsidy that is paid by the County as of November
30, 2013. In addition, if there is an increase in the monthly premium charged
Ms. Lisa Driscoll
September 4, 2013
Page 4
by a particular health plan for 2014 and for each year thereafter, the County
and the employee will each pay fifty percent of the monthly premium
increase that is above the previous year’s plan premium.
• Delta, and PMI Delta Care. Beginning on January 1, 2014, the County will
pay a monthly dental premium subsidy for each dental plan that is equal to
the actual dollar monthly premium subsidy that is paid by the County for
2013. If there is an increase in the premium charged by a dental plan for
2014, the County and the employee will pay fifty percent (50%) of the
increase. For each calendar year thereafter, the County and the employee
will each pay fifty percent (50%) of the premium increase that is above the
2013 plan premium.
• Dental Only. Beginning on January 1, 2014, the County will pay a monthly
dental premium subsidy for each dental plan that is equal to the actual dollar
monthly premium subsidy that is paid by the County for 2013. If there is an
increase in the premium charged by a dental plan for 2014, the County and
the employee will pay fifty percent (50%) of the increase. For each calendar
year thereafter, the County and the employee will each pay fifty percent
(50%) of the premium increase that is above the 2013 plan premium.
Table 3
CCC Postemployment Health Benefits Plan
Annual Required Contribution for Fiscal Year Ending 2012
After Plan Changes
Total AAL $1,006,096,000
Assets* 65,491,000
UAAL $940,605,000
Annual Required Contribution
Normal Cost $26,251,000
30 Year Amortization of UAAL 42,396,000
ARC $68,647,000
* Assets as of 1/1/2012
The plan changes for the Contra Costa County DSA created a $20,972,000 or
2.04% decrease in the Actuarial Accrued Liability (AAL), and a $1,904,000 or 2.70%
decrease in the calculated ARC using amortization based on 4.0% payroll growth.
Future valuation results will change with demographic and cost updates, but these
changes to the most recent valuation as of January 1, 2012, do accurately measure
the magnitude and direction of the plan change costs.
In undiscounted cash flow terms there will be changes in cash costs for the County
as early as the January 1, 2014, calendar year for the postretirement medical plan
based on these plan changes. The first 2-year total cash differential from the plan
change beginning in calendar 2014 is about a $931,000 increase, while the 25-year
Ms. Lisa Driscoll
September 4, 2013
Page 5
total cash differential beginning in calendar 2014 is about a $40,150,000 decrease.
These are estimates based on current plan participation and are subject to change
upon open enrollment as the plan changes may affect future retiree plan selections.
The proposed arrangement results in initial cash cost increases since for some
options, 50% of the expected initial trend increase for the current premium amount
is actually greater than 75% of the expected premium increase on the Kaiser Bay
Area option. Over time, compounding results in the employer share will be reduced
by the 50% cost share. But in the short run, especially for options currently elected
by non-Medicare retirees, the 50% cost share will result in a slightly higher employer
cost.
Basis of Calculation
This analysis includes all actives and retirees of County entities included in the
County’s CAFR and utilizing Contra Costa County (CCC) health benefits. All results
rely on census and health plan data provided by the County. A listing of 7,720
active employees with an average age of 46.1 years and average service of 10.8
years was used for this study. A separate file containing 5,941 retirees and
survivors was provided for this study as well. Of these individuals, DSA participants
included in this analysis represented 759 active employees with an average age of
38.9 years and average service of 8.9 years, and 601 retirees and survivors. The
DSA measured in this calculation included individuals identified in bargaining units
V#, VH, and VN, as well as individuals with CalPERS benefits in bargaining units F8
and FW. It does not include other bargaining units that currently have the same
benefits structure as DSA.
Appendix A provides the assumptions used for this actuarial analysis. Unless
otherwise noted, these assumptions were developed by the prior Buck actuary. The
undersigned actuaries are relying upon the work of the prior Buck actuary in stating
that the assumptions are reasonable for the purpose of measurement of the
County’s GASB 45 costs. Other sets of assumptions may be equally reasonable for
this measurement, and could produce significantly different results.
