Susie Licht April 14, 2011

In an era of Health Care Reform, your organization may be adding adult dependents onto your plans. HCR mandates allow children to maintain benefit coverage up to age 26 without regard to dependency, marriage or student status. One way for employers to ease the added dependent burden, for those plans maintaining their grandfathered status, is to implement a working child affidavit program. This approach will review dependents who are employed and find those who are eligible for health coverage through their own employers. If their employer does offer benefits, the dependent would be ineligible for coverage under your company’s sponsored plan.

There are three questions to ask when implementing this type of review:

Will you remove an adult dependent that fails to return the affidavit? You will want to be clear of the consequences to employees of non-compliance with the program.
What will your approach to the affidavit be—soft or strict? There are options on the affidavit that allow you to take different approaches. For example, you may want to use a document that only the employee has to fill out—not the dependent’s employer. This approach would be soft and more of an attestation completed by the employee that asserts the dependent meets the guidelines. Alternatively, you could require the form be completed by the child’s employer for a more robust process to ensure strict adherence to the guidelines. The approach you take very much depends on how tightly you would want to manage the process.
Would you audit adult dependents only or roll into an overall dependent verification program? You have a choice, you can audit all covered dependents or just the adult dependent population. Should you choose the entire population, this would ensure compliance of all dependents in your benefit plans and not just a subset of the population.

You should choose an option that best fits your culture and meets your organization’s needs. The ultimate goal is to ensure that all covered dependents on your employer’s sponsored health care plans actually meet the guidelines to be covered.

To learn more about your options under a grandfathered health plan, read our White Paper or visit The Dependent Audit Guide.