Bottom Line Driven Health Benefits Planning · Bottom Line Driven Health Benefits Planning How to...

Innovation. Dedication. Knowledge. Purpose. Integrity. Vision. Talent. Results.

Bottom Line Driven Health Benefits Planning

How to Prepare for And Survive A DOL Audit

-1- How to Prepare for And Survive A DOL Audit

Jeff Schultz

Vice President

BeneCo of Wisconsin

Greg Storm

Shareholder, Employee Benefits Practice

Reinhart, Boerner, Van Deuren


Why Employers Should Care

Increase in DOL audits of health plan compliance

Potential penalties

Fiduciary breach

Plan document and distribution penalties

ACA penalties

Prohibited transaction

Referral to other government agencies

©2014 All Rights Reserved Reinhart Boerner Van Deuren s.c.


How Does an Audit Start?

ERISA §504 – grants DOL authority to investigate plan reports, books and documents

ERISA §502 – penalties enforced by DOL through EBSA

Initiated by 5500 review, participant complaints, new reports and other government entities



What is the Process?

Introduction letter and document request

Employer response

DOL visit and interviews

Violation letter

Negotiation, settlement agreement, correction

Closing statement



Enforcement Area – General ERISA Compliance

Basic documentation – Plan document, SPD/SMM/SBC, service provider agreements

Fiduciary actions – prudent procedure

Claims procedures



Enforcement Area - HIPAA

Certificates of Creditable coverage

Preexisting condition exclusions

Special enrollment rights

Privacy?



Enforcement Area – Other Group Health Plan Mandates

COBRA – notices, administration

NMHPA – notices

WHCRA – notices, benefit description



New Enforcement Area – Wellness and MHPAEA

Wellness – all descriptions, nondiscriminatory design

MHPAEA – all documents showing benefits, comparisons and limits

GINA – use of genetic information, especially in wellness programs?



New Enforcement Area - ACA

Grandfathered status and notice

Age 26 dependent coverage

Rescissions

Lifetime limits

Annual limits




Non-grandfathered plan

Provider selection notices

Emergency service benefits

Preventive services

External review and IRO contracts




Upcoming items

Waiting periods

Age 26 exclusion for grandfathered plan

Non-grandfathered – OOP limits, clinical trials, provider nondiscrimination

Pay or play?



Tips and Take Aways – Pre-Audit

Document, document, document

Keep plan updated

Demonstrate compliance with distribution requirements

Follow plan provisions and fiduciary requirements

Organize records

Review plan provisions and operations regularly

Assess responsibilities – who is doing what?

Does service provider contract reflect employer understanding?

Correct problems when discovered



Tips and Take Aways - Audit

Respond professionally

Be thorough, but not excessive

Utilize service providers

Maintain copies of disclosures and responses

Expect interviews

Anticipate correction process



Pay or Play Webinar Series Series: Course Level Date Time

Top 10 Frequently Asked Questions about ACA (Rebroadcast) 101 3/12/2014 9:00-10:30



To Register: http://www.benefitsinc.com/beneco_webinars.html


ACA Learning Series: Course Level Date Time

What Do the Updated Regs Mean To Our Company and Our ACA Strategy

313 3/19/2014 10:00-11:00

Cadillac Tax: Creating a Glide Path to Minimize the 2018 Excise Tax Impact

314 4/23/2014 10:00-11:00

Top 5 Most Inaccurate Assumptions about the ACA and How to Avoid Them

301 5/28/2014 10:00-11:00



Avoiding ACA’s Cadillac Tax: Five Most Costly Benefit Plan Misconceptions that Employers Have:

Course Level Date Time

Misconception #1: Plan Design is the Only Way I Can Reduce Plan Expenses

300 4/1/2014 10:00-11:00

Misconception #2: My PBM Doesn't Matter 300 4/24/2014 10:00-11:00

Misconception #3: Wellness Doesn't Produce an ROI 300 6/3/2014 10:00-11:00

Misconception #4: All Care Management/Utilization Review Firms Are the Same

300 7/15/2014 10:00-11:00

Misconception #5: My Employees Will Never Understand Their Benefits and Engage

300 8/5/2014 10:00-11:00



We are grateful AM 620 WTMJ has asked BeneCo to host a radio series to educate listeners on how best to tackle the ins and outs of the Affordable Care Act (ACA). Focused primarily on educating: Business Owners, CEO's, CFO's and HR professionals; we will help them determine if ACA is a "Top 3" or "Top 30" business priority. Tune in to hear us discuss critical ACA challenges to business on March 16th from 8:00-9:00pm. Be sure to listen for the advertisements! If you would like the podcast from the February 16th show please drop us a line.


MRA’s 2014 Health Care Implementation Workshop Series

Exclusive Focus on ACA Measurement, Administrative & Stability Periods Overview: Confused about the various safe harbor periods? Do you have more questions than answers? While the regulations seem simple in concept, putting these periods on paper creates a wave of questions about various classes and types of employees and scenarios. This session’s exclusive focus is helping participants leave with their periods determined and ready. Learning Objectives: Learn which period length options works best for your organization Explore the pros and cons of various time period selections Understand how the periods impact different classifications of employees Arrive with your workplace specific questions Leave with your 2014-2015 periods determined and ready To assist in your preparation, listed below are some suggested additional workshop materials: · We would like to have each participant supplied with the knowledge and practical tools they will need to return to their workplaces with a thorough understanding of how to apply what they have learned. · Practical takeaways including examples and decision-making flowcharts · To-do-checklists or guides that will reinforce steps to be taken · Case studies or survey information regarding what other employers are doing · Links to useful Internet resources

March 17th, 2014 8:30am – 11:00am

http://www.mranet.org/Home.aspx


You asked for it……

ACA Impact Study How will ACA impact my organization? What do I need to plan for?

Free initial consultation Fee for service basis based on plan complexity

ACA Sustainability Analysis How do I create a long term sustainable ACA cost strategy and still comply? Fee for service basis based on plan complexity


Ask us about Haiti…

The work: Orphan care and sponsorship, tent city refugee relocation and community development, microenterprise other ministry opportunities

To get more info or engaged in some way drop us a email, or for a glimpse of the work go to www.newlife4kids.org or www.missiondiscovery.org

Upcoming trips: December 2013 or 2014: April June and October

http://www.newlife4kids.org/

http://www.missiondiscovery.org/


Post-workshop questions or to get the links for upcoming webinars:

Jeff Schultz Vice President BeneCo of Wisconsin, Inc.

262-207-1999 x112 [email protected] www.beneco.co

Bottom Line Driven Health Benefits Planning · Bottom Line Driven Health Benefits Planning How to...

Documents

Transcript of Bottom Line Driven Health Benefits Planning · Bottom Line Driven Health Benefits Planning How to...