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Saturday, November 24, 2012

Michigan Health Care Claims Tax Fight -- Additional Rounds Ahead

It�s been a tough fight thus far in opposition to the Michigan Health Insurance Claims Assessment Act, which imposes a one percent (1%) assessment on all health care payers, including self-insured employers and certain business partners, for medical services rendered to Michigan residents in the state of Michigan.

As this blog has previously reported, business groups in Michigan signed off on the legislation last year noting it was part of a larger budget deal that was not as bad as possible alternatives.   ERISA preemption concerns were outweighed by the belief that self-insured employers could absorb the new tax without much disruption. 

Then in August of this year, a federal district court in Michigan dismissed an ERISA preemption lawsuit, which contended that the administrative obligations imposed by the Act are unlawful.    

Game over?  Well, not exactly.

An appeal of the District�s court ruling has just by filed with the Sixth Circuit Court Appeals and incorporates some very strong arguments to justify a reversal.  And this time, the self-insurance industry will have an unlikely ally in this legal fight � organized labor. 

What has not been widely recognized is that the tax applies to self-insured Taft-Hartley plans and the ERISA preemption argument is even stronger as it relates to these plans.   So it is a positive development that at least two Taft-Hartley plans are expected file amicus briefs next week. 

But while more pressure is being applied in Federal Court, things are heating back up in the Michigan State Legislature to make the tax significantly more onerous.

The Act was structured based on the assumption that it would raise $400 in annual revenue from all payers.   Of course, government budgeting is often suspect and Michigan bureaucrats have lived up to this reputation.  Through the first half of 2012, the state collected only $109 million from the health claims tax, which means the annualized estimate is short nearly $200 million.

So it should not come as any surprise that the Michigan Legislature is now considering a proposal during a lame duck session to significantly hike the tax.  SB 1359, introduced earlier this month, would allow for an unlimited and variable rate on the claims tax so that it would float up and down to ensure that the tax generates $400 million annually.  The bill would also eliminate the proportional credit/refund provision should the tax collect more than the $400 million target amount.

Interestingly, state business groups who provided tacit approval to the tax last year have now launched an aggressive lobbying effort to defeat the proposed 2.0 version.   We�ll see if labor groups join the cause. 

While it�s certainly encouraging that there is strong push back against SB 1359, the opposition remains focused on the economic argument.    Yes, this is clearly important but arguably not as important as the ERISA preemption issue.

We�ll concede that the most self-insured employers in Michigan have figured out how to comply with this new tax obligation, but multi-state employers will also tell you that if other states implement a similar tax scheme this would greatly complicate compliance efforts.  In turn, this could make the self-insurance option much less attractive � a particularly troubling development in the post-ACA world where self-insurance offers a critical safe harbor.

Look around.  Most states have budget challenges, especially as it relates to health care obligations.  If the Michigan tax withstands legal and legislative challenges then we should not be surprised if other states attempt the same approach.

So the stakes are high in Michigan as it is now ground zero in the ERISA preemption fight.

Saturday, November 17, 2012

Captives & Dodd-Frank -- Hitting the Right Target

The recent announcement of an industry coalition to push for federal legislation clarifying that the Nonadmitted and Reinsurance Reform Act (NRRA), included as part of the Dodd-Frank law, does not apply to captive insurance companies certainly sounds like a positive initiative.  But despite good intentions, this blog is skeptical that it will acheive the desired result.

We have actually been tracking this issue for some time and is aware of discussions that have taken place with key congressional sources regarding the viability of a possible legislative fix (two conversations as recent as yesterday).  The consensus is that it could be done technically, but DC politics dictate that such an effort would be a heavy lift.

The political reality is that neither Democrats nor Republicans have the appetite to open up the Dodd-Frank Law for any changes at this point. 

Truth be told, congressional Republicans don�t want to do anything to help the law actually work, as this was a highly partisan piece of legislation, much like the Patient Protection and Affordable Care Act.  The only way Republicans would be motivated to even consider amending the legislation is if such action would substantively lessen the administrative burdens on the banking industry and provide certainty to the business community, especially small business.

 Democrats, for their part, will be resistant to �technical amendment� legislation even if they support it in principle for fear that it would become a legislative vehicle where additional amendments would be grafted on with the intent of watering down the law.

