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United States General Accounting Office: 
GAO: 

Report to the Honorable Don Nickles, U.S. Senate 

April 2002: 

Retired Coal Miners' Health Benefit Funds: 

Financial Challenges Continue: 

GAO-02-243: 

Contents: 

Letter: 

Results in Brief: 

Background: 

Along Some Dimensions, the Funds' Benefits Are More Generous than 
Those Offered by Major Manufacturers or Companies with Unionized Labor 
Forces: 

The Funds' Beneficiaries Have Higher Health Care Costs than Comparable 
Beneficiaries: 

The Funds' Trustees Have Implemented a Number of Cost Control 
Initiatives: 

Concluding Observations: 

Comments from the UMWA Health and Retirement Funds and Our Evaluation: 

Related GAO Products: 

Tables: 

Table 1: Selected Features of the Funds' Health Plans Compared with 
Health Plans Offered to Salaried Workers and Retirees in Manufacturing 
Companies and Plans Offered to Unionized Hourly Workers and Retirees: 

Table 2: Comparison of the Funds' Outpatient Prescription Drug Benefit 
with Benefits Offered by Selected Retiree Health Plans in 
Manufacturing Companies, 2000: 

Figures: 

Figure 1: Health Care Expenditures for the Funds' Medicare-Eligible 
Beneficiaries and Comparable Medicare Beneficiaries with Employer-
Sponsored Health Insurance, 1999: 

Abbreviations: 

AML: Abandoned Mine Reclamation fund: 

BCOA: Bituminous Coal Operators Association: 

CBF: Combined Benefit Fund: 

CMS: Centers for Medicare and Medicaid Services: 

HCFA: Health Care Financing Administration: 

PBM: pharmacy benefits manager: 

SNF: skilled nursing facility: 

SSA: Social Security Administration: 

UMWA: United Mine Workers of America: 

UMWAF: United Mine Workers of America Health and Retirement Funds: 

[End of section] 

United States General Accounting Office: 
Washington, DC 20548: 

April 18, 2002: 

The Honorable Don Nickles: 
United States Senate: 

Dear Senator Nickles: 

In 1992, certain retired coal miners and their spouses and dependents—
more than 100,000 individuals in all—faced a potential decrease in 
their employment-related health insurance coverage or loss of such 
coverage altogether. Some former employers had stopped mining coal or 
gone out of business, so they were no longer contributing to the 
United Mine Workers of America (UMWA) retiree benefit funds. To ensure 
that these individuals would continue to receive the health benefits 
specified in previous collective bargaining agreements reached with 
coal companies, often gained in exchange for lower pensions, the 
Congress enacted the Coal Industry Retiree Health Benefit Act of 1992 
(Coal Act).[Footnote 1] The Coal Act replaced the existing UMWA 
retiree health benefit funds with the Combined Benefit Fund (CBF) and 
the 1992 Benefit Plan—collectively referred to in this report as the 
Funds.[Footnote 2] The act specified how each fund would be financed 
by the coal miners' former employers and other sources to cover the 
health care costs not paid for by Medicare. In 2001, there were about 
55,000 beneficiaries in the CBF and about 6,000 in the 1992 Benefit 
Plan. The health plans are administered by the United Mine Workers of 
America Health and Retirement Funds (UMWAF). 

Since 1997, the CBF has incurred annual operating deficits. Although 
the Congress has made special appropriations to keep the CBF solvent, 
these actions have not addressed the CBF's long-term financial 
challenges.[Footnote 3] Health care spending has risen faster than 
contributions to the CBF, and financial difficulties have been 
compounded by court decisions that have reduced the per beneficiary 
premium paid by the coal miners' former employers and relieved some 
companies of the responsibility for paying premiums for certain 
beneficiaries.[Footnote 4] Consequently, actuarial projections 
indicate that annual revenue shortfalls are expected to continue. 

In contrast to the CBF, the 1992 Benefit Plan has not incurred ongoing 
deficits. The 1992 Benefit Plan has a different financing structure 
and premiums paid by coal companies are adjusted each year to meet the 
expected health care costs of covered beneficiaries. From 1997 through 
2002, these premiums rose by 47 percent to keep pace with increases in 
per capita health care spending.[Footnote 5] 

To help the Congress consider long-term solutions to the Funds' 
financial challenges, you asked us to examine (1) how the Funds' 
health benefits compare to benefits offered by other retiree plans, 
(2) how the health care costs of the Funds' beneficiaries compare to 
the costs of other retiree groups, and (3) the efforts of the Funds' 
officials to control costs.[Footnote 6] To conduct our study, we 
compared the benefit packages the Funds offered in 1999 to the benefit 
packages certain major manufacturing companies offered and those 
offered to a sample of unionized hourly workers.[Footnote 7] Because 
89 percent of the Funds' beneficiaries are eligible for Medicare, we 
compared the health care costs for these individuals to the health 
care costs of other, demographically similar Medicare beneficiaries 
covered by employer-sponsored insurance. We also interviewed the 
Funds' managers and their contractors, officials from the Health Care 
Financing Administration (HCFA),[Footnote 8] and coal company 
representatives about the financing and operations of the Funds. We 
performed our work from October 2000 through March 2002 in accordance 
with generally accepted government auditing standards. 

Results in Brief: 

The Funds' health care benefits package requires relatively less cost 
sharing by beneficiaries and provides more extensive coverage of some 
services than benefit packages offered by the major manufacturing 
companies and companies with unionized workforces that we examined, 
but overall, the extent of coverage is generally comparable. For 
hospital care and physician services, which comprise the majority of 
health care spending, the Funds' coverage is similar to that offered 
by the majority of manufacturing companies and to other unionized 
hourly workers. However, unlike many retirees in the comparison 
companies, the Funds' beneficiaries do not pay premiums for their 
health care coverage and beneficiaries' annual out-of-pocket expenses 
for covered services are capped at $150 per family. In contrast, the 
typical unionized hourly worker is liable for $1,750 for covered 
services. The Funds' beneficiaries receive somewhat more comprehensive 
coverage for skilled nursing facility (SNF) care than other retirees 
from manufacturing companies. The Funds require a relatively low 
copayment of $5 for each covered prescription and cap this required 
cost sharing at $50 per year, although beneficiaries may be liable for 
additional amounts if they use brand name drugs instead of generic 
equivalents or use brand name drugs not on a list specified by the 
Funds. In contrast, beneficiaries in a sample of manufacturing 
companies we contacted are responsible for $1,000 or more in 
prescription drug costs. 

The cost of health care for the Funds' beneficiaries in 1999 was about 
29 percent higher ($2,163 per person) than for demographically similar 
Medicare beneficiaries with employer-sponsored insurance.
Approximately 62 percent of this difference ($1,345) reflects higher 
spending on Medicare-covered services, while the remaining 38 percent 
($818) reflects higher spending on benefits not covered by Medicare, 
such as outpatient prescription drug coverage. However, the Funds' 
beneficiaries may also use more services because of their relatively 
poor health. Compared to demographically similar retirees, the Funds' 
beneficiaries report poorer health status and thus their greater use 
of hospital care, physician services, and SNF care may, in part, 
reflect greater needs. 

The Funds' trustees believe the beneficiaries of the CBF and the 1992 
Benefit Plan are entitled to the level of benefits established through 
prior bargaining agreements and consequently, their numerous cost 
containment initiatives have focused on the efficient management of 
health care services and on obtaining lower prices from their health 
care providers. The Funds' officials said they have attempted to 
control costs largely through approaches that do not reduce or limit 
the benefits for beneficiaries, do not increase beneficiary cost 
sharing requirements, or that have a minimal impact on beneficiaries. 
For example, the Funds' officials initiated case and disease 
management programs, implemented claims review procedures designed to 
avoid payment of inappropriate claims, hired a pharmacy benefits 
manager (PBM) to help control their outpatient prescription drug 
costs, solicited competitive bids to obtain better prices for durable 
medical equipment, and negotiated for their providers to accept 
Medicare rates as payment in full for all the Funds' beneficiaries. 

In comments on a draft of this report, the Funds' officials stressed 
that in comparing their plans and beneficiaries with other plans and 
populations, it is important to have a full appreciation of the 
history behind the 1992 Coal Act and the tradeoffs coal miners made to 
secure their health benefits. The Funds' officials also noted that 
they have implemented a wide range of managed care and cost 
containment initiatives and have realized substantial savings for the 
Funds and for Medicare and the U.S. Treasury. 

Background: 

The Coal Act established beneficiary eligibility requirements, a 
standard for covered benefits, and separate boards of trustees to 
oversee the CBF and the 1992 Benefit Plan. For both funds, the act 
requires coal companies to pay premiums for beneficiaries and their 
dependents, but the annual premium amount, the method for adjusting 
the premium each year, and other financing arrangements are quite 
different for each fund. Since the Funds were established in 1993, 
coal companies have challenged several provisions of the law. Court 
decisions in favor of former employers have reduced the premium 
contributions paid by the companies to the CBF. Although the CBF's 
financing was originally expected to be adequate, the CBF has incurred 
an annual operating deficit in each year since 1997, prompting 
Congress to make special appropriations in 1999 and 2000 to maintain 
its solvency. In contrast, the 1992 Benefit Plan has had an annual 
operating deficit in only one year (2000) since its inception. 
[Footnote 9] 

The Funds' Beneficiaries: 

The Coal Act limited coverage under the Funds to retired coal miners, 
their spouses and dependents who were eligible for benefits under 
former UMWA retiree benefit plans. There were approximately 115,000 
beneficiaries in 1993. The number of beneficiaries has declined each 
year as individuals died and dependent minors reached 22 years of age 
and no longer qualified for coverage (the current population is 
declining by approximately 9 percent per year). In 2001, the Funds 
provided health benefits to about 61,000 beneficiaries. Approximately 
70 percent of beneficiaries are female and the median age is over 78. 
Most of the Funds' beneficiaries are eligible for Medicare (89 
percent) and others are from 55 to 64 years of age and nearing 
eligibility (7 percent). 

Most of the Funds' beneficiaries (62 percent) live in rural or 
nonmetropolitan urban areas. More than three quarters of the 	
beneficiaries live in five states: West Virginia (32 percent), 
Pennsylvania (19 percent), Kentucky (12 percent), Virginia (8 
percent), and Ohio (6 percent). In 2000, the median income of the 
Funds' beneficiaries ($17,100) was similar to the median income of all 
Medicare beneficiaries ($18,000). 

Health Care Benefits: 

The Coal Act specified that "to the maximum extent feasible," the 
Funds' coverage be "substantially the same as" the coverage provided 
under the UMWA retiree health plans they replaced, provided that 
premium income is sufficient to cover payment rates to providers. 
[Footnote 10] Thus, the Funds' benefit packages reflect the outcome of 
prior agreements between UMWA and coal companies. The benefits include 
coverage for inpatient and outpatient hospital care, physician 
services, prescription drugs, home health services, SNF care, mental 
health care, and durable medical equipment such as ventilators and 
wheelchairs. 

All of the Funds' beneficiaries receive the same package of benefits 
regardless of their entitlement status (retiree, spouse, or dependent) 
or their eligibility for Medicare. For Medicare-eligible 
beneficiaries, the Funds pay Medicare's required cost sharing 
(coinsurance, copayments, and deductibles) in addition to the cost of 
services included in the Funds' benefit packages but not covered by 
Medicare, such as outpatient prescription drugs. Except for required 
copayments, the Funds pay the entire cost of covered services provided 
to beneficiaries who are not eligible for Medicare. 

Operations and Financing: 

There are separate boards of trustees for the CBF and for the 1992 
Benefit Plan. The Coal Act stipulates that the CBF board consist of 
one individual designated by the Bituminous Coal Operators Association 
(BCOA) to represent employers in the coal mining industry, one 
individual jointly designated by the three employers with the greatest 
number of assigned beneficiaries, two individuals designated by UMWA, 
and three persons selected by the other board members.[Footnote 11] 
UMWA and BCOA each appoint two members to the board of the 1992 
Benefit Plan. Some individuals serve as trustees for both the CBF and 
the 1992 Benefit Plan. 

The Coal Act established the Funds' initial and ongoing financing 
structures. Both funds receive annual revenues from coal company 
premiums and Medicare payments.[Footnote 12] However, the CBF also 
received an initial transfer of assets from the 1950 UMWA Pension 
Plan,[Footnote 13] and has received some of the accumulated interest 
from the Abandoned Mine Reclamation fund (AML) since 1996.[Footnote 
14] Together, these revenues pay for health care expenses and the 
associated administrative costs of the health plans, which include the 
cost of third-party contracts for claims processing and utilization 
review, general overhead, and legal representation in lawsuits brought 
by and against the Funds.[Footnote 15] 

Company Premiums: 

The Coal Act requires certain coal and other companies to pay premiums 
on behalf of beneficiaries who are covered by the 1992 Benefit Plan or 
the CBF.[Footnote 16] However, the 1992 Benefit Plan and the CBF 
differ in how the annual premium amount is determined and the extent 
to which coal companies are responsible for beneficiaries. For the 
1992 Benefit Plan, the Coal Act allows the premiums to be adjusted 
annually to cover changes in the cost of providing benefits. The 
trustees have historically set the premiums so that revenues will meet 
projected annual expenditures. Thus, premium adjustments reflect 
changes in medical prices or beneficiaries' use of medical services. 
For 2002, the annual premium was about $4,437, or about 38 percent 
higher than the CBF annual premium. 

The Coal Act assigns financial responsibility for paying premiums to 
each eligible retiree's most recent coal industry employer.[Footnote 
17] If an employer has gone out of business, or the premium cannot 
otherwise be collected, the cost of affected 1992 Benefit Plan 
beneficiaries is shared by other coal companies that were signatories 
to a prior agreement between the industry and UMWA and that have 
either current or potentially eligible beneficiaries under the 1992 
Benefit Plan. 

For the CBF, the Coal Act specifies a method for determining the 
premium to be paid by a company for each of its retirees and eligible 
dependents, and how the premium is updated. The premium is based on 
the cost of providing benefits under the UMWA's retiree health plan 
during the period between July 1, 1991 through June 30, 1992. It is 
increased each year by the percentage change in general medical prices 
as measured by the medical component of the consumer price index. In 
2002, the annual premium was about $2,725. 

The Social Security Administration (SSA) was charged with determining 
which company is financially responsible for each CBF beneficiary. In 
some cases, SSA was not able to assign a beneficiary to a responsible 
company. This occurred, for example, when a beneficiary's former 
employer had gone out of business. In 2001, about 71 percent of CBF 
beneficiaries were assigned to companies that were responsible for 
paying premiums on their behalf. The CBF did not receive premium 
payments from coal companies or their successors for the 29 percent of 
beneficiaries who were unassigned. 

Transfers of Accumulated Interest from the AML: 

The Coal Act allows for transfers of accumulated interest from the 
AML, a federal fund financed by levies on coal extraction, to cover 
the projected costs of the CBF's unassigned beneficiaries. Since 1996, 
transfers of interest from the AML to the CBF have helped to pay for 
costs associated with assigned beneficiaries. In 1999 and 2000, 
Congress made special appropriations to keep the CBF solvent. The AML 
moneys have not been used to support the 1992 Benefit Plan. 

Medicare Payments: 

The Funds are participants in a Medicare demonstration project that 
places them at financial risk for the cost of Medicare-covered 
services delivered to eligible beneficiaries. The extent of the Funds' 
financial risk varies by type of service. The Funds assume partial 
risk for the cost of Medicare's part A benefits that include coverage 
for inpatient hospital services and skilled nursing facility care. 
Annual spending for these services is compared to an expenditure 
target. If spending was less than the targeted amount, the difference 
is shared between the Funds and Medicare according to a predetermined 
formula. The same formula specifies how the cost of any spending in 
excess of the targeted amount is to be shared. The Funds assume full 
financial risk for the cost of Medicare-covered part B benefit that 
cover physician, hospital outpatient, and certain other services. 
Medicare pays the Funds a fixed monthly payment per beneficiary, known 
as a capitation payment, that is projected to cover the cost of these 
services.[Footnote 18] If the Funds' spending on these services for 
eligible beneficiaries is less than Medicare's capitation payments, 
the Funds may retain the difference. However, the Funds are 
financially responsible for any spending in excess of Medicare's 
capitation payments. 

In recent years, the Funds spent less on Medicare-covered services 
than the combined total of the annual expenditure target and 
capitation payments from Medicare. In 1999, for example, this 
difference amounted to approximately $16 million, of which $4.4 
million was retained by the Funds and $11.6 million was retained by 
Medicare. The Funds can use these retained moneys to help pay for 
services and items not covered by Medicare, such as outpatient 
prescription drugs. 

On July 1, 2001, the Centers for Medicare and Medicaid Services (CMS) 
renewed the demonstration project for an additional 3 years. At the 
same time, CMS agreed to include a new component in the demonstration 
project that will provide the Funds with additional revenue to help 
cover the cost of outpatient prescription drugs. Under the terms of 
the new demonstration component, Medicare will pay the Funds an amount 
equal to 27 percent of their expenditures on outpatient prescription 
drugs for Medicare-eligible beneficiaries. CMS estimates that the new 
demonstration component will result in an additional $135 million in 
Medicare payments to the Funds during the 3-year period. 

Impact of Legal Challenges: 

Court decisions in several lawsuits brought by coal companies have 
reduced the premium revenues available to the CBF and contributed to 
the financing challenge it faces.[Footnote 19] The cost of legal 
representation has also increased the CBF's annual administrative 
costs. Since 1992, companies have filed over 50 lawsuits challenging 
specific aspects of the Coal Act's implementation. One lawsuit 
challenged SSA's calculation of the initial premium rate. As a result 
of the court decision in that case, premiums charged to companies were 
reduced by approximately 10 percent.[Footnote 20] In other lawsuits, 
companies have challenged some of SSA's beneficiary assignment 
decisions. The effect of one Supreme Court decision was to reduce 
companies' financial responsibilities thereby increasing the number of 
unassigned beneficiaries.[Footnote 21] Another case changed the status 
of several thousand beneficiaries from assigned to unassigned. 
[Footnote 22] The CBF will receive no further premiums from coal 
companies for all living beneficiaries who are now unassigned as a 
result of these cases, and transfers from the AML will have to 
increase to cover the health care costs of these additional unassigned 
beneficiaries. Furthermore, the CBF will need to refund the premiums 
it previously collected on behalf of any affected beneficiaries. 

Discrepancy between Cost and Revenue Growth: 

The rise in health care expenditures during the 1990s, which prompted 
many private employers to reduce the health insurance benefits they 
provided to their employees or to require larger contributions from 
beneficiaries, also affected the expenditures of the Funds. From 1994 
through 2000 the per capita cost of the CBF's beneficiaries rose by 53 
percent, an average annual increase of 7.3 percent, and the per capita 
costs of the 1992 Benefit Plan beneficiaries, who tend to be younger 
than CBF beneficiaries, increased by 28 percent, an average annual 
increase of 4.2 percent. Part of the rise in cost was due to higher 
medical prices.	 

However, overall increases in the use of medical services and 
increases in the use of outpatient prescription drugs and other 
expensive services also pushed up per beneficiary costs. Although 
Medicare per capita costs rose by 26 percent during this period, in 
part due to rising utilization, the trend may have been magnified in 
the CBF because it serves a closed, and therefore aging, population. 
Per capita costs would be expected to grow faster among CBF 
beneficiaries relative to Medicare beneficiaries because older 
individuals tend to use more medical services than younger individuals 
and because the cost of outpatient prescription drugs, which are not 
covered by Medicare, have risen faster than other components of health 
care spending during this period. 

Unlike premiums in the 1992 Benefit Plan, CBF premiums have not kept 
pace with increases in the cost of services not covered by Medicare. 
The CBF premium update adjustment specified in the Coal Act only 
reflects changes in medical prices, which rose at an average annual 
rate of 3.6 percent from 1994 to 2000 while per capita spending 
increased at twice that rate. To date, Medicare payments have been 
sufficient to cover the cost of providing Medicare-covered services in 
both the CBF and the 1992 Benefit Plan because annual updates to 
Medicare's payments reflect underlying changes in both prices and use 
of services. Similarly, AML funding for the non-Medicare costs of the 
CBF's unassigned beneficiaries is based on projected costs and takes 
into account expected changes in both utilization and prices. 

