Final Regulations Released on Employer Shared Responsibility Requirements for 2015 and Beyond

Reform-Alert-Header-2014

On Feb. 10, the final regulations for the Employer Shared Responsibility provisions (also referred to as the “employer mandate”) under the Affordable Care Act were released by the Internal Revenue Service and Department of the Treasury.

These final regulations provide different types of safe harbors to employers in 2015, depending on the type of employer or plan offered. The triggers for the tax penalties also vary depending on the type and timing of the safe harbor option an employer may qualify for (and chooses to implement).

Key safe harbors for 2015 are outlined below:

Applicable large employers with 50 to 99 full-time equivalent employees may not be subject to the employer mandate requirements until the first day of their 2016 plan year.

An applicable large employer is not subject to tax penalties for any calendar month in 2015 (and for the portion of the 2015 plan year that falls in 2016 if it has a non-calendar plan year) if it meets all three major requirements and certifies that it qualifies for this safe harbor:

  1. An applicable large employer has at least 50 and no more than 99 full-time equivalent employees during 2014 so that it meets the workforce size requirements.
  2. There are no reductions to an employer’s workforce size or overall hours of service between Feb. 9, 2014 and Dec. 31, 2014.
    • However, reductions made due to “bona fide” business reasons are allowed. The regulations provide examples of “bona fide” reasons that include changes in the economic marketplace, sales of business divisions or other similar reasons.
  3. An applicable large employer must maintain the health coverage it previously offered between Feb. 9, 2014 through Dec. 31, 2015 (or on the last day of the 2015 plan year).

An employer will certify its eligibility requirements on designated IRS forms (1095-C for self-funded large employers and 1094-C for fully insured large employers) by Jan. 31, 2016. These forms have not yet been issued by the IRS.

Applicable large employers with calendar or non-calendar plan years and new employers may qualify for this safe harbor.

Percentage threshold to offer coverage is 70 percent for all applicable large employers

For all applicable large employers in 2015, including employers with 50 to 99 full-time equivalent employees that do not qualify for the safe harbor described earlier, the employer will be liable for tax penalties only if:

  1. The applicable large employer does not offer coverage to at least 70 percent of full-time employees and their dependents (unless the employer qualifies for the 2015 safe harbor for dependent coverage described later in this alert), and at least one of the full-time employees receives a premium tax credit to help pay for coverage on a Marketplace (Exchange); or
  2. The applicable large employer offers coverage to at least 70 percent of full-time employees and their dependents (unless the employer qualifies for the 2015 safe harbor for dependent coverage), but at least one full-time employee still receives a premium tax credit to help pay for coverage on a marketplace.
    • This may occur because the employer did not offer coverage to that employee or because the coverage that was offered to that employee was either unaffordable to the employee or did not provide minimum value.

This percentage threshold only applies for 2015. The percentage of employees that must be offered coverage to limit employer mandate liability increases from 70 to 95 percent in 2016.

Change in 2015 tax penalty calculation for employers with 100 or more full-time equivalent employees

An employer with 100 or more full time equivalent employees during 2014 is still subject to the tax penalty in 2015 for not offering health coverage to at least 70 percent (will increase to 95 percent in 2016) of its full-time employees and their dependents. This means a tax penalty will be assessed if the employer (a) does not provide health coverage at all, or (b) the employer does not offer coverage to at least 70 percent of its full-time employees and at least one full-time employee receives a premium tax credit on the Marketplace.

For 2015, this tax penalty calculation is different. The tax penalty will be calculated by subtracting 80 full-time employees (instead of 30):

  • 2015: Annual penalty calculation is $2,000 x (number of full-time employees minus 80)
  • 2016: Annual penalty calculation is $2,000 x (number of full-time employees minus 30)

This safe harbor is only available for each calendar month in 2015 (and for any months that fall in 2016 for a 2015 plan year). For example, a group with a July 1 plan year would be able to use the tax penalty calculation above for July 2015 through June 2016.

