Dependent Audit Communications
Your communications plan will have a direct result on your audit response rate. The more communication you provide, the higher the response rate you should expect. You will want to consider the best mediums for communicating with your audit population—whether through direct mail, email, department or location meetings, voice-mail, or intranet postings. During the audit process, your communications will need to consist of the following items, depending on your approach and culture:
Amnesty Letter (optional)
The Amnesty Phase (or ‘no consequence’ phase) allows the employee to closely review his/her covered dependents and the healthcare plan’s eligibility guidelines. The Amnesty Letter should include eligibility definitions specific to your Summary Plan Description and a list of the employees’ dependents receiving healthcare benefits. Other than loss of coverage, the amnesty communication allows the employee to remove a dependent from the benefit plan without consequence. The form includes the option of removing a dependent from coverage, and the employee can list the date on which the dependent became ineligible. As provided by the employee, this information can be used in determining whether or not to offer COBRA benefits.
Amnesty FAQs (where Amnesty is included)
In an effort to assist your audience in completing the dependent verification program, HMS recommends including a document which outlines Frequently Asked Questions (FAQ). This information will serve as a resource to the program participant and will alleviate inquiries to your human resources and benefits personnel.
Verification Letter
Verification notices will be mailed to employees with dependents who are not removed from coverage during the Amnesty Phase (where applicable). The verification notice should include eligibility guidelines specific to your Summary Plan Description, a list of covered dependents, and documentation requirements for validating each dependent relationship. The verification notice should also include the option of removing an ineligible dependent, as well as any consequences for covering an ineligible dependent. As the recommended time frame for conducting verification is 45 days, multiple communications may be necessary. Not all of your constituents will respond to your initial Verification Letter. Therefore, HMS recommends sending additional letters prior to the verification deadline.
Verification Reminder Letter
As the recommended time frame for conducting verification is 45 days, multiple communications will be necessary. Not all of your constituents will respond to your initial Verification Letter. Therefore, HMS recommends sending a reminder mailer twenty days into the process and then a third mailer ten days prior to the verification deadline in order to remind employees of their required participation.
Verification FAQs
In an effort to assist your audience in completing the dependent verification program, HMS recommends including a document which outlines Frequently Asked Questions (FAQ). This information will serve as a resource to the program participant and will alleviate inquiries to your human resources and benefits personnel.
Termination Confirmation Letter
A Termination Confirmation notice should be sent to an individual who chooses to remove a dependent from coverage. The notice should be sent at the conclusion of the Amnesty Phase, where applicable, and throughout the verification process to alert these employees of their request. Variations of the termination notice may be necessary if additional consequences are imposed for removing dependents during the verification process.
Custom Response Notice
Employees who provide a partial or incomplete response should receive a Custom Response Notice to include the documentation received as well as any outstanding documentation required to complete the audit. This communication will alleviate calls to your human resource or benefits personnel as it will outline exactly what documentation is still needed.
Involuntary Termination Notice
When documentation is submitted in an attempt to validate a dependent but the documentation actually indicates a dependent is ineligible, an Involuntary Termination Notice should be sent to the employee. The notice should include the affected dependent’s name, relationship, and explanation of removal from coverage. As an example, involuntary termination confirmations are sent to an employee who confirms that his or her listed spouse is actually a common law spouse where the specific plan guidelines do not recognize this relationship.
Final Notice of Adverse Action
Depending on your audit response rate, you may choose to send a Final Notice of Adverse Action to individuals who did not provide a response or only provided a partial/incomplete response. The notice informs the employee of the action(s) to be incurred for not complying with the audit process. The letter can also serve as a final notice to submit outstanding documentation if you decide to allow an extension of time to respond. Previous communication attempts, the affected dependent(s) and instructions to appeal the termination of benefits are detailed in the letter.