Along Some Dimensions, the Funds' Benefits Are More Generous than 
Those Offered by Major Manufacturers or Companies with Unionized Labor 
Forces: 

In four areas—premium contributions, annual deductible, the cap on 
beneficiary out-of-pocket expenses, and coverage for SNF care—the 
Funds' benefits are more generous than those benefits typically 
offered to retirees and workers by major manufacturing companies or to 
unionized hourly workforces in other companies.[Footnote 23] In 
addition, most aspects of the Funds' outpatient prescription drug 
coverage are more generous than the coverage provided by other benefit 
plans. However, many features of the Funds' health plans are similar 
to those offered in the comparison plans. In particular, the Funds' 
coverage for hospital and physician services, which account for the 
majority of health care spending, is comparable to the coverage 
provided by the other plans. (Table 1 compares selected benefits of 
the Funds' plans with those in plans offered to workers in 
manufacturing companies and to unionized hourly workers.) Eligibility 
requirements for retiree health plan coverage by the Funds are similar 
to those of other manufacturing employers. The Funds' beneficiaries 
can qualify for retiree health benefits at age 62 with 5 years of 
service, or at age 55 with 10 years of service.[Footnote 24] Most 
retiree plans require a similar combination of minimum age and years 
of service to qualify for retiree health benefits.[Footnote 25] 

Table 1: Selected Features of the Funds' Health Plans Compared with 
Health Plans Offered to Salaried Workers and Retirees in Manufacturing 
Companies and Plans Offered to Unionized Hourly Workers and Retirees: 

Retirees age 65 and older: 

Plan feature: Retiree premium contribution: No contribution required; 
Feature included in the CBF and the 1992 Benefit Plan: [Check]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 8; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 39. 

Plan feature: Retiree premium contribution: Contribution required, 
amount varies by pay, service, age, or other factor; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 10; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 19. 

Plan feature: Retiree premium contribution: Fixed contribution 
required; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 82; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 42. 

Retiree premium contribution: Total; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 100; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 100. 

Plan feature: Employer subsidy of premium: Subsidized, no defined 
limit; 
Feature included in the CBF and the 1992 Benefit Plan: [Check]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 51; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 65. 

Plan feature: Employer subsidy of premium: Subsidized, defined limit; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 41; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 31. 

Plan feature: Employer subsidy of premium: No subsidy
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 8; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 4. 

Employer subsidy of premium: Total; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 100; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 100. 

Retirees less than 65 years old: 

Plan feature: Retiree premium contribution: No contribution required; 
Feature included in the CBF and the 1992 Benefit Plan: [Check]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 4; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 30. 

Plan feature: Retiree premium contribution: Contribution required, 
amount varies by pay, service, age, or other factor; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 10; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 20. 

Plan feature: Retiree premium contribution: Fixed contribution 
required; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 86; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 50. 

Retiree premium contribution: Total; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 100; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 100. 

Plan feature: Employer subsidy of premium: Subsidized, no defined 
limit; 
Feature included in the CBF and the 1992 Benefit Plan: [Check]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 54; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 51. 

Plan feature: Employer subsidy of premium: Subsidized, defined limit; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 38; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 41. 

Plan feature: Employer subsidy of premium: No subsidy
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 8; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 8. 

Employer subsidy of premium: Total; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 100; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 100. 

Beneficiaries who have not retired: 

Plan feature: Deductible: No deductible; 
Feature included in the CBF and the 1992 Benefit Plan: [Check]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 48; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 59. 

Plan feature: Deductible: Deductible; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 52; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 41. 

Deductible: Total; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 100; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 100. 

Plan feature: Cap on employee out-of-pocket expenditures[A]: Included; 
Feature included in the CBF and the 1992 Benefit Plan: [Check]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): NA; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 73. 

Plan feature: Cap on employee out-of-pocket expenditures[A]: Not 
included; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): NA; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 5. 

Plan feature: Cap on employee out-of-pocket expenditures[A]: Not 
needed; plan pays 100 percent; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): NA; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 22. 

Cap on employee out-of-pocket expenditures[A]: Total; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): NA; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 100. 

Plan feature: Hospital room and board coverages: 100 percent of 
reasonable and customary charges, no limit on days; 
Feature included in the CBF and the 1992 Benefit Plan: [Check]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 39; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 52. 

Plan feature: Hospital room and board coverages: 100 percent of 
reasonable and customary charges, with limitations on days; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 3; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 9. 

Plan feature: Hospital room and board coverages: Less than 100 percent 
of reasonable and customary charges; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 39; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 59. 

Hospital room and board coverages: Total; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 100[B]; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 100. 

Plan feature: Hospital copayment or separate deductibles: No copayment 
or separate deductible; 
Feature included in the CBF and the 1992 Benefit Plan: [Check]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 86; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 88. 

Plan feature: Hospital copayment or separate deductibles: Separate per 
admission copayment/deductible; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 11; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 11. 

Plan feature: Hospital copayment or separate deductibles: Separate per 
day copayment/deductible; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 2; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 1. 

Plan feature: Hospital copayment or separate deductibles: Other
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 1; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): [Empty]. 

Hospital copayment or separate deductibles: Total; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 100; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 100. 

Plan feature: Surgical coverages: 100 percent of reasonable and 
customary charges; 
Feature included in the CBF and the 1992 Benefit Plan: [Check]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 39; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 57. 

Plan feature: Surgical coverages: Less than 100 percent; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 61; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 43. 

Surgical coverages: Total; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 100; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 100. 

Plan feature: Physician office visit coverage[A]: 100 percent coverage 
with no copayment; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 5; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 8. 

Plan feature: Physician office visit coverage[A]: 100 percent coverage 
with copayment; 
Feature included in the CBF and the 1992 Benefit Plan: [Check]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 52; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 55. 

Plan feature: Physician office visit coverage[A]: Less than 100 
percent coverage; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 43; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 37. 

Physician office visit coverage[A]: Total; 
Feature included in the CBF and the 1992 Benefit Plan: [Empty]; 
Percentage of plans offered to salaried	workers and retirees in	
manufacturing companies with feature (n=513): 100; 
Percentage of plans offered to unionized hourly workers and retirees 
with feature (n=126): 100. 

NA: Data not available. 

[A] Information based on beneficiaries seeking care from a provider 
participating in the plan. 

[B] Percentages do not add to 100 due to rounding. 

Source: UMWA Combined Benefit Fund Plan Document (www.umwafunds.org, 
downloaded on December 12, 2001), UMWA 1992 Benefit Plan Plan Document 
(www.umwafunds.org, downloaded on December 12, 2001), Hewitt 
Associates, LLC, Salaried Employee Benefits Provided by Major U.S. 
Employers in 1999—Manufacturing, and Hewitt Associates, LLC, Hourly 
Employee Benefits Provided by Major U.S. Employers, 1999. 

[End of table] 

Retiree premium contribution. The Funds' beneficiaries do not pay a 
premium beyond that required for Medicare part B, the optional part of 
Medicare. According to a study by Hewitt Associates, 61 percent of 
unionized companies require retired unionized hourly workers to pay a 
health insurance premium.[Footnote 26] A related study found that more 
than 92 percent of major manufacturing companies require retirees from 
salaried jobs to pay a health insurance premium.[Footnote 27] 

Deductible. The Funds' beneficiaries are not responsible for an annual 
deductible. Beginning with the first covered service used, the Funds 
pay all but the copayment. In contrast, the average annual deductible 
for workers in large manufacturing companies is more than $260 for 
individuals and more than $615 for families. 