And neither party wants to come back under fire from the powerful financial services industry lobby, which would surely happen if Dodd-Frank is opened back up � even for so-called technical fixes.   

But just for the sake of argument, let�s assume that legislation is introduced and some co-sponsors are lined up.  Does that mean success is any more likely?  Probably not.  To understand this assessment, we need to talk about the relative political power of interest groups in DC. 

While many of the larger lobbying organizations active in DC have the ability to block and/or shape legislation, there are far fewer who have enough political juice to get their own special interest legislation passed through Congress, no matter how limited. To be blunt, the captive insurance industry simply does not fit into this latter, more exclusive group.   

Finally, the country�s biggest captive domiciles simply do not have powerful congressional delegations with regard to insurance-related issues, which could potentially offset the deficiencies and complications described above.  That is not to say these members of Congress would not be forceful advocates, they simply are not positioned to move legislation envisioned by proponents of this approach.

So does all this mean that there will never be clarity relative to whether the NRRA applies to captives?  Well, it may not to come from Congress for the reasons we just explained, but it may come from federal regulators as part of the Dodd-Frank rule-making process. 

In fact, this avenue is now being actively explored by self-insurance industry lobbyists.   This strategy can best be described as a �surgical strike,� as opposed to an expensive and pro-longed �land war,� which the congressional route would surely become. 

We�ll see if the political operatives now engaged with the regulators can hit the target.  But at least an arguably clearer path has been identified.

 

 

 

 

 

 

Tuesday, October 16, 2012

Packaging Health Plan Fee Details for a Post-Election Launch

Self-insured employers have been waking up in recent weeks and months to the reality that they will soon be hit with new fees to finance a transitional reinsurance program provided for the in the Affordable Care Act (ACA).  But they are likely going to have to wait on the details until after the November elections.

As a quick refresher, the fees will be earmarked to capitalize reinsurance facilities in each state that serve as financial backstops for health insurance companies which offer individual coverage plans through public health insurance exchanges slated to come on-line in 2014.  Health insurance companies will also be subject to this fee.

What has caused some confusion is that the statute and a pre-curser rule finalized earlier this year references that third party administratorson behalf of self-insured plans will be responsible for paying the fee.   In private meetings over the summer, regulators clarified that it was not the intent that TPAs be financially liable for these fee, but rather they will be expected to assist in the collection of these fees from their clients.  Those details, along with the specific fee amounts, are still under wraps.

This blog has learned that an increasing number of large self-insured employers have been complaining directly to senior White House officials that the fee is fundamentally unfair because it helps to support the profitability health insurance companies, with no direct benefit for employers.  Responses have ranged from �we hear you but there is nothing we can do� to �there should be no complaining now because you (the employer community) signed off on this ACA provision during the legislative process.�

The former response is expected, but the latter response deserves some fact checking.

According to a source directly involved with drafting this section of the ACA, there is an interesting back story that is not widely known.  When legislative language was being developed, Democratic drafters did not understand the difference between independent TPAs with insurance company owned ASOs and did not understand that ASOs are typically separate business entities from their insurance company parents.

The reason why this is important is because ACA legislative drafters recognized that it did not make sense to impose fees on self-insured plans to subsidize insurance companies but they figured by referencing TPAs they would exclusively tap the fully-insured marketplace on the assumption that all TPAs were owned by insurance companies.

Only later in the legislative drafting process did they come to understand that many self-insured employers had no insurance company connection.  But by that time there was no turning back and there was no alternative to collecting the necessary revenue � all self-insured employers were going to have to pay.  No wonder that that the regulators have been slow with details on how this is all going to work.

So this brings back to the timing of when these details will be published.  Clearly if the Administration thought that employer community was going to be happy with the new rules, they would be released prior to Election Day.  But the best intel suggests that the proposed are done and are sitting right now at the Office of Management & Budget (OMB) awaiting a green light for release, likely shortly after election day.

The one positive detail is that the rules will be coming out in proposed form, so there will be an opportunity for formal stakeholder input -- just another thing to look forward to as we enter the holiday season.

Monday, October 15, 2012

Michigan Health Care Claims Tax May Just Be The Opening Bid

This blog has previously reported about the one percent health care claims tax that the state of Michigan has imposed on all payers, including self-insured group health plans.  We have also commented on the refusal of most within the employer community to support a legal challenge to the law, which should be preempted by the Employee Retirement Income Security Act (ERISA).