Applicable large employers with non-calendar year plans

An applicable large employer may receive relief from tax penalties for any month prior to the first day of the 2015 plan year if it meets the following requirements:

  1. Maintained a non-calendar plan year as of Dec. 27, 2012 and not changed its plan year after this date to begin later.
  2. Meets one of the following three tests:
    1. offers affordable coverage meeting minimum value requirements to its eligible employees (under the terms of the non-calendar plan as of Feb. 9, 2014) by the first day of the 2015 plan year
    2. covered at least 25 percent of all employees on any date between Feb. 10, 2013 through Feb. 9, 2014, or offered coverage to at least 33 percent of all employees during the most recent open enrollment period ending before Feb. 9, 2014
    3. covered at least 33 percent of its full-time employees as of any date between Feb. 10, 2013 through Feb. 9, 2014, or offered coverage to at least 50 percent of full-time employees during the most recent open enrollment period ending before Feb. 9, 2014
  3. Offers coverage to at least at least 70 percent of full-time employees and their dependents (unless the employer qualifies for the 2015 safe harbor for dependent coverage) as of the first day of the 2015 plan year.

Note that the relief does not apply to employees also eligible for or covered under a calendar year plan offered by the applicable large employer.

Dependent coverage safe harbor

Another safe harbor is available for applicable large employers with 2015 plan years where dependent coverage:

  1. Is not offered,
  2. Does not meet minimal essential coverage requirements, or
  3. Is offered to some, but not all, dependents

This applies to employers that take steps during 2015 (or the 2015 plan year) to extend coverage to dependents that were previously not offered coverage during the 2013 and/or 2014 plan years. This is not an option for employers that offered, but then dropped, dependent coverage during the 2013 and/or 2014 plan years.

Under the employer mandate a dependent is a biological and/or adopted child of an employee who has not reached age 26. This excludes foster children and stepchildren (only for the employer mandate). It also excludes an employee’s spouse being considered as a dependent.

Points for clarification

The employer shared responsibility provision does not apply to employers with less than 50 full-time equivalent employees.

Employers affected by the employer mandate are encouraged to seek their own legal counsel as each employer’s situation will be unique to the type of safe harbor that an employer may qualify for.

More information can be found at:

Additional guidance is pending.

 

*Blue Cross Blue Shield of Michigan is not responsible for the content or practices of the destination website.

The information in this document is based on preliminary review of the national health care reform legislation and is not intended to impart legal advice. The federal government continues to issue guidance on how the provisions of national health reform should be interpreted and applied. The impact of these reforms on individual situations may vary. This overview is intended as an educational tool only and does not replace a more rigorous review of the law’s applicability to individual circumstances and attendant legal counsel and should not be relied upon as legal or compliance advice. As required by US Treasury Regulations, we also inform you that any tax information contained in this communication is not intended to be used and cannot be used by any taxpayer to avoid penalties under the Internal Revenue Code.

Tagged , , , , , , , , , , , , , , , , , , , , ,

Final regulations released on Employer Shared Responsibility requirements for 2015 and beyond

Reform-Alert-Header

On Feb. 10, 2014, the Treasury Department and the Internal Revenue Service released final regulations for the Employer Shared Responsibility provisions (also referred to as the employer mandate) under the Affordable Care Act.
An applicable large employer that, for a calendar month, does not offer its full-time employees health coverage that is affordable and provides minimum value may be subject to the assessable payments (tax penalty) if a full-time employee enrolls for that month in a qualified health plan (QHP) through an Exchange and receives a premium tax credit.
These requirements were originally effective beginning Jan. 1, 2014, but in July 2013, the assessable payments were delayed by one year.
These final regulations issued yesterday provide additional transition relief to employers and clarify or confirm guidance that was been previously issued.
Who does this apply to?
In general, the employer mandate applies to applicable large employers with 50 or more full-time equivalent employees. However, there is a transition period that will phase in this requirement.
Starting on Jan. 1, 2015, the employer mandate will apply to applicable large employers with 100 or more full-time equivalent employees. In 2015, the mandated requirements will not apply to employers with fewer than 100 full-time equivalent employees.
In 2016, the employer shared responsibility provisions will apply to employers with 50 or more full-time equivalent employees.
Is there a phase-in period for the number of employees that must be covered to avoid an assessable payment?
Yes. In 2015, an applicable large employer potentially will be subject to a penalty if it does not cover at least 70 percent of its full-time equivalent employees.
In 2016, applicable large employers will be required to cover at least 95 percent of their full-time employees.
Is there a safe harbor for the requirement that employers offer coverage to employees’ dependents?
Yes. Employers that currently do not offer coverage to dependents (and did not offer coverage to dependents in 2013) are generally permitted to transition to offering such coverage in 2016.
When are these requirements effective?
Generally, the requirements are effective beginning on Jan. 1, 2015. For those applicable large employers with non-calendar plan years that begin after Jan. 1, 2015, the final rule includes a safe harbor that generally will make the mandate effective beginning with the first day of their 2015 plan year.
More information can be found at:
Internal Revenue Service FAQ*
Final regulations*
Treasury Department fact sheet*

*Blue Cross Blue Shield of Michigan is not responsible for the content or practices of the destination website.

