2020-11-12T14:37:07-06:00 2019-12-31 381357951 PLANTE & MORAN PLLC 10 S RIVERSIDE PLAZA 9TH FLOOR CHICAGO IL 60606 990 2019-01-01 367008317 BLUE CROSS AND BLUE SHIELD PLANS NATIONAL RETIREE HEALTH BENEFITS TRUST BLUE 3124445670 225 NORTH MICHIGAN AVENUE CHICAGO IL 60601 TERRENCE J COONEY ASST. SECRETARY OF COMMITTEE 3124445670 2020-11-11 1 DAVID LOWENTHAL P00378651 3122071040 2020-11-10 73.8.87.142 2020-11-11 08:11:42 CS P DA39A3EE5E6B4B0D3255BFEF95601890AFD80709 23D9C3BAD3C11415BCA5E3AEE50D281DF37E870F 2019 2021-04-22 16:20:28Z TERRENCE J COONEY 225 NORTH MICHIGAN AVENUE CHICAGO IL 60601 57583952 0 X N/A X 1991 IL TO PROVIDE HEALTH BENEFITS TO ELIGIBLE RETIREES OF THE BLUE CROSS & BLUE SHIELD COMPANIES. 11 9 0 10 9804614 8691512 0 0 900000 0 14049350 14141346 0 0 14949350 14141346 0 0 10249997 9704792 506939 424171 0 0 0 2228627 821197 12985563 10950160 1963787 3191186 192055377 211021064 10434585 10603750 181620792 200417314 THE PRIMARY PURPOSE OF THE TRUST IS TO PROVIDE HEALTH BENEFITS TO ELIGIBLE RETIREES OF THE BLUE CROSS & BLUE SHIELD COMPANIES. 0 0 PROVIDED HEALTH BENEFITS TO ELIGIBLE RETIREES OF BLUE CROSS & BLUE SHIELD. TOTAL HEALTH BENEFITS PAID DURING THE YEAR WAS $9,704,792. 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 1 0 0 1 0 0 0 1 1 0 0 0 0 0 0 0 X 11 9 1 0 0 0 0 0 0 1 1 0 0 0 1 1 1 1 1 0 0 0 X TERRENCE J COONEY 3122976000 225 N MICHIGAN AVE CHICAGO IL 60601 ROBERT J KOLODGY COMMITTEE MEMBER 0.10 40.00 X 0 1037556 58951 THE NORTHERN TRUST TRUSTEE 40.00 0.00 X 62508 0 0 TIM HUCKLE COMMITTEE MEMBER 0.10 0.20 X 0 0 0 CHRISTOPHER BOOTH COMMITTEE MEMBER 0.10 10.20 X 0 0 0 MATT ALL COMMITTEE MEMBER 0.10 0.20 X 0 0 0 ERIN STUCKY COMMITTEE MEMBER 0.10 0.20 X 0 0 0 MIKE STOLLAR COMMITTEE MEMBER 0.10 0.20 X 0 0 0 DIANE GORE COMMITTEE MEMBER 0.10 0.20 X 0 0 0 MARK EL-TAWIL COMMITTEE MEMBER 0.10 0.20 X 0 0 0 CHUCK DIVITA COMMITTEE MEMBER 0.10 0.20 X 0 0 0 BRYAN CAMERLINCK COMMITTEE MEMBER 0.10 0.20 X 0 0 0 JOHN F GIBLIN COMMITTEE MEMBER 0.10 0.20 X 0 0 0 MICHAEL MIZEUR COMMITTEE MEMBER 0.10 0.20 X 0 0 0 MARK P STIMPSON COMMITTEE MEMBER 0.10 0.20 X 0 0 0 62508 1037556 58951 0 0 1 0 THE NORTHERN TRUST COMPANY PO BOX 803878 CHICAGO IL 60680 INVESTMENT MANAGEMENT & TRUSTEE 486679 1 7491693 3154961 4336732 50092259 43442606 6649653 6649653 6649653 14141346 0 9804614 4336732 9704792 424171 29782 62508 12000 TAXES INCURRED 716907 10950160 188364733 206896198 3690644 4124866 192055377 211021064 10405658 9990880 28927 612870 10434585 10603750 X 181620792 200417314 0 0 0 0 181620792 200417314 192055377 211021064 X 3191186 16650132 -1044796 X 0 1 X 1 0 0 INCOME TAXES PAYABLE 612870 612870 X 29746682 