While one prominent Michigan employer has privately been a big financial supporter of this self-insurance legal defense initiative, the state�s largest employer organizations, as well as at least one major national association focused on ERISA preemption issues have been on the sidelines.

Now, it�s probably unrealistic to expect that the average self-insured employer will take the time to think about the longer term implications of ERISA preemption erosions.  Significant as these implications are, those employers are more concerned about the immediate financial implications.

 Fair enough.  Let�s talk about this shorter term perspective. 

 We have just learned from a very reliable source that the revenue collected so far this from health claims tax is much lower than projected -- so much lower, in fact, that the state Legislature will likely consider a proposal to raise it early next year.

 For employers who ran the numbers and determined that they could absorb a one percent tax, they should get ready to do a new set of calculations, perhaps on a yearly basis going forward, should a federal appeals court not strike down the law.  At some point it would seem that this health care tax could become an important factor as employers consider whether self-insurance is as cost effective as it otherwise would be,

 And in case you think this issue is contained to Michigan, think again.  Other cash-strapped states are watching how things play out in Michigan and at least some are likely to follow-suit if they believe such action will go unchallenged.

 When a camel gets its nose under the tent the occupants should not be surprised that the damage often cannot be contained.  For self-insured employers with workers in Michigan, they may soon learn this important lesson.

 

 

 

 

 

Sunday, October 14, 2012

Stop-Loss Regulation and the Coming Zombie Apocalypse

Key regulatory officials made some interesting comments about their interest in self-insured health plans utilizing stop-loss insurance at an American Bar Association event last week in Washington, DC

 Phyllis Borzi, assistant secretary at the U.S. Department of Labor, said her agency is working on two ACA-required studies, one on wellness that is due in 2014 and an annual report to Congress on self-insured plans.

 �To try and help get information on self-insured plans, a couple of things have happened. Probably most recently what we asked for was we put out a tri-agency request for information (RFI),� Borzi said.

 George Bostick, benefits tax counsel at the U.S Treasury Department, said the RFI �produced a number of paranoid responses,� but Borzi then assured the audience that there were no ulterior motives to the RFI.

 �It is what it is. We don't have enough information, we think.. It's not like we have some hidden agenda, pro- or anti-stop-loss; we just want to find out what's going on out there,� Borzi said.

 Another panelist, Amy Turner, senior adviser and special projects manager in EBSA's Office of Health Plan Standards and Compliance Assistance, echoed Ms. Borzi's comments about the departments needing more information on stop-loss insurance and wanted feedback from a �broad group of stakeholders.�

 The departments are sifting through the comment letters responding to the RFI, but Turner said not to expect any stop-loss guidance in the near future.

 �To the extent that some people maybe saw the RFI and thought, �Oh my goodness! Is something like the zombie apocalypse going to happen?' I think we're just working on the comment letters. I wouldn't expect any major guidance from the departments very quickly on this,� Turner said.

 This blog will give Ms. Turner the benefit of the doubt that a zombie apocalypse is probably not in the offing regardless of any further regulatory action that may be taken.

 That said, the regulators will have to forgive the �paranoia� expressed by self-insurance industry stakeholders.  After all, the current administration has proven to be very adept at sidestepping normal legislative procedures and inclined to give the green light to regulatory agencies to test the bounds of statutory authority when political needs arise.

 Speaking of political needs, it�s worth reminding everyone of how the regulators explained the reason for the RFI.  The following is an excerpt from the RFI introduction:

 It has been suggested that some small employers with healthier employees may self-insure and purchase stop-loss insurance with relatively low attachment points to avoid being subject to certain consumer protection requirements while exposing themselves to little risk.  This practice, if widespread, could worsen the risk pool and increase premiums in the fully-insured small group market, including the in the Small Business Health Options Program (SHOP) exchanges that begin in the 2014.

 If, in fact, the regulars reach these same conclusions, is it reasonable to believe they will simply sit on their hands?  We�ll be sure to keep an eye out for zombies as these developments continue to play out just in case.