The information in this document is based on preliminary review of the national health care reform legislation and is not intended to impart legal advice. The federal government continues to issue guidance on how the provisions of national health reform should be interpreted and applied. The impact of these reforms on individual situations may vary. This overview is intended as an educational tool only and does not replace a more rigorous review of the law’s applicability to individual circumstances and attendant legal counsel and should not be relied upon as legal or compliance advice. As required by US Treasury Regulations, we also inform you that any tax information contained in this communication is not intended to be used and cannot be used by any taxpayer to avoid penalties under the Internal Revenue Code.

Tagged , , , , , , , ,

Legislative Update – 2014 Eligible Personal Property Tax Exemption

For the 2014 tax year, legislation was passed that exempts certain “Eligible Personal Property” from taxation. Businesses that own personal property of less than a true cash value of $80,000 ($40,000 assessed value) may be entitled to an exemption for the 2014 tax year. To qualify for the Eligible Personal Property exemption, the qualifying business MUST FILE Form 5076 with the local assessor by February 10, 2014. If the business fails to file the Form 5076, the local assessor is obligated to place an assessment, even if the assessor’s estimate is less than the $80,000 true cash value threshold.

Personal Property Statements were mailed to taxpayers shortly after January 1, 2014. If you have questions regarding this issue, please contact your local assessor.

Tagged , , , , , , , , ,

Department of Health & Human Services issues guidance for the 2015 benefit year

Reform-Alert-Header

On Nov. 25, 2013, the Department of Health and Human Services (HHS) issued guidance proposing changes to the annual open enrollment period and the qualified health plan (QHP) certification deadlines for the 2015 benefit year.

For the 2015 benefit year, the proposed annual open enrollment period is Nov. 15, 2014 through Jan. 15, 2015:

Enroll by Dec. 15, 2014
For Coverage Effective January 1, 2015

Enroll December 16, 2014 through January 15, 2015
For Coverage Effective February 1, 2015

Qualified individuals already enrolled in a QHP through the Marketplace in 2014 who maintain the same eligibility would have their coverage continue into 2015, but may choose to select new coverage at any time during the annual open enrollment period.

The annual open enrollment period for benefit years on or after 2016 is still Oct. 15 through Dec. 7 of the preceding calendar year, with coverage effective the first day of the following benefit year.

If finalized, the Marketplace is expected to delay 2015 QHP certification dates by at least one month.

HHS is currently seeking comments.

Where can I find more information?

Blue Cross Blue Shield of Michigan will continue to monitor and advise when new information is received. Please visit our Reform Alerts webpage for the latest health care reform updates.

The information in this document is based on preliminary review of the national health care reform legislation and is not intended to impart legal advice. The federal government continues to issue guidance on how the provisions of national health reform should be interpreted and applied. The impact of these reforms on individual situations may vary. This overview is intended as an
educational tool only and does not replace a more rigorous review of the law’s applicability to individual circumstances and attendant legal counsel and should not be relied upon as legal or compliance advice. As required by US Treasury Regulations, we also inform you that any tax information contained in this communication is not intended to be used and cannot be used by any taxpayer to avoid penalties under the Internal Revenue Code.

Tagged , , , , , , , ,

Federally-facilitated Marketplace enrollment period extended one week

Reform-Alert-Header

The Department of Health and Human Services (HHS) advised Friday, Nov. 22, 2013, individuals will have an extra week to enroll in coverage effective Jan. 1, 2014. The delay is to account for technical issues experienced with the healthcare.gov website. The original Dec. 15 deadline for people to apply for coverage effective Jan. 1 has been extended to Dec. 23.

The President’s announcement came in response to concerns expressed by individuals and groups who had received notification that their current plan would be discontinued because it was not compliant with Affordable Care Act requirements.