The assumptions include demographic items such as expected turnover rates,
retirement rates, future trend rates, and mortality rates. The rates that we used are
consistent with those used by CCCERA in its pension actuarial valuations. A
discount rate of 6.32% is used throughout this analysis. This rate was developed
based on the County’s decision to partially prefund the plan to a dedicated
irrevocable trust. Under GASB 45, the discount rate for partially funded plans
reflects the proportionate amount of plan and employer assets expected to be used
to pay benefits. We have not reviewed the discount rate in light of any potential
difference in proportions that may result from the change in DSA benefits measured
in this analysis.
All valuation results reflect the use of the Entry Age Normal (EAN) actuarial cost
method. The entry age normal actuarial cost method also matches the cost method
used by CCCERA for the pension valuation. For the postretirement medical
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APPENDIX A
Valuation Assumptions
Mortality Rates — RP-2000 Combined Healthy Mortality Tables, projected forward
with Scale AA to 2019 and 2027 for currently retired and currently active
participants, respectively.
Withdrawal Rates — Representative values are shown below
Year
General
Withdrawals per
1,000 Lives for
employees with less
than 5 years of
Service
Safety
Withdrawals per
1,000 Lives for
employees with less
than 5 years of
Service
1 140.00 110.00
2 90.00 70.00
3 80.00 50.00
4 60.00 40.00
5 50.00 30.00
General
Withdrawals per
1,000 Lives for
employees with more
than 5 years of
Service
Safety
Withdrawals per
1,000 Lives for
employees with more
than 5 years of
Service
Age
30 50.00 30.00
35 49.20 22.00
40 42.30 16.10
45 35.40 10.50
50 16.80 0.00
55 3.70 0.00
60 0.00 0.00
New Entrants — None Assumed.
Dependent Assumptions — For active employees, 80% of males and 55% of
females are assumed married at retirement. Female spouses are assumed to be
three (3) years younger than their husbands.
Discount Rate — 6.32%.
Amortization — Level percentage of pay with an overall projected payroll increase
of 4.00%, on an open 30 year basis.
Participation Assumption — 98% active participation assumed upon retirement.
APPENDIX A (Continued)
Valuation Assumptions
Retirement Rates
Probability of retiring at age 70 equals 100% for both General and Safety.
Marital Characteristics — Retirees: actual data. Active Employees: Wives are
three years younger than their husbands. 80% of males and 55% of females are
assumed married at retirement.
Health Care Cost and Expense Trend — Annual trend rates are shown below.
Medical Trend Rates
by Calendar Year
CY12 10%
CY13 9%
CY14 8%
CY15 7%
CY16 6%
CY17+ 5%
All calculations are based on these assumed trend rates. While premium rates for
2013 and 2014 are available, the assumed trend rates are used throughout the
calculation for consistency.
Probability of Eligible
Retirements During the Year
Age General Safety
50 3.0% 25.0%
51 3.0% 20.0%
52 3.0% 20.0%
53 3.0% 20.0%
54 5.0% 25.0%
55 10.0% 30.0%
56 10.0% 30.0%
57 10.0% 40.0%
58 10.0% 40.0%
59 10.0% 40.0%
60 15.0% 100.0%
61 20.0% 100.0%
62 25.0% 100.0%
63 25.0% 100.0%
64 30.0% 100.0%
65 35.0% 100.0%
66 35.0% 100.0%
67 35.0% 100.0%
68 35.0% 100.0%
69 35.0% 100.0%
APPENDIX A (Continued)
Valuation Assumptions
Contra Costa County 2012 Rates and Contributions
The following Premium Rates and Increases vary by bargaining unit. For illustrative
purposes the following R-1A rates for 2012 cover over 75% of the current retiree
population.
Total Monthly
Premium
County Monthly
Premium
Early Retirees (under 65)
Kaiser EE $673.87 $478.91
EF $1,570.11 $1,115.84
Health Net HMO EE $894.87 $627.79
EF $2,195.19 $1,540.02
Health Net PPO EE $1,109.51 $604.60
EF $2,635.73 $1,436.25
CCHP - A
EE $586.13 $509.92
EF $1,396.49 $1,214.90
CCHP – B EE $649.74 $528.50
EF $1,543.89 $1,255.79
Retirees (over65)
Kaiser Cost EE $678.32 $626.37
Retiree EF $1,542.28 $1,397.80
Kaiser Senior EE $261.96 $261.95
Advantage EE+1 $707.46 $707.45
Health Net Cost EE $515.78 $467.13
Retiree EF $1031.56 $934.29
Health Net EE $468.83 $409.69
Seniority Plus EE+1 $937.66 $819.38
CCHP – A EE $489.73 $420.27
Retiree EE+1 $1,203.69 $1,035.60
CCHP – B EE $553.34 $444.63
Retiree EE+1 $1,351.09 $1,088.06
APPENDIX A (Continued)
Valuation Assumptions
CalPERS Participating Retirees:
For those retirees participating in CalPERS such as DSA retirees, the County
contribution had been based on a percentage of the Bay Area Kaiser non-Medicare
rates; the 2012 rates are shown below.
Non-Medicare
Single - $610.44
Employee +1 Dependent - $1,220.88
Employee + Family - $1,587.14
Medicare
Medicare Retiree Only - $277.81
Medicare Retiree & 1 Medicare Dependent - $555.62
Medicare Retiree & 2 Medicare Dependents - $833.43
Medicare Retiree & 1 Basic Dependent - $888.25
Medicare Retiree & 2+ Basic - $1,254.51
Medicare Retiree & Dependent & Basic Dependent - $921.88
Basic Retiree & 1 Medicare Dependent - $888.25
Basic Retiree & 2 Medicare Dependents - $1,166.06
Basic Retiree & 1 Dependent & 1 Medicare Dependent - $1,254.51
In measuring the impact of the changes outlined in this report, costs for non-
Medicare coverage were based on current medical benefit option and total premium
amount reported for each employee and retiree. For current Medicare retirees as
identified by their tier, we reflect the medical the cost for their current medical benefit
option. For other individuals, the premiums for Medicare coverage is based on a
percentage reduction off of the level of the non-Medicare coverage that is based on
the average cost by tier (Medicare Retiree Only vs. Medicare Retiree and
Dependent) for participants who currently have the 75%/25% inflation cost sharing
provision, the bulk of whom are represented by the DSA .
APPENDIX B
Glossary of Terms
Actuarial Accrued Liability (AAL) – The actuarial present value of benefits attributed to
employee service rendered to a particular date.
Active Plan Participant – Any active employee who has rendered service during the credited
service period and is expected to receive benefits, including benefits to or for any
beneficiaries and covered dependents, under the postretirement benefit plan.
Actuarial Present Value – The value, as of a specified date, of a future benefit cost or a
series of benefit costs, with each amount adjusted to reflect (a) the time value of money
(through discounts for interest and (b) the probability of payment (for example, by means of
decrements for events such as death, disability, withdrawal or retirement) between the
specified date and the expected date of payment.
Amortization – Systematic reduction of the principal portion (only) of an asset or liability.
Annual Required Contribution – Consists of the normal cost and a portion of the total
unfunded actuarial accrued liability (UAAL). The normal cost and UAAL are derived from
the actuarial present value of benefits, the actuarial cost method and the plan assets.
Attribution Period – The period of an employee’s service to which the expected
postretirement benefit obligation for that employee is assigned.
Discount Rate – The interest rate used in developing present values to reflect the time value
of money.
Health Care Cost Trend Rate – An assumption about the annual rate(s) of change in the
cost of health care benefits currently provided by the postretirement benefit plan, due to
factors other than changes in the composition of the plan population by age and
dependency status, for each year from the measurement date until the end of the period in
which benefits are expected to be paid. The Health Care Cost Trend Rate implicitly
considers estimates of health care inflation, changes in health care utilization or delivery
patterns, technological advances, and changes in the health status of plan participants.
Differing types of service, such as hospital care and dental care, may have different trends.
Normal Cost – The portion of the Actuarial Present Value of Future Benefits attributed to
employee service during a period.
Substantive Plan – The terms of a postretirement benefit plan as understood by an
employer that provides postretirement benefits and the employees who render services in
exchange for those benefits. The substantive plan is the basis for the accounting for that
exchange transaction. In some situations an employer’s cost-sharing policy, as evidenced
by past practice or by communication of intended changes to a plan’s cost-sharing
provisions, or a past practice of regular increases in certain monetary benefits may indicate
that the substantive plan differs from the extant written plan.
APPENDIX C
Summary of Plan Provisions
1. Plans Available
The following medical providers are currently available to General employees: Kaiser,
Health Net, and the Contra Costa Health Plan. These plans are all available to both
Medicare and Non-Medicare eligible retirees in varying forms. The majority of Safety
employees are covered under various CalPERS health plans. All retirees have dental
options provided through the County.
2. Covered Groups
All current active employees other than new tiers as established through bargaining
are eligible for subsidized coverage, as are retirees currently receiving pension
benefits. Employees hired after January 1, 2011 in many of the bargaining groups
are eligible to participate in the medical plans only if they pay the entire stated
premium. A retiree must be receiving pension benefits to receive health benefits.
3. Eligibility for Retirement (individuals hired prior to January 1, 2013)1
General employees can retire once they satisfy any of the following requirements: 50
years old with 10 years of service, 70 years old, or 30 years of service.
Safety employees can retire once they satisfy any of the following requirements: 50
years old with 10 years of service, 70 years old, or 20 years of service.
4. Dependents
Participating retirees may cover dependents at the rates given in Appendix A.
Surviving dependents of deceased retirees may continue County provided coverage
(medical or dental) if they pay the full stated premium. Surviving dependents of
participants in CalPERS plans may continue employer subsidized premium for health
coverage.
5. Significant Contribution Provisions
For Unrepresented County Employees, In Home Supportive Services, and First Five
as well as Employees Represented by AFSCME Local 512, AFSCME Local 2700,
Public Employees Union Local One, SEIU Local 1021 and Western Council of
Engineers, Professional & Technical Engineers Association (AFL-CIO) Local 21,
Public Defender s’ Association, Probation Peace Officers Association, and Deputy
District Attorneys’ Association:
County Premium Subsidy – Non-CalPERS plans:
o January 1, 2012, and forward – the County’s monthly subsidy will be fixed
at the 2011 dollar amount
1 The Califormia Public Employees’ Pension Reform Act of 2013 (PEPRA), generally raises
retirement eligibility to age 52 for non-safety employees hired after January 1, 2013.
APPENDIX C (Continued)
Summary of Plan Provisions
For Employees Represented by the Deputy Sheriff's Association
District:
County contributions for 2011 were based on an 87%/13% split of the
Kaiser Bay Area Pre-Medicare retiree rates; in 2012, inflation in these rates
was split 80% County/20% retiree and prior to the change measured in this
calculation, for 2013, the inflation was split 75% County/25% employee and
under the bargaining agreement in place before the change discussed in
this letter, future inflation was to be split 75% County/25% employee.
For Employees Represented by the Physician's and Dentist's Association,
United Chief Officers Association, United Professional Firefighters, IAFF, and
Local 1230:
County contributions for the particular benefits offered to the bargaining groups
noted are assumed to increase with trend as in the governing Memoranda of
Understanding.
For Employees Represented by the Contra Costa UCOA:
As of July 1, 2012, employer/retiree contribution split is 80% employer/20%
retirees—based on Kaiser Bay Area rate, with subsequent medical inflation
also to be split 80% employer/20% retiree.
For Employees Represented by the Contra Costa District Attorney Investigators’
Association (DAIA):
Effective September 1, 2012, the County will contribute up to an amount,
equivalent to 87% of the 2011 CalPERS Kaiser Bay Area premium plus 80%
of the increases premium amount for Kaiser Bay Area premium for 2012 at
each level (retiree only, retiree + one, retiree + two or more) toward the
covered retiree’s CalPERS or CalPERS Alternative Plan (CCHP) premium
plus:
Effective January 1, 2013, the County and the DAIA will divide any increase in
the Kaiser Bay area premium 75% employer/25% employee.
For Employees Represented by the Contra Costa County California Nurses
Association (CNA):
Employees Active as of July 1, 2012:
o Medicare. Persons who become age 65 on or after July 1, 2012, and
who are eligible for Medicare must enroll in Medicare Parts A and
B. Effective July 1, 2012, there will be no County subsidy for
Medicare Part B.
APPENDIX C (Continued)
Summary of Plan Provisions
Retirees Retired as of July 1, 2012:
o Medicare. Persons who become age 65 on or after November 1,
2012, and who are eligible for Medicare must enroll in Medicare Parts
A and B. Effective November 1, 2012, there will be no County
subsidy for Medicare Part B.