Friday, August 31, 2012

The Summer of Stop-Loss

While this blog took the summer off, we have been keeping a close eye on the numerous developments related to stop-loss attachment point regulation.  Now that most of these developments have slowed down, at least for now, some exclusive reporting and commentary should be useful as those in the self-insurance industry (including those involved with employee benefit captives) take a collective breath.

 Pushed and prodded by a collection of health care reform advocates, federal regulators invited interested parties to submit written comments regarding the smaller insured group health plans facilitated by stop-loss insurance with �low� attachment points.

 About 150 comment letters have been submitted to date and the talking points are largely predictable. 

For the critics of self-insurance, the usual canards are widely repeated.  This request for information (RFI) process signaled a clear focus on self-insurance unlike anything that has been seen in recent years.  But the path forward remains unclear.

 That�s because the Affordable Care Act does not provide any explicit statutory authority for regulators to promulgate new rules relating to stop-loss insurance arrangements�yet that may not preclude action that could achieve the same objective.

 The HHS, DOL and/or Treasury Department (tri-agencies) could potentially rely on their general rule-making authority under ERISA or the Public Health Services Act, to play with definitions or to engage in other revisionist rule-making mischief.   The most likely scenario is that a new definition of a self-insured group health plan is crafted based on risk retention/risk transfer arrangements � thereby allowing the feds to indirectly regulate stop-loss insurance.

 So how serious is this potential threat?   The answer is complicated.

 In a private meeting with self-insurance industry representatives over the summer, a senior DOL official downplayed the prospects that any action is imminent or even likely, explaining that they felt the RFI was necessary for the agencies to get a better understanding of how the self-insurance marketplace operates in the real world.

 But conspicuously absent from the meeting, despite previously confirming their attendance, were senior HHS officials involved with the stop-loss RFI process.  This was notable because it is believed that HHS has the most aggressive regulatory agenda when it comes to self-insurance.  The Treasury Department was represented at the meeting but that agency has remained guarded about its interest and intent. 

 Any of the three agencies could initiate a rule-making process, but it is less likely if there is not a consensus among the three.

 So with that in mind, industry lobbyists have been making the rounds to congressional oversight committees to encourage that they become engaged on this issue and request that the agencies stand down now that the RFI process has been concluded and there is no �smoking gun� which would justify new regulatory action.

The most substantive meeting took place just a few weeks ago with the senior policy advisors for the Senate Finance Committee.  Given that the committee is chaired by Democratic Senator Max Baucus, who has been supportive of self-insurance in the past, it is best positioned to intervene.

The biggest push back by committee staffers was centered on the fact that the ACA does not require that self-insured employers cover essential health benefits (EHBs).   They argued that because of this �loophole� there is incentive for smaller employers to self-insurer, facilitated by stop-loss insurance with low attachment points, in order to be able to offer skimpy health care coverage as a way to save money.

Industry experts at the meeting, including executives from two leading TPAs, explained why this fear is unfounded for practical reasons.  It was then pointed out that while self-insured employers are not required to cover EHBs, they will be subject to �minimum value� requirements, which essentially accomplish the same public policy objective.

 But a final argument seemed to box in the Senate staffers.  Even if you concede the EHB �loophole� (which this blog does not), the fact is that the law was drafted in a very deliberate way to distinguish self-insured group health plans from health insurance carriers.  In this regard, any proposed changes should come back to Congress in the form of legislation as opposed to letting unelected regulators arbitrate substantive policy issues.

 The discussion was concluded with a formal request that Chairman Baucus consider exercising the committee�s oversight authority and communicate to the Treasury Department accordingly.   We understand that the request is still under consideration, so be sure to check back with this blog for updates.

Of course, the focus on self-insured plans with stop-loss insurance extends beyond Washington, DC. 

Many of our friends at the National Association of Insurance Commissioners (NAIC), have been led by the nose over the past year by health care reform advocates to take action on making it more difficult for smaller employers to self-insurer through tighter stop-loss attachment point regulation.

 At the NAIC summer meeting held a few weeks ago in Atlanta, the ERISA (B) Working Group considered a proposal to endorse �guideline amendments� to the current stop-loss insurance model act related to attachment point requirements. 