The delay does not change the 2014 open enrollment period which began Oct. 1, 2013, and runs through March 31, 2014.

For 2015 coverage, HHS announced applicants can sign up starting Nov. 15, 2014, rather than Oct. 15, 2014, and have until Jan. 15, 2015, rather than Dec. 7, 2014, to complete the process.

The extension will allow the federally run Marketplace more time to prepare for the next open enrollment period and allow insurers to make appropriate rate decisions.

Where can I find more information?

More information can be found at healthcare.gov.*

*Blue Cross Blue Shield of Michigan is not responsible for the content or practices of the destination website.

The information in this document is based on preliminary review of the national health care reform legislation and is not intended to impart legal advice. The federal government continues to issue guidance on how the provisions of national health reform should be interpreted and applied. The impact of these reforms on individual situations may vary. This overview is intended as an educational tool only and does not replace a more rigorous review of the law’s applicability to individual circumstances and attendant legal counsel and should not be relied upon as legal or compliance advice. As required by US Treasury Regulations, we also inform you that any tax information contained in this communication is not intended to be used and cannot be used by any taxpayer to avoid penalties under the Internal Revenue Code.

Tagged , , , , , , , , , , ,

Affordable Care Act requires new taxes and fees

Health Care Questions

To help finance health care reform initiatives created under the Affordable Care Act, the federal government established new taxes and fees that impact health insurers and customers. The Blues are committed to helping customers understand what the taxes and fees are for and what they will cost.

Regardless of the customer’s renewal or plan date, the Blues will begin billing fully insured customers for five ACA taxes and fees starting with Jan. 1, 2014 invoices.

Self-funded customers are responsible for calculating and sending ACA tax and fee payments to the federal government. However, we will bill self-funded group customers that purchase stop-loss coverage from Blue Cross for the Federal Insurance Premium Tax. The tax will be assessed on the stop-loss coverage only.

Note: Not all federal and state taxes apply to all segments. We will bill customers for the applicable taxes and fees.

Federal-Taxes-and-Fees-Table

State taxes

There are also two state taxes, the Michigan Claims Tax Assessment and the State Insurance Premium Tax. The Michigan Claims Tax Assessment became effective on Jan. 1, 2012. The Blues will continue to bill fully insured and self-funded groups as well as individuals for this assessment.

The State Insurance Premium Tax will become effective on Jan. 1, 2014. The Blues, like many other health plans, are subject to the State Insurance Premium Tax in lieu of the corporate income tax. The State Insurance Premium Tax does not apply to Blue Care Network plans or self-funded customers.

However, we will bill self-funded group customers that purchase stop-loss coverage from Blue Cross for the State Insurance Premium Tax. The tax will be assessed on the stop-loss coverage only for self-funded customers.

Online tax estimator
Your 2014 quotes, renewals and bills will include the amount of federal and state taxes you will need to pay. If you want a detailed breakdown of your taxes and fees, use our taxes and fees estimator tool at bcbsm.com. It now includes the State Insurance Premium Tax and the ACA federal taxes and fees. (The tool previously only estimated the Michigan Claims Tax Assessment.)

The estimator tool breaks down the taxes presented on the quote, renewal or bill and provides estimated amounts for each tax. It’s important to note that the tool provides estimates, not actual amounts of taxes and fees. And, it does not apply to Medicare Advantage individual and group customers.

To access the tool:

  1. Go to bcbsm.com.
  2. Go to Help and click on Calculators and Tools.
  3. Under Health care reform, click on Health Insurance Tax Estimator.

BCBS-Pantone-Blue

Blue Cross Blue Shield of Michigan and Blue Care Network of Michigan are nonprofit corporations and independent licensees of the Blue Cross and Blue Shield Association.

Tagged , , , , , , , , , ,

Marketplace Eligibility Provisions Amended in New Proposed Rule – a ReformAlert from Blue Cross Blue Shield

The Program Integrity: Marketplace, SHOP, Premium Stabilization Programs and Market Standards proposed rule released on June 14 amends two provisions regarding Individual Marketplace eligibility.