16650132 -1044796 15605336 14141346 0 14141346 10950160 0 10950160 0 10950160 PART X, LINE 2: U.S. GAAP REQUIRES EVALUATION OF TAX POSITIONS TAKEN BY THE TRUST AND RECOGNITION OF A TAX LIABILITY OR ASSET IF THE TRUST HAS TAKEN AN UNCERTAIN POSITION THAT MORE LIKELY THAN NOT WOULD NOT BE SUSTAINED UPON EXAMINATION BY THE IRS. IN 2018, THE TRUST ADMINISTRATOR RECEIVED CORRESPONDENCE FROM THE IRS UNDER SECTION 512(A)(3)(E)(I) OF THE CODE STATING THAT THE TRUST OWED ADDITIONAL TAX AND INTEREST FOR TAX YEARS 2015 AND 2016 AND PROPOSED TAX ADJUSTMENTS WHICH THE TRUST HAS NOW ACCEPTED. THE TRUST ADMINISTRATOR HAS ANALYZED THE TAX POSITIONS TAKEN BY THE TRUST AND HAS CONCLUDED THAT, AS OF DECEMBER 31, 2019 AND 2018, THERE ARE NO UNCERTAIN POSITIONS TAKEN OR EXPECTED TO BE TAKEN THAT WOULD REQUIRE RECOGNITION OF A TAX LIABILITY OR ASSET OR FINANCIAL STATEMENT DISCLOSURE, OTHER THAN THOSE PREVIOUSLY DESCRIBED. THE TRUST IS SUBJECT TO ROUTINE AUDITS BY TAXING JURISDICTIONS, HOWEVER THERE ARE CURRENTLY NO AUDITS FOR ANY TAX PERIODS IN PROGRESS OTHER THAN THOSE PREVIOUSLY DESCRIBED. PART XI, LINE 2D - OTHER ADJUSTMENTS: ADJUSTMENT TO BASIS OF SECURITIES (INCLUDING AMORTIZATION) -1,028,169. RETURN OF CAPITAL -16,627. 0 1 0 ROBERT J KOLODGY COMMITTEE MEMBER 0 631155 0 396900 0 9501 0 14000 0 44951 0 1096507 0 0 PART I, LINE 4B ROBERT KOLODGY PARTICIPATED IN A LONG-TERM INCENTIVE PLAN BUT DID NOT RECEIVE ANY DISTRIBUTIONS FROM THE PLAN IN 2019. FORM 990, PART VI, SECTION A, LINE 2 CERTAIN MEMBERS OF THE NATIONAL EMPLOYEE BENEFITS COMMITTEE ("COMMITTEE") SERVE TOGETHER ON THE BOARD OF BLUE CROSS AND BLUE SHIELD ASSOCIATION. ALL MEMBERS OF THE COMMITTEE ARE EITHER EMPLOYEES OF THE BLUE CROSS AND BLUE SHIELD ASSOCIATION OR ONE OF THE MEMBER PLANS. FORM 990, PART VI, SECTION B, LINE 11B FORM 990'S CONTENT AND SOURCE OF INFORMATION ARE REVIEWED BY SUBJECT MATTER EXPERTS INCLUDING, BUT NOT LIMITED TO, INTERNAL AND EXTERNAL TAX AND ACCOUNTING PROFESSIONALS AND INTERNAL LEGAL PERSONNEL, AND THE AUDITED FINANCIAL STATEMENTS ARE PRESENTED TO THE COMMITTEE THAT SERVES AS THE GOVERNING BODY BY THE INDEPENDENT AUDITORS. FORM 990, PART VI, SECTION B, LINE 12C BLUE CROSS BLUE SHIELD ASSOCIATION (BCBSA) MAINTAINS A COMPREHENSIVE CODE OF CONDUCT AND COMPLIANCE PROGRAM APPLICABLE TO ALL EMPLOYEES AND OFFICERS, INCLUDING THOSE WHO EITHER SERVE ON THE COMMITTEE (THAT GOVERNS AND ACTS FOR THE ORGANIZATION) OR ACT ON BEHALF OF THAT COMMITTEE. IN ADDITION, ALL EMPLOYEES, OFFICERS, AND DIRECTORS (INCLUDING THOSE WHO SERVE ON THE COMMITTEE OR ACT ON ITS BEHALF) ARE REQUIRED TO COMPLETE AN ANNUAL CONFLICT OF INTEREST FORM. THE BCBSA CHIEF AUDITOR