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HomeMy WebLinkAbout06-21-2016 Item 12 Authorization to move from CJPIA Primary Insurance Program to the Excess Insurance Program for Liability Coverage Meeting Date: 6/21/2016 FROM: Monica Irons, Director of Human Resources Prepared By: Greg Zocher, Human Resources Manager SUBJECT: AUTHORIZATION TO MOVE FROM CJPIA PRIMARY INSURANCE PROGRAM TO THE EXCESS INSURANCE PROGRAM FOR LIABILITY COVERAGE RECOMMENDATION 1. Authorize the City Manager to execute a Memorandum of Coverage (MOC) (Attachment A) when final with California Joint Powers Insurance Authority (CJPIA) to participate in the Excess Insurance Program for liability insurance coverage, subject to final approval as to form and substance by the City Manager and City Attorney; and 2. Adopt a resolution delegating claim settlement authority to CJPIA (Attachment B); and 3. Authorize the City Manager to execute agreement with Carl Warren for third party administration services for liability insurance program (Attachment C), subject to final approval as to form and substance by the City Manager and City Attorney. DISCUSSION Background The City of San Luis Obispo became a member of the CJPIA in 2003 for participation in the liability program. Membership in the CJPIA means sharing risk with other member agencies. However, the risk is shared among a large number of agencies, who share common goals of risk avoidance, claims control and transfer of risk in order to eliminate or reduce exposure. By following proven practices of risk management, member agencies assist each other in keeping the cost of claims down. By sharing risk, the cost to an agency for a year with significant claims experience is somewhat mitigated and spread out over a number of agencies. After ten years of participation in the CJPIA and with direction from Council, it was appropriate to explore alternatives to the CJPIA with the objective of reducing costs while effectively managing the City’s risk and protecting the City’s assets. This analysis was conducted and presented to Council in April 2014 with the recommendation to remain in CJPIA. The City currently has “first dollar” coverage, meaning that CJPIA pays all eligible claims with lower financial risk associated with the coverage under the CJPIA and costs for this type of coverage were competitive based on the quotes received and analysis conducted. However, insurance costs continue to be significant for the City and cost increases are unpredictable based on the pool’s experience, thus warranting continued evaluation as identified in Other Important Council 12 Packet Pg. 154 Objectives – Fiscal Sustainability and Responsibility. Since its inception, CJPIA has offered its members “first dollar” or Primary Insurance Program for covered liability claims, meaning that there is no Self Insured Retention (SIR) or deductible. This results in the full amount of the claim being allocated and shared by members in the pool, just as other members’ claims costs are shared by the City of San Luis Obispo. Similar to our evaluation of CJPIA costs, other member agencies in the CJPIA pool began exploring other insurance funding models outside CJPIA. In an effort to address their member agencies’ request for more insurance options, CJPIA realized the need to develop a separate Excess Insurance Program (EIP), wherein EIP members no longer share the risk with all CJPIA member agencies and are able to select an SIR level which best fits the EIP member’s claim experience resulting in a discounted insurance premium. The newly developed EIP allows members to select from five SIR levels ranging from $150,000 to $1.0 Million. The newly developed EIP is for Liability coverage only. CJPIA will explore expanding the EIP for the Workers’ Compensation program at a later time. When developed, staff will analyze the merits of moving to the EIP for Workers’ Compensation coverage, and will make a recommendation to Council at that time. Until then, the City will remain in the primary insurance program and continue to receive “first dollar” coverage for Workers’ Compensation coverage. Based on an analysis of claims experienced and potential savings, staff recommends moving to the EIP liability coverage, with a $500,000 SIR. A draft version of the MOC is provided in Attachment A. CJPIA is working with staff on finalizing contract language as this report is being written and CJPIA will take the MOC to its Executive Committee to review requested modifications and for final approval on June 22nd. In order to join the EIP effective July 1, 2016, staff recommends Council authorize the City Manager to execute an agreement with Carl Warren, the City’s current third party claims administrator, for continued third party claims administration services under the EIP, as well as the MOC with CJPIA when finalized, subject to City Attorney approval as to form and provided there are no significant substantive changes. Primary Insurance Program vs. Excess Insurance Program The City of San Luis Obispo has eleven years of claim experience with CJPIA’s Primary Insurance Program. The concept of “pooling” risk means there is an allocation of costs among all members in the insurance pool based on the pool’s claim experience, not the individual agencies’ claim experience. All costs, including third party claims