  • Incomplete Applications. The proposed rule recognizes there will be applicants who submit incomplete applications. The Marketplace will notify the applicant of missing information needed to make an eligibility determination. The Marketplace will determine a time period, at least 15 days but no more than 90 days, for applicants to provide that missing information.
  • Verification of Minimum Essential Coverage. The proposed rule makes largely technical corrections, and also adds a new paragraph enabling HHS to provide a response to the Marketplace in order to verify information about eligibility and verify enrollment in minimum essential coverage public programs other than Medicaid, Children’s Medicaid (CHIP) and the Basic Health Programs — such as the Veterans Health Administration, TRICARE and Medicare.

Where can I find more information?
More information can be found in the proposed rule (PDF).*

BCBS-Pantone-Blue

*Blue Cross Blue Shield of Michigan is not responsible for the content or practices of the destination website.

 

The information in this document is based on preliminary review of the national health care reform legislation and is not intended to impart legal advice. The federal government continues to issue guidance on how the provisions of national health reform should be interpreted and applied. The impact of these reforms on individual situations may vary. This overview is intended as an
educational tool only and does not replace a more rigorous review of the law’s applicability to individual circumstances and attendant legal counsel and should not be relied upon as legal or compliance advice. As required by US Treasury Regulations, we also inform you that any tax information contained in this communication is not intended to be used and cannot be used by any taxpayer to avoid penalties under the Internal Revenue Code.

Tagged , , , , , ,

Affordable Care Act: Revised Paper Applications for Employers and Employees – a post from Blue Cross Blue Shield of Michigan

The Affordable Care Act (ACA) requires the Center for Medicare and Medicaid Services (CMS) to develop and provide to each state a single, streamlined application for (Small Business Health Options) SHOP enrollment. Alternatively, states may elect to develop and use their own application, subject to approval by CMS, but Michigan is currently not developing its own applications. Draft applications for employers and employees, including logic for the online applications, were initially proposed in January 2013.

On May 31, 2013, CMS released revised paper applications for employers and employees. Many of the changes to the paper application were clarifications in the directions, including the addition of a section to help employers determine if their business may be eligible. CMS also strengthened the language regarding providing false information on the application and provided employees with the opportunity to opt out of dental coverage. You can view the revised applications by following the links provided below.

The SHOP also changed the follow-up deadline and now anticipates following up within one to two weeks of application submission, instead of three to four weeks. CMS does not promise to make a decision on eligibility within that timeframe, but states that employers and their employees will get information about the next steps to complete for health coverage through the SHOP.

Employers and their employees will be able to submit an application for the SHOP online, using a paper application, over the phone through an agent or broker, or in person through an agent, broker, or navigator. In most cases, CMS expects that small employers will be able to receive a real-time eligibility determination when applying online. Coverage effective dates may be earlier for applications filed online than for those filed on paper.

Where can I find more information?
Revised applications can be found here: Application for Employers and Application for Employees.*

*Blue Cross Blue Shield of Michigan is not responsible for the content or practices of the destination website.

BCBS-Pantone-Blue

The information in this document is based on preliminary review of the national health care reform legislation and is not intended to impart legal advice. The federal government continues to issue guidance on how the provisions of national health reform should be interpreted and applied. The impact of these reforms on individual situations may vary. This overview is intended as an educational tool only and does not replace a more rigorous review of the law’s applicability to individual circumstances and attendant legal counsel and should not be relied upon as legal or compliance advice. As required by US Treasury Regulations, we also inform you that any tax information contained in this communication is not intended to be used and cannot be used by any taxpayer to avoid penalties under the Internal Revenue Code.

Tagged , , , , , , ,

Health Care Reform: a Look at the Basics from Blue Cross Blue Shield Blue Care Network of Michigan

Health Care Questions

Health care is evolving and there’s a lot of information to wade through. So we’re here to help you get to the bottom line.

How does health care reform impact you and your employees?

We want you to know your options so you can make good decisions about your company’s health care coverage. We’ve started a series that provides you with easy-to-understand information about the Affordable Care Act and its requirements.

So be sure to look for the health care reform articles in each issue. In this article, we begin with the basics.

Why health care reform and why now?

Health care reform is driven by a number of factors:

  • Currently, we spend more than 17 percent of every earned dollar on health care.
  • Almost half of all Americans have chronic diseases — diabetes, asthma, heart and cardiovascular disease — that currently cause about 70 percent of all U.S. deaths.
  • Many people are not insured or don’t have as much insurance as they need.

These are huge issues. Congress passed the health care reform law as the first step in addressing them.

