Audit Participants
As you consider the benefits and expected outcomes of conducting a dependent verification program, you will need to determine which populations to include. Depending on your model approach, you may choose to segment your populations for participation. Employees can be selected at random, or a single group of Plan participants, such as a location or union can be chosen. This is also a viable option for conducting a pilot program prior to initiating a comprehensive verification program. We strongly recommend that you consult with an attorney prior to segmenting your population for inclusion in the Dependent Audit for any method other than a random selection process.
Active Employees
Active Plan participants will be your most captive audience and the easiest group with which to communicate. You should be able to initiate personal outreach to this group fairly easily if you find that they are not responding as you would like.
International Employees
In developing your communication strategy, be cognizant of the extra time and effort required to communicate with Plan participants on an ex-patriot assignment or those living outside of the United States. Be sure that you are committed to removing outstanding dependents for this group before including them in the audit process to avoid any potential of treating groups differently at the conclusion of the audit.
Retirees
We usually receive the highest response rate from retirees. However, it can be more difficult to reach this population as they tend to travel frequently and may not have alternate means of communicating such as email accounts. Be sure to keep these items in mind when deciding on a timeline.
COBRA Recipients
We usually receive a low to moderate response rate from COBRA participants. It is important to consider that dependents are typically enrolled in COBRA plans as they no longer meet the definition of an eligible dependent. This group can have difficulty providing the documents needed to continue coverage. For example, an employee may have the marriage certificate needed to establish that a legal marriage took place for a former spouse but would likely not have the current documentation needed to establish financial interdependency for them. It becomes very important to be able to differentiate dependents on COBRA from other dependents within the data file(s) so that special consideration can be given to this group in regard to documentation required for the audit.
Surviving Dependents
Surviving dependents, those who remain on coverage after the death of the employee, can present a special challenge. Many employers prefer to be sensitive to this population and choose to leave them out of the audit process so as not to create anxiety or be seen as harsh toward this group. If you do decide to include this group in your audit, you will want to consider the communications used and documentation required for them in order to complete the audit process.