 Clearly aware of the blowback that would be directed at the NAIC if it took aggressive action that was seen to be disruptive to the health care marketplace, Working Group Chair Christina Goe of Montana tried to diffuse concerns by explaining the proposal is only advisory in nature and that the NAIC does not intend to formally amend the model act for a variety of procedural reasons.  And for good measure, committee members made it clear that they did not overstep their charge and attempt to redefine stop-loss insurance as health insurance.

 Well, it is certainly nice to hear this self-awareness of the limitations to their �charge,� but multiple federal court rulings have already confirmed that stop-loss insurance cannot be defined as health insurance, so no real favor here.

 And as far as considering a guideline amendment versus an amended model act, it�s a distinction without a meaningful difference.

 Of the 26 states that currently regulate stop-loss attachment points, only a few have adopted the model act without variation.  So it is unlikely that an amended model act would take root across the country any time soon.   No matter, as a simple NAIC recommendation on how states should regulate stop-loss attachment points could accomplish the same objective (restricting the ability of smaller employers to self-insure) much quicker.

That is because individual insurance commissioners who are already inclined to push stop-loss legislation in their states will use the NAIC recommendation as justification for action.  Given the technical nature of this issue, it�s easy to understand how this would be enough to persuade most state legislators to go along without asking too many questions.

 The NAIC working group deferred action on the proposal until its winter meeting, which in hindsight was predictable because insurance commissioners, like all political creatures, normally put off major policy decisions when Election Day looms.  Let the dust settle after November 6 and get ready for more action.

This brings us to California.

 As this blog has previously reported, the state�s insurance commissioner, Dave Jones, is a political creature who is interested in beefing up his credentials within the Democratic Party.  So it should not be surprising that he has come out as a major proponent of health care reform, and more specifically the establishment of California�s health insurance exchange, which is expected to come online in 2014.

 Self-insurance therefore became a target for political reasons every bit as much as for misinformed policy reasons in order for Commissioner Jones and his allies in the Legislature to claim credit for protecting the viability of the state�s health insurance marketplace as the exchange begins to be implemented.   A nice populist message for sure.

 One health care broker in California perhaps summed it up best when he referred to SB 1431 as the �California Health Insurance Exchange Protection Act of 2012.�

 Now that it has been confirmed that SB 1431 has been shelved, at least until a special session this December, we can look at the past as prologue.

The same stale arguments are certain to be dredged back up when some version of SB 1431 is brought back for consideration after the November elections, and the political posturing will be predictably crass.

 Equally unfortunate is that many stakeholders who will oppose SB 1431 �2.0� will likely concede the central principle once again of whether stop-loss attachment points should be regulated at all and immediately begin negotiating the numbers and formula.   Yes, political realities often dictate short term lobbying strategies based on compromise, but the longer view should not be ignored in this case.

It�s been a long hot summer for stop-loss insurance indeed, which has ended without much certainty for the future of the self-insurance marketplace.    We will see whether the coming autumn chill cools off the debate or if partisan health care reform advocates continue to overplay their hand.

Wednesday, August 15, 2012

EuroTrippin'2012: London (Week 1)

Day 1: 14th May 2012

Twinkle came over to spend the day with me before my flight at night which was super sweet of her cuz she still had another exam to study for. I did most of my packing the night before so I had to make some final packing. I brought about 2 sets of clothes, a dress and a romper (for 45 days) LOLOL. Wanted to bring jeans but decided I'd buy over there. When I had finally packed everything my luggage was completely full. That's great. I panicked but Dad just said it's cuz I didn't pack properly and since he's a seasoned traveler I decided to trust him.


Later on I found out that I had been scammed by him cuz his trips are always 4 days long and for the rest of my 45 days, every day I was just questioning my luggage choice while Ida sat near by laughing and shouting "Bring a smaller bag la why! Smaller la!!!" or making sarcastic remarks at how my bag is "seriously too big". -_-


We picked up my bro and my dad before going to the airport and my brother laughed like shit when he found out Twinkle was coming to 'send me off' and I didn't really know how to tell him I had like 6 other friends coming HAHAHA.

We ate KFC for dinner and I was feeling damn nervous because it's my first trip ALONE and I didn't know the boarding procedure or anything at all cuz usually my dad does everything. And I was damn worried I'd go to the wrong gate or miss my flight or die somewhere in Europe and my friends were all telling me not to die which was seriously making me damn scared because I also thought I was going to die. True story.