The Patient Protection and Affordable Care Act was signed into law on March 23, 2010. The companion bill, the Health Care and Education Reconciliation Act, was signed on March 30, 2010. Together, these two bills constitute the national health care reform law, known as the Affordable Care Act.

Beginning in 2014, U.S. citizens and legal residents will be required to have health insurance — whether they purchase it on their own, get it through an employer or are covered by a government program such as Medicaid or Medicare. The law requires everyone to have a standard set of basic medical benefits covered in his or her plans. The Affordable Care Act also introduces the Health Insurance Marketplace.

What is the Health Insurance Marketplace?

Starting on Oct. 1, 2013, eligible individuals may buy health insurance through the federal Health Insurance Marketplace. If your employees do not get insurance through your business, their parents or a government-sponsored program, the Marketplace is where they can go to buy insurance if they meet the eligibility requirements.

Think of Expedia.com, where you can compare potential purchases in one place. The Marketplace is meant to give people a place to compare and understand health plans from different companies so that individuals can choose the plan that’s best for them. The Marketplace will also be available by phone and, in certain areas, walk-in centers for people who do not have Internet access.

Preparing your business and your employees

In upcoming issues, we’ll talk about your role in complying with the law — the decisions you need to make and the notices you need to provide your employees. We’ve also created a resource for you and your employees at healthcarereformbasics.com.

This article was provided courtesy of

BCBS-Pantone-Blue

Tagged , , , , , , , , ,

Saginaw River Emergency Dredging

The U.S. Army Corps of Engineers approved $1.2 million in emergency dredging to re-open the Saginaw River to shipping. This year’s heavy spring rains sent sediment down the river and restricted shipping to and from businesses in Saginaw County and the Region. Prior to the excessive rain, the Saginaw River turning basin was in the best condition it has been in over 30 years. However, the U.S. Army Corps of Engineers determined that as a direct result of the recent flooding, the basin is once again filled with silt, to the point that it is closed to shipping traffic.

Dock owners, along with the Saginaw County Chamber of Commerce and Saginaw Future Inc., asked Congressional and State Legislative Delegations to support decisive action for emergency dredging. In addition, six State Department Heads encouraged immediate assistance and the Great Lakes Bay Regional Alliance also supported the funding request. Quick assistance was needed, because the actual dredging could not take place until 60 days after approval by the Army Corps of Engineers.

“We are very appreciative of the Army Corps of Engineers decisive action to dredge the Saginaw River and reopen shipping to vital businesses in Saginaw and the Great Lakes Bay Region,” said U.S. Senator Carl Levin. “Goods shipped on the river include coal that powers electric generators, cement and aggregate that is needed to complete the I-75 highway resurfacing project, and limestone, potash, grain and other raw materials to supply businesses along the river.”

There was a major concern that if the Saginaw River Basin was not reopened, the Region and the State could lose the river for commerce, much like the Missouri River was lost after large floods 10 years ago. The river is a major Michigan shipping route listed as the second busiest port for exports.

“The Saginaw River is a crucial part of our economic infrastructure and must be maintained,” said Michigan State Senator Roger Kahn. “The river is a unique asset that connects Saginaw County and the Great Lakes Bay Region to the rest of the world.”

The Corps of Engineers has already advertised the emergency dredging contract and are expecting to award the project on or before June 28, 2013, with the actual dredging starting in July.

Saginaw County Chamber of Commerce President Bob Van Deventer stated, “It was amazing how quickly leaders and organizations came together to support this much-needed project. We want to thank Senators Stabenow and Levin and Congressmen Kildee and Camp as well as our State Legislative Delegation, Senators Kahn, Moolenaar and Green and Representatives Cotter, Stamas, Kelly, Brunner and Erwin Oakes. Governor Rick Snyder, the Michigan Economic Development Corporation and the Great Lakes Bay Regional Alliance also provided much needed support.”

William G. Webber, President of Sargent Docks and member of the Saginaw River Alliance stated, “We are so grateful to the Saginaw Chamber and Saginaw Future for partnering with the Saginaw River Alliance to encourage the Army Corps of Engineers to award the emergency dredging funds. This could have been a disastrous outcome, but instead, we will be able to open the River to commerce once again.”

Tagged , , , , , , , ,
Follow

Get every new post delivered to your Inbox.

Join 1,976 other followers

%d bloggers like this: