HomeMy WebLinkAboutR-89-0043C
RESOLUTION 90 89-43
A RESOLUTION AUTHORIZING THE CITY MANAGER TO
EXECUTE AN AGREEMENT IN SUBSTANTIALLY THE
ATTACHED FORM WITH THE WYATT COMPANY TO
CONDUCT A PRELIMINARY ASSESSMENT OF THE
IMPACT OF THE TAX REFORM ACT OF 1986 ON THE
CITY'S GROUP BENEFITS PLAN FOR THE DEPARTMENT
OF PERSONNEL MANAGEMENT FOR A PERIOD OF THREE
(3) MONTHS AT A PROPOSED COST NOT TO EXCEED
$12,000; ALLOCATING FUNDS FROM THE DEPARTMENT
OF PERSONNEL MANAGEMENT'S TRUST AND AGENCY
BUDGET, SUBJECT TO THE AVAILABILITY OF FUNDS.
WHEREAS, the City requires the professional services of a #-
consultant to conduct a preliminary assessment of the impact of
the non-discrimination requirements of the Tax Reform Act of 1986 l'
on the City's life, medical, dental and prescription drug plans
for active employees; and
WHEREAS, the Consultant has expressed a desire to perform
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the required services; and i.
WHEREAS, the City Manager and the Assistant City Manager for
f
the Department of Personnel Management recommend that this three
(3) month agreement for consulting services to be provided by the
Wyatt Company, be approved; and
WHEREAS, funding is available in the Department of Personnel
Management's Trust and Agency operating budget to cover the cost !'-
i
of said agreement; �'
NOW, THEREFORE, BE IT RESOLVED BY THE COMMISSION OF THE CITY t':--
,4.
OF MIAMI, FLORIDA:
Section 1. The City Manager o
authorized to execute an agreement,
s' R
r designee is hereby
i
k
in substantially the
attached form with
the Wyatt Company to provide an
assessment of
the impact of the
Tax Reform Act of 1986 on the
City's Group
Benefits Plan for
active employees at a proposed
cost not to
_
exceed $12,000 with funds therefor being hereby allocated
from
the Department of
Personnel Management's Trust
and Agency
Operating Budget.
ATTACHMENTS
CONTAINED �
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� $�ltif1•i '`°fit' �1�l15"i is hA��atheti�d h;
e �: i ► trti t the Chief Ptccct$�cttt officer to iAsue a urcha a bl� i�
for this 'Set* of f11i1dika
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MASSED . Atb ADOPTED this 12th day' bf Jarivary
AVIER L. SUAREZ MAYOR
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ATTIS
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MATTY IRAI
CITY CLERK
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BUbGETARY REVIEW:
ANOE S. SURANA, DIRECTOR
DEPA ENT OF BUDGET
FINANCIAL REVIEW:
CARLO GARCIA, DIRECTOR
"k K r'i< rEr
DEPARTMENT OF .FINANCE PREPARED AND APPROVED BY: > '' 3 y L
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IF
R BERT F. CLARK
_
CHIEF DEPUTY CITY ATTORNEY
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APPROVED AS T FORM AND CORRECTNESS: aie 'rsf:
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This Agreement entered into this day of ,
1988, by and between the City of Miami, a municipal corporation
of the State of Florida, hereinafter referred to as "CITY", and
Wyatt Company, a Delaware for profit corporation, hereinafter
referred to as "CONSULTANT."
R E C I T A L:
WHEREAS, the CITY requires professional services to conduct
a preliminary assessment of the impact on the CITY'S welfare
plans for active employees of the non-discrimination requirements
imposed by -the Tax Reform Act of 1986; and
WHEREAS, the CONSULTANT has expressed a desire to perform
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the required dervices for the City;
NOW, THEREFORE, in consideration of the mutual covenants and
obligations herein contained, and subject to the terms and
conditions hereinafter stated, the parties understand and agree
as follows:
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TERM:
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_
The term of this Agreement shall be from the 13th day of
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October, 1988, through January 31, 1989.
SCOPE OF SERVICES:_
CONSULTANT shall perform a p preliminary appraisal of the non-
discrimination rules for the City's welfare plans for active
',
employees required by the Tax Reform Act of 1986. This
evaluation will be a point -in -time study, as of the data
collection date, which will allow time for advance planning to
either bring the City's plans into compliance or develop
administrative systems to handle any employee taxation
consequences. The plans included in this assessment are the
life, medical (HMO's included), dental, and prescription drugs.
