TIps to Reduce the Likelihood of a DOL Audit
Unfortunately the Department of Labor (DOL) has been increasing its audits of group health plans. It’s a good idea to be sure you’re compliant now, since an audit can occur at any time. We recommend you review the checklist below which will help reduce the likelihood of an audit, and ensure that you’re prepared when you’re audited.
- Keep all your benefit plan documents together in one location.
- Put one person in charge of the benefit plans.
- When there are participant and beneficiary questions, respond promptly.
- Familiarize yourself with all plan documents, and be sure you understand them.
- Make sure all benefit plans covered by the Employee Retirement Income Security Act (ERISA) comply with relevant laws, such as Health Care Reform and the Health Insurance Portability and Accountability Act (HIPAA).
- All plan participants must receive summary plan descriptions (SPDs), with accompanying benefit plan component documents such as benefits booklets and certificates of insurance, within 90 days of becoming covered under the plan.
- Administer all ERISA-covered benefit plans, including group health plans and other welfare plans, in accordance with a written plan document.
- If you have participant and beneficiary requests for an SPD and plan document, be sure you respond within 30 days after a written request.
- Any material changes to the plan either through a revised SPD or in a separate document, called a summary of material modifications (SMM), must be reported to participants.
- Note specified timeframes and distribute required notices, such as COBRA (continuation of health benefits) and SBC (summary of benefits and coverage) notices accordingly.
- If Form 5500 must be filed, be sure to accurately complete all portions and file it before the deadline.
- Be sure you have procedures for disputes and claims resolution in writing which can be referred to as needed.
*The above list contains general guidelines. This information is subject to change based on amendments to the law.
We look forward to discussing this with you! Contact Jamie Moran, HIA, MHP, a Principal and the Director of Employee Benefits at Provider Group. He can be reached at 401-671-6359 or jmoran@providerig.com.
Jamie is a Principal, and leads Provider Group’s Employee Benefits Practice. He designs and implements cost effective, long-term benefits strategies while balancing the employee’s demand for quality plans. Jamie works with businesses and non-profit organizations throughout New England to develop a variety of traditional and non-traditional ways to approach employee benefits.