Cap on beneficiary out-of-pocket expenses. The Funds' beneficiaries 
are responsible for copayments on each service used, up to an annual 
amount of $100 per family, excluding prescription drugs. Additional 
out-of-pocket expenses for covered prescription drugs are capped at 
$50 per family per year. The total cap of $150 is substantially less 
than the median cap of over $1,750 in plans offered to other unionized 
hourly workers. 

SNF coverage. The Funds' beneficiaries are eligible for SNF care with 
no cost-sharing requirement and no limit on the number of covered 
days.[Footnote 28] In contrast, most employer-sponsored retiree plans 
do not offer SNF care. Those that do typically restrict the number of 
days covered, require cost sharing, or both. 

Outpatient prescription drug benefit. The Funds' beneficiaries pay a 
$5 copayment per prescription and their annual out-of-pocket costs for 
covered prescription drugs are capped at $50. In contrast, many plans 
offered by manufacturing companies do not have deductibles but require 
beneficiaries to pay higher cost sharing requirements with no cap on 
out-of-pocket costs.[Footnote 29] (See table 2.) Some plans require 
beneficiaries to pay 20 percent of the cost of each prescription while 
others use multitiered copayment schedules that may, for example, 
require $5 for generic drugs, $10 to $15 for brand name drugs included 
in the health plan's formulary, and $20 or more for nonformulary brand 
name drugs. [Footnote 30] Furthermore, 14 of the 17 companies we 
contacted that cover prescription drugs do not cap retirees' out-of-
pocket costs for outpatient prescription drugs. 

Table 2: Comparison of the Funds' Outpatient Prescription Drug Benefit 
with Benefits Offered by Selected Retiree Health Plans in 
Manufacturing Companies, 2000: 

Plan feature: Prescription drug benefit: No benefit; 
Feature included in the	CBF and the 1992 Benefit Plan: [Empty]; 
Number of comparison plans with features (n=25): 8. 

Plan feature: Prescription drug benefit: Benefit offered; 
Feature included in the	CBF and the 1992 Benefit Plan: [Check]; 
Number of comparison plans with features (n=25): 17. 

Plan feature: Drug deductible (annual): None; 
Feature included in the	CBF and the 1992 Benefit Plan: [Check]; 
Number of comparison plans with features (n=25): 12. 

Plan feature: Drug deductible (annual): $50; 
Feature included in the	CBF and the 1992 Benefit Plan: [Empty]; 
Number of comparison plans with features (n=25): 1. 

Plan feature: Drug deductible (annual): More than $50; 
Feature included in the	CBF and the 1992 Benefit Plan: [Empty]; 
Number of comparison plans with features (n=25): 4. 

Plan feature: Cap on beneficiary out-of-pocket drug expenses: Cap on 
costs; 
Feature included in the	CBF and the 1992 Benefit Plan: [Check][B]; 
Number of comparison plans with features (n=25): 3. 

Plan feature: Cap on beneficiary out-of-pocket drug expenses: No cap 
on costs; 
Feature included in the	CBF and the 1992 Benefit Plan: [Empty]; 
Number of comparison plans with features (n=25): 14. 

Plan feature: Generic drug substitution incentive policy: Mandatory 
substitution; 
Feature included in the	CBF and the 1992 Benefit Plan: [Check]; 
Number of comparison plans with features (n=25): 5. 

Plan feature: Generic drug substitution incentive policy: 
Voluntary/differential pricing[C]; 
Feature included in the	CBF and the 1992 Benefit Plan: [Empty]; 
Number of comparison plans with features (n=25): 10. 

Plan feature: Generic drug substitution incentive policy: 
Voluntary/equal pricing for generics and brands; 
Feature included in the	CBF and the 1992 Benefit Plan: [Empty]; 
Number of comparison plans with features (n=25): 2. 

[A] Comparison companies are a randomly selected subset of automotive, 
energy, oil, mining, and metals/steel companies that responded to the 
1999 Hewitt survey of the manufacturing industry. 

[B] The Funds cap beneficiary out-of-pocket drug costs at $50 
annually, although beneficiaries may pay an additional amount if they 
use brand names instead of generics or nonpreferred brand names for 
certain classes of drugs. The amount was higher ($1,000 to $2,000) for 
the comparison companies whose plans had caps. 

[C] Voluntary/differential pricing includes multitiered pricing with 
lower copayments for generics than for brand name drugs. 

Source: UMWA Combined Benefit Fund Plan Document (www.umwafunds.org, 
downloaded on December 12, 2001), UMWA 1992 Benefit Plan Plan Document 
(www.umwafunds.org, downloaded on December 12, 2001), and GAO survey 
of 25 manufacturing companies' retiree health plans. 

[End of table] 

However, the Funds' prescription drug benefit is more restrictive than 
those of some other retiree benefit plans, in that it generally limits 
coverage to generic versions of prescription drugs when generic 
versions are available. The Funds pay the entire cost of a drug, with 
the exception of the copayment, if a beneficiary uses a generic 
version of a prescription drug when one is available, unless his or 
her physician submits a written justification specifying that a 
particular brand is necessary. If the request is approved, the 
beneficiary is not charged an additional amount for the brand name 
product. Typically, about 40 such requests are received each month and 
about 30 percent of them are approved. Without approval, the Funds' 
beneficiaries who use brand name drugs instead of generic equivalents, 
or who use off-formulary brand names instead of ones included on the 
formulary, must pay the full difference in price between the preferred 
and nonpreferred drug. This amount does not count toward the 
beneficiary's $50 annual cap on prescription drug expenditures. Only 5 
of the 17 companies we contacted that cover prescription drugs have 
similar mandatory generic drug use policies. 

The Funds' Beneficiaries Have Higher Health Care Costs than Comparable 
Beneficiaries: 

The average annual health care cost of the Funds' beneficiaries is 
approximately 29 percent higher than the average cost of 
demographically similar Medicare retirees with employer-provided 
insurance.[Footnote 31] The Funds' beneficiaries also tend to use more 
health care services than Medicare beneficiaries of the same age and 
sex. The Funds' beneficiaries appear to be in relatively poorer 
health, which may explain the differences in cost and service use. 

In 1999, the Funds spent an average of $9,732 on each beneficiary who 
was eligible for Medicare. This was $2,163, or 29 percent, higher than 
the estimated average health care cost of Medicare beneficiaries who 
live in the same counties where the Funds' beneficiaries live, have 
similar demographic characteristics, and have employer-provided 
supplemental insurance. (See figure 1.) Approximately $1,345 (62 
percent) of the $2,163 estimated cost differential is associated with 
increased use of Medicare-covered services while the remaining $818 
(38 percent) is associated with additional benefits, such as 
prescription drug coverage, that are covered by the Funds. 

Figure 1: Health Care Expenditures for the Funds' Medicare-Eligible 
Beneficiaries and Comparable Medicare Beneficiaries with Employer-
Sponsored Health Insurance, 1999: 

[Refer to PDF for image: stacked vertical bar graph] 

Per capita health care expenditures are depicted for the following: 

Funds' beneficiaries: 
Benefits covered by employer insurance: approximately $3,200; 
Benefits covered by Medicare: approximately $6,500. 

Comparable Medicare beneficiaries: 
Benefits covered by employer insurance: approximately $2,000; 
Benefits covered by Medicare: approximately $5,000. 
			
Note: Estimates reflect costs of Medicare beneficiaries who live in 
counties where beneficiaries of the Funds live and are adjusted to 
reflect differences between Medicare beneficiaries and the 
beneficiaries of the Funds in characteristics such as age, sex, 
Medicaid eligibility, current labor force participation, and whether 
or not they are living in institutions. 

Source: GAO analysis of CMS's and the Funds' data. 

[End of figure] 

The beneficiaries of the Funds who are eligible for Medicare generally 
use more health care services than do similar Medicare beneficiaries 
nationwide. In 1999, the beneficiaries of the Funds had 22 percent 
more physician office visits, 51 percent more days in SNFs, 91 percent 
more days in the hospital, and 55 percent more days in hospice care 
than the national average for Medicare beneficiaries of the same age 
and sex.[Footnote 32] However, the Funds' beneficiaries' use of home 
health care was substantially below the average home health 
utilization rate among demographically similar Medicare beneficiaries. 
[Footnote 33] 

The health status of the Funds' beneficiaries may explain some of the 
observed differences in health care costs and utilization. In 1999, 
the average beneficiary in the Funds reported his or her health status 
as fair or good. That same year, the average Medicare beneficiary with 
similar demographic characteristics reported his or her health status 
as good or very good.[Footnote 34] Several studies have found that 
individuals who report poorer health tend to use substantially more 
services than individuals who report better health.[Footnote 35] Thus, 
it is likely that some of the higher costs and utilization associated 
with the Funds' beneficiaries is a result of their relatively poorer 
health. The Funds' low cost-sharing requirements provide few financial 
barriers to care, which may also contribute to the cost differential. 
However, we cannot determine how much of the cost and utilization 
difference is attributable to health status differences, local 
practice patterns, or differences in benefit packages and cost sharing 
arrangements. 

The Funds' Trustees Have Implemented a Number of Cost Control 
Initiatives: 

The Funds' trustees have stated that they are firmly committed to 
preserving the "benefits that were promised and guaranteed" to the 
retired miners and therefore their cost control efforts largely focus 
on making the Funds a more efficient manager and prudent purchaser of 
health care services.[Footnote 36] While many private employers have 
responded to rising health care costs by requiring their beneficiaries 
to contribute more to the cost of health insurance, either through 
higher premiums or increased copayments and deductibles, the trustees 
have chosen to make relatively few changes that would affect the 
Funds' beneficiaries' out-of-pocket expenses.[Footnote 37] 

According to the Funds' representatives, the trustees have tried to 
deliver services more efficiently and negotiate lower prices from 
providers and suppliers. The Funds' efficiency initiatives include a 
disease and case management program and the management of medical 
service use through prepayment claims and utilization review. 
Beneficiaries with health conditions such as diabetes or congestive 
heart failure receive care coordinated by the Funds' disease 
management program. To help prevent unnecessary spending, the third-
party administrator that processes the Funds' claims reviews billing 
patterns to identify potential billing abuses or inappropriate 
payments and has also instituted other program integrity safeguards. 

The Funds' efforts at being a prudent purchaser of care include a 
competitive bidding program for durable medical equipment suppliers, a 
range of initiatives designed to help control spending for 
prescription drugs, and arrangements with hospitals and physicians 
providers to accept Medicare rates as payments in full for all 
beneficiaries, including those who are not eligible for Medicare. The 
Funds have solicited competitive bids for durable medical equipment in 
an effort to obtain better pricing and have reduced the number of 
suppliers nationwide from several hundred to six The Funds' PBM, which 
administers the prescription drug benefit, has established a 
formulary, mandated the use of generic drugs when available, 
implemented a preferred product program, negotiated discounts, and 
initiated mail order pharmacy services. The Funds claim that these 
cost control efforts collectively have achieved millions of dollars in 
savings per year. 

The Funds' officials have tried to maintain the established level of 
benefits and cost sharing for their beneficiaries even while health 
care costs have risen. For example, neither the copayments nor the cap 
on out-of-pocket expenditures for the Funds' beneficiaries have been 
adjusted for inflation or otherwise modified since they were 
established.[Footnote 38] The Funds' beneficiaries face no cost 
sharing after they reach their annual $100 cap on out-of-pocket 
expenses for covered services ($150 including outpatient prescription 
drugs). In contrast, other employers have reduced coverage for 
prescription drugs or other benefits, shifted retirees into managed 
care plans, or stopped offering retiree health benefits altogether in 
response to recent health care cost increases. 

Concluding Observations: 

From 1994 through 2000, the per capita health care costs of the CBF's 
beneficiaries increased by 53 percent while those of the 1992 Benefit 
Plan's beneficiaries increased by 28 percent. The Funds' officials 
have taken steps to help control the cost growth. The Funds' officials 
contend, however, that statutory requirements pertaining to coverage 
impede their ability to require beneficiaries to pay more for their 
health care. To cover rising health care costs, the 1992 Benefit Plan 
has increased the premiums charged to coal companies. This option is 
not available to the CBF because the Coal Act ties annual premium 
updates to a formula that accounts for inflation, but not to changes 
in the use of health care services. Consequently, Congress has had to 
provide the CBF with additional money in recent years to close the gap 
between its costs and revenues. These annual shortfalls are expected 
to continue into the future as the CBF's beneficiaries grow older and 
require more medical services. 

Comments from the UMWA Health and Retirement Funds and Our Evaluation: 

In written comments on a draft of this report, the Funds[Footnote 39] 
emphasized the importance of the history of the Coal Act in 
understanding the Funds' operations, provided additional detail on the 
health status of their beneficiary population, and stressed the 
breadth and success of their cost control efforts. The Funds also 
pointed out technical issues that we have incorporated, where 
appropriate. 

The Funds' officials stressed that comparisons of their plans and 
beneficiaries with other plans and populations are misleading without 
a full appreciation of the history behind the 1992 Coal Act and the 
characteristics of their beneficiary population. Specifically, they 
emphasized that coal miners traded lower pensions for better health 
care benefits in their labor contracts. The Funds' comments cited the 
1990 Coal Commission Report conclusion that "retired miners are 
entitled to the health care benefits that were promised and guaranteed 
them and that such commitments must be honored." They noted that the 
Funds' beneficiaries have already contributed significantly to their 
health care benefits through the shifting of assets from their pension 
plans. The Funds stated that any comparisons of benefits with other 
groups are inappropriate because the plans' benefits are a culmination 
of their history. 

The Funds also said that cost comparisons are misleading because their 
population is sicker than comparably aged men and women. Finally, the 
Funds emphasized their record of success in implementing a wide range 
of managed care and cost containment programs and claimed that these 
initiatives have realized substantial savings for the Funds and for 
Medicare and the U.S. Treasury. 