Went to the departure hall and said bye to all my sweet friends who came. (Thanks Nadia, Charlotte, Charis, Twinkle, Par, Ashes, Jane, Sharan) The last time I went to the departure hall was when i said bye to Ida in Sept and could naht stop crying. Anyway I was seriously SO close to having panic attacks at the thought of being without my family for 45 days in a foreign place. My mom still can tell me "It's not too late to turn back now" HAHAHAHAAH DAMN. TOO. MUCH. And she was completely serious.


Anyway hugged everyone goodbye and went straight to my gate C24 cuz it was opened. Was BBMing korkor that I'm damn scared and he told me C in C24 stands for China. That's great also. I took Thai Airways so I flew from SG to BKK and then from BKK to London. My dad booked biznez class for me and I didn't know how freaaaaaking shiok it was until I got on the plane and they served me CHAMPAGNE and my seat was super huge.


I have a light right next to me and they give you comforters as blankets and the seat can recline all the way to become a bed and there's a 'massage' function. I'm not sure if you understand how totally friggin awesome I think this is but let's just say that if typing in CAPS wan't so annoying this whole paragraph would be in caps. Also, the seat next to me was empty on both flights so I had two pillows and 2 fluffy comforters. So I made a fortress.

From SG to BKK, they served dinner and i watched 40 year old virgin. I had foie gras and kahlua and then I was too full to eat anything else (That's just the appetizer). They also kept giving us hot towels and the service was seriously damn good like my own personal butler. The flight was too short so I couldn't finish my show hahaha.

Then from BKK to LONDON, I had my 3rd dinner (tuna ravioli) then seriously wanted to vomit. I think I was also started to get too high from the alcohol so I watched 3 half an hr episodes of some lame show (Suburgatory) and took a nap. (My plan was to watch as many movies as possible) WELL GUESS WHAT. I woke up when they served breakfast and after breakfast the pilot said we're reaching in half an hour. Srsly I was like wad........da................ and the flight was 12 hours by the way. So i basically slept about 9 hrs straight and didn't watch a single mowie.

In total it felt like I was on the plane for 20 minutes, I really wished it could have been longer. Sobs.
Mandatory flying in the sky photo.

Day 2:

Reached London and went by the 'Fast Track' Lane. Turns out Fast Track was slower than Normal Track and I waited from 6:40am till 8am (London Time). I had to wait till 12pm to meet Ida cuz that's when she finished her exam (her exams were postponed to a week later than we had previously planned). I sat at the airport for a couple of hours reading my Europe book that Mr Imran got for me. I went outside the airport to look around and that was when I knew SHIT WAS ABOUT TO GET REAL because it was so cold that my breath became visible. Now, I had never been to London and I was told it's summer in London so i packed two VERY thin jackets, no, not even jackets. Like cardigans. And sleeveless shirts and short dresses and I DIDNT EVEN HAVE JEANS.

Anyway I followed the directions Ida mailed me and found my way to Whitechapel pretty easily. Waited for Ida at the station and she came AND I CRIED. I joked about crying but didn't think I would really cry cuz that's just lame. Anyway the area Ida lives in is kind of low-income with a lot of Pakistanis and African-Americans. Ironically there were very few angmohs. I saw about 1 for every 10 Pakistanis. Was weird being in Ida's room cuz I had been seeing it over skype the past 6 months and now I was actually in it. haahaha.
You can see my jacket on the floor next to ida's feet. And the floor was also my bed for the next two weeks.

We went to Sainsburys which is like SG's NTUC except a billion times bigger and cheaper. We went wild and bought a shitload of food. Ate leftover pizza for lunch and Ida cooked noodles w pork for dinner. I wanted to stay up til Ida slept cuz she was studying but I think I had jetlag so I wanted to pass out from 3pm onwards but really basically fainted at about 11pm.

Day 3:

Had breakfast with Ida then I went with her to the school building where she was having her exam. I walked around the area alone while she had her exam.

Part of Ida's School & the first picture I took with my camera

Cute vine covered houses

Tesco! Kinda like petrol kiosk shops in SG.

Walked and found a place called Watney Market



 Watney Market (Reminded me of Khaosan in Bangkok, minus the bars)

 RAINBOWWW

 Gigantic Cokes at Iceland
Lololol. Everything is gigantic.