AND COMPLIANCE OFFICER IS CHARGED WITH INVESTIGATING ANY ALLEGATIONS OF NON-COMPLIANCE WITH THE CODE OF CONDUCT, INCLUDING ANY COMPLAINTS REPORTED THROUGH THE ANONYMOUS HOTLINE MAINTAINED THROUGH AN INDEPENDENT ORGANIZATION. THE RESULTS OF THE COMPLIANCE PROGRAM'S EFFECTIVENESS ARE REPORTED TO THE AUDIT COMMITTEE OF THE BCBSA BOARD OF DIRECTORS ON AN ANNUAL BASIS. FAILURE TO ADHERE TO THE CODE OF CONDUCT MAY RESULT IN DISCIPLINARY ACTION, UP TO AND INCLUDING TERMINATION OF EMPLOYMENT. MOREOVER, COMMITTEE MEMBERS RECEIVE FIDUCIARY TRAINING FROM THE BCBSA CHIEF EMPLOYEE BENEFITS COUNSEL REGARDING THEIR FIDUCIARY DUTIES, INCLUDING THE ERISA FIDUCIARY CONFLICT OF INTEREST RULES. BCBSA'S CHIEF EMPLOYEE BENEFITS COUNSEL ALSO PROVIDES THE COMMITTEE WITH AN ANNUAL ASSESSMENT OF THE ORGANIZATION'S AND COMMITTEE'S LEGAL COMPLIANCE, INCLUDING COMPLIANCE WITH ERISA. AS EMPLOYEES OF VARIOUS BLUE PLANS, EACH COMMITTEE MEMBERS NOT EMPLOYED BY BCBSA IS SUBJECT TO ADDITIONAL CONFLICT OF INTEREST RESTRICTION UNDER POLICIES ADOPTED BY HIS OR HER EMPLOYER PLAN. FORM 990, PART VI, SECTION B, LINE 15 THE ORGANIZATION DOES NOT REQUIRE COMPENSATION POLICIES AS IT DOES NOT COMPENSATE ANY OFFICERS, MANAGEMENT OFFICIALS, OR KEY EMPLOYEES. FORM 990, PART VI, SECTION C, LINE 19 THE GOVERNING DOCUMENTS AND FORM 990 ARE MADE AVAILABLE TO PARTICIPANTS IN THE EMPLOYEE BENEFIT PROGRAMS FUNDED THROUGH VEBA UPON REQUEST TO THE VICE PRESIDENT, NATIONAL EMPLOYEE BENEFITS ADMINISTRATION, BLUE CROSS AND BLUE SHIELD ASSOCIATION, 225 N. MICHIGAN AVENUE, CHICAGO, IL 60601. FORM 990, PART XI, LINE 9: ADJUSTMENT TO BASIS OF SECURITIES (INCLUDING AMORTIZATION) -1,028,169. RETURN OF CAPITAL -16,627. BLUE CROSS BLUE SHIELD ASSOCIATION 225 NORTH MICHIGAN AVE CHICAGO IL 60601 135656874 VEBA ADMINISTRATIVE SUPPORT IL 501(C)(4) N/A N/A 0 BLUE CROSS & BLUE SHIELD OF WYOMING CONTRIBUTING EMPLOYER 0 ANTHEM INC & CONTROLLED AFFILIATES OTHER PARTICIPATING EMPLOYER 0 BLUE CROSS & BLUE SHIELD OF TENNESSEE & CONTROLLED AFFILIATES OTHER PARTICIPATING EMPLOYER 0 BLUE CROSS & BLUE SHIELD OF NORTH CAROLINA OTHER PARTICIPATING EMPLOYER 0 BLUE CROSS AND BLUE SHIELD OF ARIZONA & CONTROLLED AFFILIATES OTHER PARTICIPATING EMPLOYER 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 FORM 990, SCHEDULE R, PART V, LINE 2: DESCRIPTION OF TRANSACTIONS REFERRED TO IN RESPONSE TO LINES 1P AND 1S LINE 1P: AS PERMITTED BY ERISA SECTIONS 408(B)(2) AND 408(C)(2), PROGRAM ASSETS ARE DISBURSED TO REIMBURSE PROGRAM BENEFIT PAYMENTS, PROGRAM PREMIUMS AND PROGRAM ADMINISTRATIVE EXPENSES. LINE 1S: NONE OF THE PARTICIPATING EMPLOYERS MADE CONTRIBUTIONS IN 2019 TO FUND PROGRAM BENEFITS.