We acknowledge that the retired coal miners traded lower pensions for 
the promise of future health care benefits, and that this may be an 
important consideration when interpreting our benefit comparisons with 
packages offered by other manufacturing companies and companies with 
significant numbers of unionized workers. Our analysis finds that the 
Funds' plans are generally comparable, but more generous in some 
dimensions and less so in others. Our cost comparison adjusts for all 
the demographic information used by Medicare to calculate the average 
cost per beneficiary, and acknowledges the differences in self-
reported health status. Finally, as we have noted in the report, the 
Funds' officials have adopted numerous cost-cutting initiatives and 
have a history of achieving savings against their Medicare targets. 

As we agreed with your office, unless you publicly announce the 
contents of this report earlier, we plan no further distribution of it 
until 30 days from the date of this letter. We will then send copies 
of this report to the UMWA Health and Retirement Funds and other 
interested parties. We will also make copies available to others upon 
request. 

If you or your staff have any questions about this report, please call 
me at (202) 512-7119 or James C. Cosgrove, assistant director, at 
(202) 512-7029. Other major contributors to this report include Jim S. 
Hahn and Richard M. Lipinski. 

Sincerely yours, 

Signed by: 

Laura A. Dummit: 
Director, Health Care—Medicare Payment Issues: 

[End of section] 

Related GAO Products: 

Medigap: Current Policies Contain Coverage Gaps, Undermine Cost 
Control Incentives, [hyperlink, 
http://www.gao.gov/products/GAO-02-533T]. Washington D.C.: Mar. 14, 
2002. 

Retiree Health Insurance: Gaps in Coverage and Availability, 
[hyperlink, http://www.gao.gov/products/GAO-02-178T]. Washington, 
D.C.: Nov. 1, 2001. 

Retiree Health Benefits: Employee-Sponsored Benefits May Be Vulnerable 
to Further Erosion, [hyperlink, 
http://www.gao.gov/products/GA0-01-374]. Washington, D.C.: May 1, 2001. 

Additional Information Related to Analysis of the Administration's 
Proposal to Ensure Solvency of the United Mine Workers of America 
Combined Benefit Fund, [hyperlink, 
http://www.gao.gov/products/GAO/MNID-00-308R]. Washington, D.C.: Aug. 
31, 2000. 

Financial and Legal Issues Facing the United Mine Workers of America 
Combined Benefit Fund, [hyperlink, 
http://www.gao.gov/products/GAO/MNID-00-280R]. Washington, D.C.: Aug. 
15, 2000. 

Analysis of the Administration's Proposal to Ensure Solvency of the 
United Mine Workers of America Combined Benefit Fund, [hyperlink, 
http://www.gao.gov/products/GAO/MNID-00-267R]. Washington, D.C.: Aug. 
15, 2000. 

Prescription Drugs: Increasing Medicare Beneficiary Access and Related 
Implications, [hyperlink, 
http://www.gao.gov/products/GAO/T-HEHS/AIMID-00-100]. Washington, 
D.C.: Feb. 16, 2000. 

Private Health Insurance: Declining Employer Coverage May Affect 
Access for 55- to 64-Year-Olds, [hyperlink, 
http://www.gao.gov/products/GAO/HEHS-98-133]. Washington, D.C.: June 
1, 1998. 

Retiree Health Insurance: Erosion in Retiree Health Benefits Offered 
by Large Employers, [hyperlink, 
http://www.gao.gov/products/GAO/T-HEHS-98-110]. Washington, D.C.: Mar. 
10, 1998. 

Retiree Health Insurance: Erosion in Employer-Based Health Benefits 
for Early Retirees, [hyperlink, 
http://www.gao.gov/products/GAO/HEHS-97-150]. Washington, D.C.: July 
11, 1997. 

[End of section] 

Footnotes: 

[1] Pub L. No. 102-486, Tit. XIX, Subtit. C, 106 Stat 2776, 3036 
(codified at 26 U.S.C. §§ 97019722 (1994)). 

[2] The 1950 UMWA Benefit Plan and the 1974 UMWA Benefit Plan were 
merged to create the CBF, which continued coverage for retirees 
receiving benefits from either of the two plans. The 1992 Benefit Plan 
was created to serve (1) individuals who, on February 1, 1993, were 
eligible but not receiving benefits as of July 20, 1992, and who had 
retired by September 30, 1994, and (2) subsequent retirees eligible 
under the previous plans whose former employers stopped providing 
health care coverage or had gone out of business. The CBF and the 1992 
Benefit Plan are alike in most respects except for how they are 
financed. The comments in this report generally apply to both funds. 
When a distinction must be drawn between the two funds each one is 
identified by name. 

[3] Had the Congress not made a special appropriation to keep the fund 
solvent, there would have been an annual operating deficit of about 
$53.4 million in 2001. 

[4] Under the Coal Act, the CBF also assumed responsibility for the 
death benefits coverage previously provided by the pension plans it 
replaced. These benefits amounted to $7.8 million in 2000. Expenditure 
figures are reported for the fund's fiscal year. 

[5] Under the Coal Act, the 1992 Benefit Plan is financed by a 
combination of two premiums charged to signatory coal companies. The 
references in this report to 1992 Benefit Plan premiums refer to the 
per beneficiary premium, which the trustees set to reflect the 
expected per beneficiary cost of health care for the coming year. The 
other premium is calculated and charged to coal companies to ensure 
that there are sufficient funds to cover the costs of individuals in 
the plan whose companies no longer offered health care benefits or who 
could not be assigned to specific companies. 

[6] We addressed questions concerning fund financing in three previous 
letters: U.S. General Accounting Office, Analysis of the 
Administration's Proposal to Ensure Solvency of the United Mine 
Workers of America Combined Benefit Fund, [hyperlink, 
http://www.gao.gov/products/GAO/AIMD-00-267R] (Washington, D.C: Aug. 
15, 2000), Financial and Legal Issues Facing the United Mine Workers 
of America Combined Benefit Fund, [hyperlink, 
http://www.gao.gov/products/GAO/AIMD-00-280R] (Washington, D.C.: Aug. 
15, 2000), and Additional Information Related to Analysis of the 
Administration's Proposal to Ensure Solvency of the United Mine 
Workers of America Combined Benefit Fund, [hyperlink, 
http://www.gao.gov/products/GAO/AIMD-00-308R] (Washington, D.C.: Aug. 
31, 2000). 

[7] See Hewitt Associates, LLC, Salaried Employee Benefits Provided by 
Major U.S. Employers in 1999—Manufacturing (Lincolnshire, Ill.: 2000) 
and Hourly Employee Benefits Provided by Major U.S. Employers, 1999 
(Lincolnshire, Ill.: 2000). The manufacturing study included 
information from 513 companies, while the hourly employee benefits 
study included information from 126 employers with union employees. 

[8] On July 1, 2001, the name of the Health Care Financing 
Administration (HCFA) was changed to the Centers for Medicare and 
Medicaid Services. In this report, we continue to refer to HCFA where 
our findings apply to the organizational structure and operations 
associated with that name. 

[9] The 2001 financial statements were not available during the time 
we were preparing this report. 

[10] 26 U.S.C. §§ 9701-9722 (1994). 