 Cute houses

 Postman delivering mail. I think this is my favourite photo of the trip.

Cool Toilets

Met Ida back at Floyer House

Took a bus to St Paul's
Went to the mall next to St Paul's to shop!!! Didn't buy anything tho cuz it was quite expensive.

Pretty building on the way home.

Slept at 11:30pm cuz I was dead tired from jetlag.

Day 4:

Woke up at 6+ am again with a massive headache. Talked to Ida before she went for her exam then I slept till 11am when we went to Tesco to buy coconut milk to make Greeeeeeeen Curryyyyyyy!!!!

Best green curry ever.

We talked about school after lunch and Ida took a nap.

Chinese Food @ Canary Wharf
In the evening we took the overground tube to Canary Wharf and shopped a bit. Then we RAN from the shopping centre all the way to the river side (like 10minute walk) cuz we were late for our dinner appointment. It was damn funny because we kept laughing while running. We were seriously super tired after.

 Ate Char Siew, Wanton soup, Jellyfish, Dumplings & Hor fun.

 Riverside


The Gherkin

Cabbed home at 9:45pm and slept at 12:45pm. Felt less tired, think my jetlag got bettur.

Day 5:

Shopping @ Westfield Mall at Stratford
Woke up at 11am when Ida got back from her last exam YEY!!!! And we went shopping DOUBLE YEYYY!!!!!!

Took the tube to Stratford station.

Westfield Shopping Mall!!! (It's huge and has F21, Topshop, River Island and PRIMARKKK)

Ida (on the left in the brown coat) walking to Westfield

They have a gigantic F21. I think it's two storeys but probably same size as SG's F21 in 313. Lurve the neon pink bag.
Our feet were dying after F21 so we went for a lunch break at Marks & Spencer's

Fresh Pasta!

We went to Primark next, which is officially my favourite store in London. It's huge and their clothes damn hip & trendy (I did naht just say that) and SUPER CHEAP. Like I think generally 5-10 pounds. and the quality isn't compromised (that much).  Really Craysee. But ofc queues for the changing room are damn long and it's v crowded because shit is really damn cheap. Another downside is that the fitting is damn weird sometimes so you HAVE to try the clothes. They sell everything from clothes to shoes to luggages. My second fave shop is Boots and Superdrugs which is London's drugstores like our Watsons and Guardian. They sell a shitload of mekkup and they always have awesome promos so it's v cheap :)

Another break. This time for teaaa~~~ Ida posing w my Primark bag. As you can see I tore the bag within seconds of holding it. Le sigh.




 The soap HAD GLITTER. Sooooo preeeeeetteeeeeeeee.

Checked out a few more shops then went home cuz we were damn tired.

 7 hrs of shopping later...

Bought Moscato at M&S on the way home in preparation of our first night in da club^^

I didn't like the moscato since I was still paying for my night at Filter in SG when I got so smashed I came home w/o my shoes and didn't even know and my parents came into my room at 3am to watch me vomit (Gr8 memories). So i mixed 5ml of sherry with 500ml of OJ. We decided to just have a chill night so we went to Mother Bar at Shoreditch High Street which had free entry. It was more like a house party than a club (probably because of the wooden floors). We had a great time dancing to hip-hop/old school music w the occasional dubstep. Went opposite to the cab office. It's a special cab system that calls the cab for u. It's basically just normal cars with Indian drivers and they don't go by meter so you agree on a price beforehand. Came home at 3:30am.



Day 6:

We basically spent the whole day eating and sleeping. Went grocery shopping at Sainsburys again and Korkor told me about the game between Chelsea and Bayern in the UEFA Champion's League. So we figured it'd be a good experience to watch it with the locals. Headed to The Good Samaritan Pub which is about 5 minutes away from Floyer.
 Generally not a fan of watching sports. But if it's big games/interesting I dont mind.

Unfortunately, it was boring as hell so we went to Tesco to get alcohol. Went into some other club/bar we found while on the way to Mother Bar. The club was very cosy and old school. The DJ spun on a wooden table. They played Outkast/Craig David remixes and alot of "Black but not Ghetto" music. Went to the cab office and Raheel from the office got us a cab again. Cabs are pretty expensive. Like, these cabs that we take after clubbing (not London cabs) are already 10 pounds for like a ten minute drive.
 