Retirees will be excluded from the scope of this preliminary
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study.
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In the absence of definitive regulations, the appraisal will be
based on our best interpretation of the General Explanation of
the Tax Reform Act of 1987 ("Blue Book") prepared by the staff of
the Joint Committee on Taxation. As the CONSULTANT does not
practice law, the CITY will need to seek the advice of its
Counsel as to matters of legal interpretation.
CONSULTANT will assist the CITY in:
- Defining its highly compensated vs0 non -highly
compensated employee groups, and which employees could
ostensibly be excluded from discrimination tests.
Determining which non-discrimination tests (i.e.:
i
eL.igibility or benefits, or alternative tests) will be
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the most critical for the CITY-S plans. '±
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Identifying which plans are likely to pass non-
F_
discrimination testing and which may not, and why. �—
(1
Discussing potential options for dealing with non- f:
discrimination test probable outcomes. ;!
CONSULTANT will perform the tests on the data provided by
the CITY. CONSULTANT will meet with the appropriate CITY
representative'and assign a numeric code to each plan offered by #f
the CITY or any of its unions. Formal specifications will then
be prepared for the data required. While, CONSULTANT will
perform some basic edits to check the validity of the data,
CONSULTANT will not independently verify the accuracy of the data
and therefore any conclusions drawn will not be warranted by the
CONSULTANT.
CITY'S RESPONSIBILITIES
i -
Complete data must be provided by the CITY in the manner. y`
described below. CONSULTANT'S compensation includes an allowance-
for a minimal amount of data entry or cleanup.
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Along with the data, the CITY must provide a summary of the
total number of people on the tape and an approximate number of
people in each job classification, union, etc., as well as an
approximate number of people eligible for and participating in
each plan. These will enable the CONSULTANT to detect any
obvious errors in the data before proceeding.
The data should be provided on a magnetic tape conforming to
the following specifications:
9-track fixed length records
1600 BPI 50 records per block
ASCII (or EBCDIC) No packed decimal data
standard labels (or no labels)
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A single record should be provided for each employee. The
Social Security number must be provided for each employee and
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must be unique. All fields described below must be completed
with a valid entry for each employee.
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CONSULTANT will meet with the appropriate CITY
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representative and assign a numeric code to each plan offered by
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the CITY or any of the unions. CONSULTANT will then prepare
formal specifications for the data required.
The following type of data will be required for each
employee: Indicative data (name, social security number, birth
date, single or with dependents); Department or job class codes
to indicate the type of employee, bargaining unit, etc., as
appropriate; Hire date; Salary (projected annual salary and base
;-
salary for determining life insurance); Part time/full time code
and scheduled weekly hours; A code to indicate if the employee is
"highly compensated"; Information for each plan. Plan will be
,. +-
each indemnity medical option, HMO offered, dental, life,
prescription drugs, etc., for all employees including bargaining
units. Include the plan code, plan status (eligible but not
participating, participating ineligible, excluded due to age,
service or hours, etc.). If participating in a particular plan,.
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we also need information on any dependents covered and the cost
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of each plan to the employee.
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In addition to ettployee inforinationt CONSULTANT Vill requite
en r�arji piiat: desctiptiotle for each plan offered.
IT
COMPENSATION:
f A) CITY shall pay CONSULTANT, as maxittutn Campetisatic�it ; f6g
the services required pursuant to Paragraph II:
Preliminary Phase: $10500 - $ 20000
Collection of Data Phase $2,500 - $ 4,000
' Testing Phase $4,000 $ 6,000
Total $8,000 - $12,000
B) Such compensation shall be paid on the following basis:
1) CONSULTANT shall receive a fee not to exceed the
amounts stipulated above upon completion of each phase of the
project.
2) Upon approval of CITY'S Director of the Department
of Personnel Management (which approval shall not be unreasonably.,'
withheld).
C) If any correction is required or if a second tape must-
be provided, the CITY will amend this agreement in order t"o
incorporate the additional data work and compensation needed <, y
If • the CITY " is unable to provide good data ` and`
thereof . t:.