[11] The Coal Act specifies that the three employers must not be 
signatories to the 1988 National Bituminous Coal Wage Agreement. 

[12] The Funds also receive a small amount of their revenues from 
other sources, such as income from the pursuit of delinquencies owed 
the merged plans, from the Department of Labor for black lung related 
care, and interest income from investments. 

[13] The Coal Act transferred $210 million (13 percent of assets) from 
the UMWA 1950 Pension Plan to the CBF in three transactions of $70 
million each from February 1, 1993, to October 1, 1994. These assets 
were then used to finance the health care benefits under the Coal Act, 
instead of pensions. Actuarial estimates produced for the BCOA place 
the value of forgone pensions due to this transfer at $743 per year 
for retired miners and $248 per year for widows. 

[14] The Surface Mining Control and Reclamation Act of 1977, Pub. L. 
No. 95-87, 91 Stat. 445, established the AML primarily to fund 
cleanups of abandoned mine land. The Coal Act specified that 
accumulated AML interest could be used to pay the health care costs of 
those beneficiaries for whom the CBF did not receive premiums from 
coal companies. AML moneys are not used for the 1992 Benefit Plan. 

[15] The Funds' representatives said that administrative costs were 
roughly 4 percent of CBF expenses from 1993 through 2000. 

[16] Following the Supreme Court's decision in Eastern Enterprises v. 
Apfel, 524 U.S. 498 (1998), some employers have been relieved of their 
financial responsibilities. 

[17] This employer must be a signatory to the 1988 National Bituminous 
Coal Wage Agreement. 

[18] The annual spending targets and capitation payment amounts are 
calculated from the Funds' per capita cost of providing Medicare-
covered services in a specified base year updated by changes in the 
Medicare program's per capita spending since that year. 

[19] For information on legal challenges, see U.S. General Accounting 
Office, Financial and Legal Issues Facing the United Mine Workers of 
America Combined Benefit Fund, [hyperlink, 
http://www.gao.gov/products/GAO/AIMD-00-280R] (Washington, D.C.: Aug. 
15, 2000).	 

[20] National Coal Association vs. Chater, 81 F.3d 1077 (11th Cir. 
1996). 

[21] Eastern Enterprises v. Apfel, 524 U.S. 498 (1998). 

[22] Dixie Fuel Co. v. Comm'r of Soc. Sec., 171 F.3d 1052 (6th Cir. 
1999, petition for rehearing denied, 1999 U.S. App. Lexis 16997 (6th 
Cir. July 7, 1999). 

[23] We compared the Funds' benefits with those offered to retired and 
active workers in 513 large manufacturing companies and 126 companies 
with unionized hourly workers that participated in a survey on 
benefits conducted by Hewitt Associates, LLC. Details on active 
workers' health benefit packages are reported here because similar 
information was not available for some dimensions of retirees' benefit 
packages. According to a representative of Hewitt Associates, the 
health benefit packages offered to retirees are typically comparable 
to, or somewhat less generous than, the benefit packages offered to 
active workers. Data on unionized companies include both manufacturing 
and nonmanufacturing companies. 

[24] Disabled workers can become eligible for pensions and health 
benefits under other conditions. 

[25] Age, years of service, or some combination of the two was 
required for eligibility for almost all of the employers with 
unionized hourly workers who responded to the survey conducted by 
Hewitt Associates, LLC. 

[26] Hewitt Associates, LLC, Hourly Employee Benefits Provided by 
Major U.S. Employers, 1999. 

[27] Hewitt Associates, LLC, Salaried Employee Benefits Provided by 
Major U.S. Employers in 1999—Manufacturing. 

[28] The care must be deemed medically appropriate and be consistent 
with Medicare's SNF coverage criteria. Medicare covers most necessary 
SNF services, including room and board, nursing care, and ancillary 
SNF services such as drugs, laboratory tests, and physical therapy for 
up to 100 days of each benefit period. Beneficiaries must meet certain 
qualifying conditions such as having prior hospitalization and paying 
a copayment beginning with the 21st day ($99 per day in 2001). There 
is no limit to the number of benefit periods a beneficiary may have. 

[29] We surveyed a randomly selected subset of 25 automotive, energy, 
oil, mining, and metals/steel companies that responded to the 1999 
Hewitt survey of the manufacturing industry. 

[30] In general, a formulary is a list of drugs that, in most 
circumstances, a health insurer prefers that physicians prescribe. The 
formulary includes drugs that the insurer has deemed to be effective 
and suppliers may have favorably priced for the insurer. 

[31] A third fund, the 1993 Benefit Plan, was established through 
collective bargaining between UMWA and BCOA. In March 2000, it covered 
approximately 2,000 beneficiaries. Because some UMWA data were 
reported collectively for the CBF, the 1992 Benefit Plan, and the 1993 
Benefit Plan, the estimated cost per beneficiary is based on a joint 
analysis of all three funds. 

[32] The Funds beneficiaries' utilization rates may resemble local 
practice patterns more closely than they reflect national averages. 
For example, about 32 percent of the Funds' beneficiaries live in West 
Virginia—a state where the number of inpatient days per thousand for 
Medicare beneficiaries is 15 percent higher than the national average. 

[33] The comparison group of Medicare beneficiaries was similar to the 
Funds' Medicare-eligible beneficiaries in terms of age, sex, Medicaid 
eligibility, labor force participation, and whether or not they were 
living in institutions. 

[34] We obtained self-reported health status information on Medicare 
beneficiaries from the Medicare Current Beneficiary Survey. In a 
February 2001 survey of the Funds' beneficiaries, 57 percent of the 
respondents aged 65 and older reported their health status as "fair" 
or "poor." Comparable information from the 2001 Medicare Current 
Beneficiary Survey was not available during the time we were preparing 
this report. 

[35] For example, see Arlene S. Bierman, Thomas A. Bubolz, Elliott S. 
Fisher, and John H. Wasson, "How Well Does a Single Question about 
Health Predict the Financial Health of Medicare Managed Care Plans?" 
Effective Clinical Practice, Volume 2, Number 2 (Philadelphia: 
American College of Physicians, March/April 1999). 

[36] According to the Funds' representatives, the trustees view the 
Coal Act's requirement that, "to the maximum extent feasible," the 
coverage under both the CBF and the 1992 Benefit Plan be 
"substantially the same" as coverage under the UMWA plans they 
replaced as a restriction on their ability to increase beneficiary 
cost sharing or to reduce covered services. 

[37] See U.S. General Accounting Office, Retiree Health Benefits: 
Employee-Sponsored Benefits May Be Vulnerable to Further Erosion, 
[hyperlink, http://www.gao.gov/products/GAO-01-374] (Washington, D.C.: 
May 1, 2001). 

[38] In comparison, the Medicare inpatient deductible increased 
approximately 19 percent from 1992 through 2000. 

[39] The Funds forwarded the draft to, and received comments, from 
BCOA, UMWA, and the three coal companies with the largest number of 
assigned beneficiaries. Our response addresses the comments from all 
of these organizations. 

[End of section] 

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