Are You Prepared to Perform a Fresh Dependent Validation Audit?
The Patient Protection and Affordable Care Act (PPACA)
has made keeping track of who is eligible
for employer health care programs a moving target.
It’s unclear which provisions of the health care law would be changed by a Supreme Court ruling
against it, but the ones at risk include the rule that allows adult children to remain on their parents' medical insurance coverage through age 26.
Depending on the Court’s decision, your team may find itself needing to
perform a fresh dependent validation audit. Performing such audits, which remove ineligible people from your programs, can lead to significant cost savings for employers. However, getting the most out of the audit requires a plan. In particular, employers should pay close attention to how they communicate with their workers before and during the dependent eligibility audit process.
Here are some of our favorite tips for communicating effectively about dependent audits.
- Define the appropriate terms in regular language. HR professionals are accustomed to using terms such as ERISA and COBRA in everyday conversation. But to your colleagues in other professional fields, this is jargon. Even when people think they know what certain terms mean, they can be wrong. For example, there’s a difference in the colloquial use of the word “dependent” and how the IRS defines it. Create and share a glossary of terms early in the process to help everyone get on the same page.
- Win management’s support. If senior leaders communicate the importance of the dependent eligibility audits early on, it will help the process move along more quickly. Have them explain to workers why the audit is important for the business’s success. Don’t let them marginalize it as “HR paperwork.”
- Use multiple channels to communicate. Keep employees up to date throughout the audit process using every channel that is available and appropriate. This can include e-mail, social media, print newsletters, bulletin boards in break rooms, or your internal blog or forum.
- Schedule an amnesty period. If the company has been lax about verifying dependents’ eligibility for benefits, employees likely have been too. Give workers the chance to come forward themselves and voluntarily remove ineligible dependents from their benefits.
- Be specific about consequences for noncompliance. You can’t forget to warn your workers about what happens if they don’t cooperate. Will eligible but undocumented dependents be kicked off until open enrollment? Are employees at risk for termination for providing misleading information? Don’t let your workers be surprised about what will happen if they fail to participate fully in the audit.
- Consider outsourcing the dependent eligibility audit. Tightening up enforcement on dependent eligibility could cause hard feelings among employees. Some of this frustration will be targeted at members of the HR team. Having an outside vendor manage this process could help reduce this risk. This could also help allay workers’ privacy concerns about sharing changes to their family situations directly with their regular colleagues.
Winston Benefits is a HR solutions company that helps businesses automate and streamline their employee benefit programs. Custom designed and developed client specific solutions help enrich their total compensation and rewards programs while optimizing processes such as benefit communications, enrollment and administration.