Day 7:

Sunday Roast @ Good Samaritan Pub
It's Sunday!!!~ We headed to the pub again for Sunday Roast!!! It's a traditional British meal served on Sundays for Brunch or Lunch.
 
 
The packaging is so cute.
 

 It wasn't fantastic but I guess it's the same as going to any random hawker centre 5 minutes from your house and eating chicken rice.
Ida says I look like a dog.
 
 
 
Mass @ St Paul's Cathedral
Took a bus to St Paul's Cathedral for mass.

 Had to run home to get jackets before coming here cuz it was way too cold. Ida lent me her Marshmellow

 

 
 I don't think they allow photos inside but we took some quick shots with Da's iphone lolol. The photos DON'T do the Cathedral justice at all.
 
 It's gigantic inside and the ceiling is mega high. So beautiful.
Walked to PAUL afterwards which is a yummy high end bakery. They have a shop in SG also in Takashimaya. I know their stuff is a little overpriced. Like a strawberry tart is SGD $8.
Apple Turnover
London Bus
 
Went to the mall to shop abit again. Then Ida wanted to bring me to do some 'touristy stuff' and wanted to show me the London Tower. We took a bus there. Ida pointed at it while we were on the bus. Then we tried to walk to it but got lost. Used Google Maps but Ida doesn't know how to use it. I confidently told her to STEP ASIDE and let the master (me) lead us there. We walked for about 15 minutes and I told her we were getting closer. Turns out I was following the pin that points to where we currently were. So we gave up and went home.
 
Indian Food @ Tayyabs 
Then we went home to rest for awhile because we had a dinner appointment at Tayyabs.
Story of Dinner at Tayyabs:
 One day earlier, Raheel from the cab office told us that he works at Tayyabs. Since he was very nice and helpful with getting our cabs we told him we'd drop by to say hi to him and have dinner because Tayyabs is apparently a famous Michelin star restaurant in the neighbourhood of Whitechapel so it's also 3 minutes from Floyer. 30 minutes before dinner, Raheel asked if he should SEND A CAR to pick us. It's a 3 min walk so we said no. We made it to the restaurant and turns out, Raheel's family OWNS THE RESTAURANT. Which is great for him. BUT THEN, he wasn't working (we thought he was the waiter) so he sat beside us and talked about the food. We thought he was gonna go away so we excitedly decided what to order. Then he said "Oh, my cousin is coming to join us for dinner" WTF is "JOIN US"??? WHO INVITED YOU? At first Ida thought he was joking. Then she realised he was not. Then her face immediately became a dark ass thunder cloud. So that's the story of how we got scammed into dinner with two men.
 
Raheel's cousin Billard, thankfully, was pretty funny and I also think he is gay but Ida doesn't think so. He makes inappropriate jokes and points out the awkwardness which I found hilarious and so enjoyed his company. But the whole time i just really wanted to pluck his unibrow.
 


 The food was mega fantastic. We sat in the VIP room. Then Raheel took me on a tour of the restaurant LOLOLOL and made me meet his brother while Ida and Billard continued eating.
 
 Then he wanted to go out so I reluctantly agreed and we stood outside and I took pictures and he told me all about Tayyabs history. It's 3 shops and 3 storeys. Has been around for 35 years, has a seating capacity of 600 and has 65 staff.


Went to show me his brother's Matte BMW w the 'Tayyabs' plate. -_-
 
Needless to say, dinner was preeeeedy dayum awkward since we were surprise attacked.
Ida and I finally made a run for it when she said she'd finish her ice cream later and Billard was like... It'll melt. Then she was like... Yea..... Then Billard was like. Ok guess you need to go home now. HAHAHAHAHAHA. and he was making it soooooo awkward and so funny.
 
In the end they were gentlemen and paid for the bill and walked us home. They kept telling us they wanted to bring us shopping/club/dinner but we were like B.I.T.C.H. PLS.
 
Watched Sweeney Todd with Da at home. It's a story filmed in London of some guy's wife who was kidnapped and he had to go into hiding. Then he met a new woman and killed people with her and she made pies with their bodies. Nasty.
 
Great first week!
 BTW, this was the most boring week of the trip so it only gets better! :)