CONSULTANT is unable to complete the project, the CITY willbe
sy
billed for accrued charges, at our standard hourly rates, not to. '
exceed the compensation amount shown for the entire project. k
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COMPLIANCE WITH FEDERAL, STATE AND LOCAL LAWS:
Both parties shall comply with all applicable Laws
ordinances and codes of federal, state and local governments•
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&SNRRAL CONDITIONS:
A) All notices or other communications which shall or may
be given pursuant to this Agreement shall be in writing and shall
be delivered by personal service, or by registered mail addressed
to the other party at the address indicated herein or as the same
may be changed from time to time. Such notice shall be deemed
given on the day on which personally served; or, if by mail, on
the fifth day after being posted or the date of actual receipt,
whichever is earlier.
CITY OF MIAMI
Angela R. Bellamy,
Assistant City Manager
City of Miami
Dept. of Personnel Management
1147 N.W. 11th Street, Rm. 103
Miami, FL' 33136
CONSULTANT
Aruna Vohra, Benefits
Consultant, Wyatt Company
Suite 210
10689 N. Kendall Drive
Miami, FL 33176
B) Title and paragraph headings are for convenient
reference and are not a part of this Agreement.
C) In the event of conflict between the terms of this
Agreement and any terms or conditions contained in any attached
f�
documents, the terms in this Agreement shall rule.
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D) No waiver or breach of any provision of this Agreement
ft
shall constitute a waiver of any subsequent breach of the same or
any other provision hereof, and no waiver shall be effective Al.
unless made in writing.
E) Should any provisions, paragraphs, sentences, words or
-
phrases contained in this Agreement be determined by a court of
competent jurisdiction to be invalid, illegal or otherwise
unenforceable under the laws of the State of Florida or the City t>-
of Miami, such provisions, paragraphs, sentences, words or _-
phrases shall be deemed modified to the extent necessary in order
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to conform with such laws, or if not modifiable to conform with
1
such laws, then same shall be deemed severable, and in either—
event, the remaining terms
_
and provisions of this�Agreement shall
remain unmodified and in full force and effect._
5 A'
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.. V
6iii�8�SHiP Oi� DOCU1#BNTS:
All documents developed by C0NSULTANT under this Agreement
shall be delivered to CITY by said CONSULTANT upon completion of
the services required pursuant to paragraph II hereof and shall
become the property of CITY, without restriction or limitation on
its use. CONSULTANT agrees that all documents maintained and
generated pursuant to this contractual relationship between CITY
and CONSULTANT shall be subject to all provisions of the Public
Records Law, Chapter 119, Florida Statutes.
It is further understood by and between the parties that any
information, writings, maps, contract documents, reports or any
other matter whatsoever which is given by CITY to CONSULTANT
pursuant to thfs Agreement shall at all times remain the property
of CITY and shall not be used by CONSULTANT for anv other
purposes whatsoever without the written consent of CITY. —
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NONDSLSGABILITY:
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That the obligations undertaken by CONSULTANT pursuant to
this Agreement shall not be delegated or assigned to any other
person or firm unless CITY shall first consent in writing to the
performance or-assignment'of such service or any part thereof by }j
another person or firm.,
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IZ.
AUDIT RIGHTS:
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CITY reserves the right to audit the records of CONSULTANT
pertaining to the work and payments related to this project at
any time during the performance of this Agreement and f-ora 't
period of one year after final payment is made under this r'
Agreement. .:
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ANARD OP AGRERMINT:
CONSULTANT warrants that it has not employed or retained any
person employed by the CITY to solicit or secure this Agreement
and that it has not offered to pay, paid, or agreed to pay any
person employed by the CITY any fee, commission percentage,
brokerage fee, or gift of any kind contingent upon or resulting
from the award of this Agreement.'
XI.
CONSTRUCTION OF AGREENENT:
This Agreement shall be construed and enforced according to
the laws of the State of Florida.
L
XII.
SUCCESSORS AND ASSIGNS:'
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This Agreement shall be binding upon the parties herein,
their 'heirs, executors, legal representatives, successors, and
assigns.
INDENNIFICATION: +
This Agreement is' for the provision.: of professional
services. CONSULTANT covenants and agrees that the services }
i
hereunder will be provided in a professional manner and that each
of its employees who performs work pursuant to this Agreement is
qualified to perform the work assigned to such employee. If the.
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CITY reasonably determines that the services are defective or
unsatisfactory in any material respect, CONSULTANT shall re- x
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perform such defective service at no additional cost to the CITY..
In no event shall CONSULTANT be.liable for any indirect3, speciA,-. N
or consequential damages.
Wix
XIV.
CONFLICT OF INTEREST:
A) CONSULTANT covenants that no person under its employ who
presently exercises any functions or responsibilities in
connection with this Agreement has any personal financial
interests, direct or indirect, with CITY. CONSULTANT further
covenants that, in the performance of this Agreement, no person
having such conflicting interest shall be employed. Any such
interests on the part of CONSULTANT or its employees, must be
disclosed in writing to CITY.
B) CONSULTANT is aware of the conflict of interest laws of
the City of`Miami (City of Miami Code Chapter 2, Article V), Dade
County Florida (Dade County Code Section 2-11.1) and the State of
Florida, and agrees that it shall fully comply in all respects
with the terms of said laws.
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INDEPENDENT CONTRACTOR:
CONSULTANT and its employees and agents shall be deemed to
be independent contractors, and not agents or employees of CITY, ;t1
and shall not attain any rights or benefits under the Civil
Service or Pension Ordinances of CITY, or any rights generally{_
afforded classified or unclassified employees; further he/she
. �s-
shall not be deemed entitled to the Florida Workers' Compensation f
benefits as an employee of CITY.
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XVI.
TERKINATION OF CONTRACT:
i
t CITY retains the right to terminate this Agreement:.at any,
time prior to the completion of the services required pursuant to
paragraph II hereof without penalty to CITY. In that event10
notice of termination of this Agreement shall be in writing :to �
;a
CONSULTANT, who shall be paid for those services performed priorF
to the date of its receipt of the notice of termination. In no 3F
a 4
case, however, will CITY pay CONSULTANT an amount in excess of Y.
the total sum provided by this Agreement.
It is hereby understood by and between CITY and CONSULTANT
that any payment rude in accordance with this Section to
CONSULTANT shall be made only if said CONSULTANT is not in }r
default under the terms of this Agreement. If CONSULTANT 1.a In' `
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default, then CITY shall in no way be obligated and shall not`.ody �!
if
to CONSULTANT any sum whatsoever. -
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XVII. f�
NONDISCRIMINATION:
- CONSULTANT agrees that it shall not discriminate as to race,
sex, color, creed, national origin, or handicap in connection $,
with its performance under this Agreement. '!
Furthermore, that no otherwise qualified individual shall,{:
solely by reason of his/her race, sex, color, creed, national
origin, or handicap, be excluded from the participation in, bed
denied benefits of, or be subjected to discrimination under anyAf
program or activity receiving federal financial assistance.
dap#yt.
XVIII.
MINORITY PROCUREMENT COMPLIANCE:
CONSULTANT acknowledges that it has been furnished a copy of
r
Ordinance No. 10062, the Minority Procurement Ordinance of the
City of Miami, and agrees to comply with all applicable
substantive and procedural provisions therein, including any
amendments thereto.—
X1X. V
CONTINGENCY CLAUSE:
Funding for this Agreement is contingent on the availability€
1
of funds and continued authorization for program activities and
is subject to amendment or termination due to lack of funds, or �—
authorization, reduction of funds, and/or change in regulations. f_'
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VfjBB$B �f ALKOy5 the patties hereto have caused th a
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to he executed 'by the respective officials theteutit{o
t., duly authorized* this the days and year first above
ATTEST:
MATTY HIRAI
City Clerk
CITY OF MIAMIi
Corporation of
Florida:
written*
a municipal
the State
By•
CESAR H. ODIO
City Manager
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ATTEST: CONSULTANT: 'ray
Cor orati4fn Secretary Group Benefits Consult tle
Walter W. Bardamierper Seal)
Assistant Secretary
_+ WITNESS:
(As to Consultant)
(NOTE: If CONSULTANT is not
a Corporation, two
N witnesses must sign.)
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APPROVED AS TO INSURANCE APPROVED, AS TO.FORM'-AND
REQUIREMENTS: CORRECTNESS:
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Insurance Ta er J.0 GE F Z
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City or MIAMI. FLORIDA
INTER -OFFICE MEMORANDUM
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Honorable Mayor and Hembern DATE: September 23, 1988
of the City Commission
SUsJECT: Recommendation for
Agreement Execution
(lion -Discrimination
sting)
-
FROM.
REFERENCESe
Cesar H. Odic
City Manager ENCLOSURE91
.77
It is respectfully recommended that the City Commission authorize
the execution of an agreement in substantially the attached form
with the Wyatt Company to provide consulting servicesto the
Department of Personnel Management relative to an assessment of
the impact orr the Tax Reform Act of 1986 on the City of 'Miami'''s
d cost oP .
rtroup:Benefits Plan for active employees. The propose
this study is not to exceed $12,000. Funding is -Available in the
Department of Personnel Hanagement's Truat and Agency budget.
BACKGROUND
The Tax Reform Act` of 1986 added Section 89 to the Internal
Revenue Code. Basic objedtives.of this government initiative-aro. ,
�. to. -as re that certain tax favored benefits are 'made available. to
i a broader cross-section of employees and/or to eliminate the "tax
breaks" or "revenue losses" assoctated with such benefits.'
Section 89, sets forth strict non-discrimination rules effective
January 1, 1989, which intend to provide consistent and uniform
treatment of health and welfare plan benefits including; �
1. Group Term Life Insurance
2 . Accident and Health Benefits
3. Section 125 Cafeteria Plans
4. (croup Legal Plans :. � � �� 4��
�i 5., Educational Assistance Programs; f5
6. Tuition Reduction Programsws
*
7. Dependent Care Plans
Fringe Benefit Plana k'
# 9. Section 505 Welfare Benefit Trusts,'{
+ In an. effort to ascertain a preliminary' assessment of °:the Amp.
oF:.the: non-discrimination requiromenta of thee Tax r-�teF:orrtljy Aot4 Q *
1986 .;.on the City:' a group benefits plans, -the �assistanab
Wyatt Company,. is required. The ' Wyatt Company
exten.s,tve tests in order to determine where benefit
discrimination exists and to orVer compliance auggestiuns in this �u
i t'�)rm of arlmLnistrative syaterots to handle any axat�
i uonsequeneea.a�
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CITY OF MIAMI. FLORID
INTER -OFFICE MEMORANDUM
To: Honorable Mayor and Members
of the City Commission
FROM . Cesar H. Odio -
City'.Hanager
Office of the City Manager
DATE: December 27, 1988 ME:
SUBJECT: Section 89 Benefits
Testing Alternatives
REFERENCES: Item 59 of 11— 3- 8 8
ENCLOSURES : Commission Meeting
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dry;
At the November 3, 1988 Commission Meeting, Item 59, requesting
authorization to hire the Wyatt Company to perform Section 89
benefits testing, was deferred pending further research. In
following with the Commission's instructions to seek alternative
means. of, performing the non-discrimination benefits testing L for
Section 89-of the federal tax code, the Department of. Personnel
N
Management contacted the individuals/organizations specified;by`,;
thee:Commiasion. Those contacted were: Washington, DC Lobbyist?*
Hra Mark Israel who,.in turn, called the United_States.Couference 'f+�
of Mayors and the . National League of ..Cities; the , American .Bar
Association; the .Florida League of Cities and the: law. offices of �k
Holland and Knight. In addition, Sharpton and,: Brunson aad
Company, a local accounting firm was contacted.
The,' responses provided by the individuals or organizations -
contacted fall into two categories: 1) the:.
individual/organization could not or .would not perform.the.work w,z
or:',that. 2)L the organization would need to subcontract thg
testing and analysis components of Section 89 to either an
employee benefits consultant or large, accounting_ firm with in-L.r
house benefits specialists. (See attached report for specific
�,.. responses provided by the contacts referenced above.) In'
i' addition to the subcontractingissue it is our understandin °
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that the contract(s). currently in effect: with theL organi.z.atio.nsy
V: we spoke with would not cover the testing services in question,.;
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Recommendations`
i Due to the technical expertise required in performing the
1 nondiscrimination ,benefits taste .1t is recommended that tho C�k, *Y�z
contract directly with a benefits -consultant. ,..This .al1ow um,'r;ifi
to directly supervise, the:5
p project ,:.and - will 1.keep they
involved: in this project at a �ce$sogable .pmQuAt. ThepfoA'�;
E item ,. wiXl . � b,e ; .placed 4n , . ibe, .,:January. 12, 1989 age>ada ft!I� r -
reconsideration.
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CITY OF MIAMI, FLORIDA
INTER -OFFICE MEMORANDUM
TO: Cesar H. Odio DATE: December 27, 1988 Fu:
City Manager
SUBJECT: Background Inforetation '.
for Cover Memo of
December 27, 1988
FROM : Ange *Rsellamy REFERENCES : Item 59 of 11-3-88
Assistant City Ma ger Commission Meeting
ENCLOSURES:
At the November 3, 1988 Commission Meeting, Item 59,, requesting
authorization to hire the Wyatt Company to perform Section 89
benefits testing, was deferred pending further research..' In
following with the Commission's instructions to seek alternative }
means of performing the non-discrimination benefits testing for
Section 89 of the federal tax code, the Department of .,Personnel r'
fF i
Management contacted the individuals/organizations specified `bq a 2
the Commission. The individual responses of those contacted are.,` -'
included in this memorandum. • In general, the responses'_,we
either, that 1) .the individual/organization could not, or would,.no�. k
Per.f.orm.the ,work or that 2)-the organization.; would. subcontract_ _
the testing component. of Section 89 to either an employee,
c T4}t
benefits consultant or large accounting- firm with. .in-house
benefits specialists. x 1
The individuals or organizations contacted. were:, Washington, ,DC
Lobbyists, Mr. Mark Israel; the American Bar Association;, the
Florida League of Cities and the. law offices. of Holland. -and
Knight. In addition, Sharpton and Brunson and Company, a local ;a
accounting firm was contacted. zr
C-1) Mr. Bark Israel: Mr.. Israel explained his role with :the ri*4
City, as one which represents. the City ,at the federal.1-vel'to '
include providing research/informational services on legislation, `
ry
regulations, policies, etc. Mr, Israel; also intimated that v.pte; Y
the contract with the City his firm does. not perform technical,+ar,v.,
legal work.aL
qt! the City's behalf, Mr. Israel contacted the United Statas
Conference of Mayors and the National League of Cities to
aid_-, grpup;s, perform; .the _non-di$crimination> benefi.s. tsr#.,� r; z
A_gor.ding ,, to Mr. Is,rael's discussions with both o"rgaqizstic�
neither group. -provides the services..,
2 tionan "erlc.Dar, Association, rx €;
t � ., ..��.� .. $poke ���� �x;�. ,�•���►� ���
VA, :oa-; of; the ;Taxation Section' as well as an aaxyst gtaF 4tir:
Retirement Association of the ABA regarding the City'e nae
tebtin$ services., Both individuals coafirued" 1:1149 .the d+'S ti
no, ,t provide this form of. technical
i t
(5) Sharpton and Brunson and Coupan': Spoke with Mr Darryl
Sharpton, managing partner of the firm, regarding the firms
ability to provide the professional services associated +with
Section 89 benefits testing. An.initial response,.similar. to .that
of Holland, and Kni,ght's was given. "Xes, we can perform this
se." However. a$ was the case with Holland and Knight, ,vice
issue of ,subcontracting was mentioned where
consultant would .Tact in ctetwe.en Can advisory capacity for techai.a8���
A#xspiewing+:the current contr.,.a..bhe G"wad ;ity h4
y
and .::Rrunaon, :fit appears that servi-cea ara= lixic�d
V-nrio:us :auditing ;functiaus .pprt4ilm. -1 a;.gxant to ►st itsy ;�l 9
ro�.enus audits .attd raviewu Q se�,eated "dspa,ttapcfla t4 _, $+P hs
rvc$s: o Otis fc�f,s
deOir. t0 arse t�1$ ss z �l M s,
i-.�d•
�.}gr,r$%
�`.k . �:_ i - _ .. a ..., c.'_.. ..Eat-, •I�.{tS-.n". TrY 7i, iu�u4T-.+_ar:.t! 4">1'M519b,
FiT, �7
L11,11; L E4,
There are two 'points in the testing phase where ,legalCO- Sul-daA
may be required.
g, where the plans ha*i'
1) Just- prior to testing, I le4iO
which require A
analyzed and questions may arise w
opinion.
.�
2) once the testing is completed we; would want..a
opinion on the assumptiono made or gray, areas identi
by the consultant.
Qutli-f ications
"Within the 114,44,lifications standards port P,
re.cent a r employers ticlop now indicate that an 6M SO
the -writtei.,' plan- oco 0, 1
Y.
S comply with
Pocutient D may not c 4 41
stands, . r4. Speculation has -it that only an ERI.S,.A-
document will be approved, It is still au'y6ng' 8 940
ant will be acceptable in .� the sbssnco,�
document
document'
u'��j prevail
r4guXatiovis 0ld' pl* the tRI-SA'
in drafting said -document.:.
cod legal assistance
4tscu gibuo with 09�-i Plq 'At hove bee
LOW Do' PA rtmen t A, tjij90 R"
whets -the n, 4 for l 0'$
xi
Vate