administration fees, are allocated proportionally to all members in the Primary Insurance Program. Historically, the City’s liability claim experience has been relatively low (City normalized claim costs - $1.31 per $100 of payroll) compared to other member agencies (Pool average normalized claim costs - $3.87 per $100 of payroll). In fact, our annual contributions have averaged $1.3 million while the City’s claim experience has only averaged $476,000. For many agencies “first dollar” Primary Insurance Program is appealing because, in the event of a poor claim year, other agencies will help cover the claim costs. In the primary insurance program, costs are allocated based on both claim experience and agency payroll. Agencies with larger payroll (exceeding $20 Million) and lower claim experience would 12 Packet Pg. 155 potentially find moving to an EIP more advantageous. While there is no set methodology when choosing an SIR level, some insurance experts recommend using the agency’s annual budget as a base and applying 1% of that figure to set the initial SIR level. Using this methodology, the City’s annual budget ($123 Million) would suggest that an SIR option up to $1 Million could be appropriate. However, choosing a higher SIR is not recommended, as the additional discounted premiums for the higher SIR are not sufficient when compared to additional potential exposure. Based on claim experience, which is stratified into loss layers, an agency can also make a determination on which SIR would be most appropriate. With the Primary Insurance Program there is little direct correlation between individual claim experience and premium costs. With the EIP there is a stronger correlation between loss experience and premium costs. This means an agency that continues to have good claim experience can more directly impact savings in premiums. Under the EIP a discounted premium would be charged to cover program costs, pooled retention costs, and to purchase Excess Insurance which pay for claims that exceed the pooled retention. In addition, claims administration fees would need to be paid directly to the third party administrator, Carl Warren. Other program characteristic differences, described in Attachment D, have been evaluated and, based on staff’s analysis of the City’s claim experience, found acceptable. Liability Claim Experience While not a perfect predictor of future claims, the City’s best indicator is to look back at actual claims data to estimate potential savings (or costs) under the EIP model. For the past eleven years, the City’s liability claim experience has averaged approximately $476,000 annually. Over 99% of these claims fall under $150,000 per claim. Based on the lower severity of claims experienced over the last eleven years, moving to the EIP with a $500,000 SIR would potentially lower premium and claim costs compared to the current Primary Insurance Program. For illustrative purposes, by overlaying prior claim experience with current annual premiums costs, the savings could be substantial (average as much as $500,000 annually). If claim experience changes significantly from the historical average, the City would have the option to reevaluate and potentially choose a different SIR level. However, moving to the EIP would require a three year commitment before the City would have the option of returning to the primary insurance program for “first dollar” liability coverage. How Would the EIP Work? Rather than pay a $2 Million premium under the Primary Insurance Program for first dollar coverage, the City would pay a discounted rate of $984,500 and move into the EIP with a $500,000 SIR. In addition, the City would pay a claims administration fee of approximately $42,000 annually based on the number and type of claims averaged during the past eleven years. The money not spent on the current Primary Insurance Program premium would need to be set aside or “designated” to pay any claims incurred under the SIR (i.e. less than $500,000) level during the fiscal year. Since it takes approximately three years for claims to close, it would be advisable to set aside a similar amount ($1.0 Million) annually for three years. Once a claim year closes out, any extra funds that were set aside and not needed to pay for claims could be used to defray insurance costs for that year or other purposes as directed by Council. For example, under the EIP for fiscal year 2016-17, instead of paying approximately $2 Million in premiums to CJPIA, the City’s premium would be reduced to approximately $1 Million 12 Packet Pg. 156 allowing a set aside of approximately $1 Million. Claim year 2016-17 would likely close in 2019, at which time any funds set aside but not used to pay claims would be available for other insurance costs or other purposes. Based on past experience average claim years, this could be as much as $500,000; an amount that would have helped pay other members’ claims under the Primary Insurance Program model. Why CJPIA Based on analysis, in April 2014 staff did not recommend moving to another Joint Powers Authority (JPA) for EIP coverage. This was due to other JPAs not offering the “hands on” risk management services, including claims administration, which would have required hiring additional staff for claims management, legal services and claims settlement. With CJPIA’s EIP, the City will have program continuity, the ability to utilize the same third party administrator, and continue to have access to high caliber law firms that have represented the City very well. The City historically has delegated authority to administratively process and reject claims and, through our existing MOC, has delegated settlement authority to CJPIA. This delegation has reduced staff time, and eliminated redundancies and the third party administrator and CalJPIA staff have consistently worked collaboratively and effectively with City risk management and legal staff. While the new EIP gives agencies the option to assume settlement authority for most claims within the SIR, the option to continue with the current claim settlement authority model is also available. For the past eleven years, staff has found the delegation of claim settlement to work very well – CJPIA communicates regularly regarding claim status, solicits staff and Council input on significant settlement decisions and is respectful of the City’s input on claims and settlement decisions. Staff recommends Council adopt a resolution (Attachment B) to continue to delegate claims settlement authority to CJPIA under the new EIP. There are numerous other benefits that would come at no additional cost by remaining a member of CJPIA and moving to the EIP. CJPIA provides access to ancillary insurance coverages at reduced group rates. The City currently takes advantage of many of these insurance options including: environmental and pollution, property, fidelity and special event insurance. CJPIA offers numerous training opportunities that meet OSHA or other legal requirements and enhances the City’s overall risk management program that puts the City in position to consider moving from first dollar coverage to an EIP. In addition, CJPIA provides access to legal advisors in the area of employment law, workers compensation and liability claims. In addition to the insurance coverages described above, the CJPIA also provides a comprehensive risk management program that includes a risk management evaluation every three years. The risk management evaluation results in a Loss Control Action Plan (LossCAP) which is a comprehensive program designed to assist the City in addressing areas in which risk exposure indicates the need for changes to the City’s operations. The LossCAP provides recommendations based on a review of various aspects of City operations including: policies, procedures, contracts, agreements, insurance and risk transfer, facilities and infrastructure. Recommendation from these evaluations will be implemented with continued reduction in claim experience as the ultimate goal. Doubtless these services have been a factor in t he City’s liability claim history. 12 Packet Pg. 157 FISCAL IMPACT In the first three years the EIP would yield no cost reductions since the City will need to build up the funds necessary to pay claims within its SIR level. After the third year in the EIP, based on historical information, the City should experience significant cost reductions in the EIP when compared to the primary insurance program assuming consistent claims experience. ALTERNATIVES Remain in the current Primary Insurance Program for liability claims. This alternative is not recommended, since historically the City has paid three times its claim severity in premium costs, whereas, the EIP allows for potential reduction in costs over current program. Attachments: a - Draft Memorandum of Coverage b - Resolution for participation in excess insurance program c - Draft Third Party Agreement d - Program Characteristic Differences 12 Packet Pg. 158 Packet Pg. 159 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 160 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M 2. Packet Pg. 161 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M 3. Packet Pg. 162 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M 4. 5. 6. Packet Pg. 163 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M 7. Packet Pg. 164 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 165 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 166 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 167 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 168 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 169 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 170 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 171 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 172 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 173 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 174 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 175 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 176 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 177 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 178 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 179 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 180 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 181 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 182 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 183 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 184 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 185 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 186 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 187 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 188 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 189 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 190 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 191 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 192 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 193 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M Packet Pg. 194 At t a c h m e n t Q : a - D r a f t M e m o r a n d u m o f C o v e r a g e ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M R ______ RESOLUTION NO. (2016 SERIES) A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN LUIS OBISPO, CALIFORNIA, APPROVING EXECUTION OF AGREEMENT FOR PARTICIPATION IN THE CALIFORNIA JOINT POWERS INSURANCE AUTHORITY’S EXCESS INSURANCE PROGRAM WHEREAS, the City of San Luis Obispo became a member of the California Joint Powers Insurance Authority (CJPIA) in 2003 for participation in the liability primary insurance program; and WHEREAS, the CJPIA has developed a separate Excess Insurance Program (EIP), wherein members may select a Self-Insured Retention (SIR) level which best fits claim experience; and WHEREAS, the City of San Luis Obispo’s claim experience for the past eleven years indicates moving to the EIP with an SIR of $500,000 could reduce insurance costs when compared to remaining in the primary insurance program; and WHEREAS, the City of San Luis Obispo’s current Memorandum of Coverage delegates claim settlement authority to CJPIA, the EIP allows an agency to continue to delegate claim settlement authority, and the City desires to do so; NOW, THEREFORE, BE IT RESOLVED, by the City Council of the City of San Luis Obispo as follows: SECTION 1. The Council authorizes the City Manager to execute a Memorandum of Coverage with CJPIA for participation in the liability EIP subject to final approval as to substance and form by the City Manager and City Attorney. SECTION 2. The City’s SIR for program participation shall be $500,000. SECTION 3. The Council authorizes continued delegation of claim settlement authority to the CJPIA for amounts up to and in excess of the City’s designated SIR. SECTION 4. The Director of Finance shall establish a trust account and take all necessary steps to ensure claim settlement amounts within the SIR are available for settlement and payment of claims. Upon motion of ______________________, seconded by ________________________, and on the following roll call vote: AYES: NOES: ABSENT: Packet Pg. 195 At t a c h m e n t R : b - R e s o l u t i o n f o r p a r t i c i p a t i o n i n e x c e s s i n s u r a n c e p r o g r a m ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S Resolution No. _____ (2016 Series) Page 2 R ______ The foregoing resolution was adopted this 21st day of June, 2016. ___________________________________ Mayor Jan Marx ATTEST: __________________________________ Lee Price, MMC Interim City Clerk APPROVED AS TO FORM: __________________________________ J. Christine Dietrick City Attorney IN WITNESS WHEREOF, I have hereunto set my hand and affixed the official seal of the City of San Luis Obispo, California, this ______ day of ______________, _________. ______________________________ Lee Price, MMC Interim City Clerk Packet Pg. 196 At t a c h m e n t R : b - R e s o l u t i o n f o r p a r t i c i p a t i o n i n e x c e s s i n s u r a n c e p r o g r a m ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S Packet Pg. 197 At t a c h m e n t S : c - D r a f t T h i r d P a r t y A g r e e m e n t ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M F O R Packet Pg. 198 At t a c h m e n t S : c - D r a f t T h i r d P a r t y A g r e e m e n t ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M F O R Packet Pg. 199 At t a c h m e n t S : c - D r a f t T h i r d P a r t y A g r e e m e n t ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M F O R Packet Pg. 200 At t a c h m e n t S : c - D r a f t T h i r d P a r t y A g r e e m e n t ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M F O R Packet Pg. 201 At t a c h m e n t S : c - D r a f t T h i r d P a r t y A g r e e m e n t ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M F O R Packet Pg. 202 At t a c h m e n t S : c - D r a f t T h i r d P a r t y A g r e e m e n t ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M F O R Packet Pg. 203 At t a c h m e n t S : c - D r a f t T h i r d P a r t y A g r e e m e n t ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M F O R Packet Pg. 204 At t a c h m e n t S : c - D r a f t T h i r d P a r t y A g r e e m e n t ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M F O R Packet Pg. 205 At t a c h m e n t S : c - D r a f t T h i r d P a r t y A g r e e m e n t ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M F O R Packet Pg. 206 At t a c h m e n t S : c - D r a f t T h i r d P a r t y A g r e e m e n t ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E P R O G R A M F O R Packet Pg. 207 At t a c h m e n t T : d - P r o g r a m C h a r a c t e r i s t i c D i f f e r e n c e s ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E Packet Pg. 208 At t a c h m e n t T : d - P r o g r a m C h a r a c t e r i s t i c D i f f e r e n c e s ( 1 3 8 6 : C J P I A P R I M A R Y I N S U R A N C E P R O G R A M T O T H E E X C E S S I N S U R A N C E Page intentionally left blank.