The benefits issue that costs employers big: Ineligible dependents on company plans

Are you paying insurance premiums for dependents who are ineligible for your company health plan? Almost 10 percent of enrolled dependents are ineligible for the programs they are enrolled in. Read on to learn more.


Are you paying insurance premiums for people who aren’t qualified to be on your company plan?

For some employers, too often the answer is “yes.”

In our experience, we find that nearly 10% of dependents enrolled in employee health and welfare plans are not eligible to be in the program. And for a company with a couple of hundred employees that spends around $2 million a year on benefits, ineligible dependents can become a significant financial issue.

When employers pay for ineligible dependents, costs increase for them and employees. Unfortunately, it’s an all-too-common issue that employers need a solid strategy to combat.

So how do ineligible dependents get enrolled in the first place? There are a couple of common ways that employers end up paying health insurance premiums for ineligible dependents. The most basic factor is a change in a person’s situation — children pass the age of 26, spouses get jobs, people get divorced, etc. — and the employee is unaware of the need to notify the plan sponsor. Most often, these situations arise because the employer doesn’t have a process in place.

But some situations are more nefarious: An employee mischaracterizes someone as a dependent. They may claim that a nephew is a son, or that they’re still married to an ex-spouse. In either of these situations, the employer loses.

Prevent ineligible dependents with best practices

Prevent paying for ineligible dependents by putting into place best practices that begin when a new employee joins the company.

During onboarding, investigate each potential plan member when the employee applies for insurance coverage. That means seeking documentation — such as marriage certificates and birth certificates — to verify that a person is, in fact, married, or that their kids are their kids and not someone else’s. Following these processes at the outset prevents the awkwardness of having to question employees about their various family relationships. Nobody wants to ask a colleague if the divorce is final yet.

To make it easy for employees to verify everyone’s eligibility, provide access to a portal where they can upload scans or images of relevant documents. This will also make it easier to track—and keep track of—onboarding documents and dependent audits when the time comes.

Once this best practice is established, it’s important to conduct periodic dependent eligibility audits, as required by ERISA. The employer can conduct an audit or hire an external auditor. This decision is usually driven by the size of the workforce.

The most logical time to conduct an audit is during benefit enrollment. Employees are already considering options for the next plan year, and they likely won’t be confused by the need to submit verifying documents. (During this exercise, it’s also a good idea to ask plan participants to verify beneficiaries on employer-provided life insurance.)

Some employers — again, depending on the size of the workforce — will conduct random sample audits of 20-25% of their employee population. Obviously, the larger the sample size, the better. Benefits administration platforms typically streamline this process.

What happens when employers identify an ineligible dependent?

Many employers offer workers an amnesty period during which an employee can come forward to say they have someone that should be taken off the plan. If the plan sponsor identifies an ineligible dependent, employees are typically offered a one-time pass. Then, they must sign an affidavit attesting that they can be terminated if it happens again.

If the employer has processed insurance claims for an ineligible dependent, they can declare fraud and seek back payment of claims payouts. Again, most in this situation prefer a more benevolent approach and will ask the employee to make monthly differential payments until the account is even. Conducting regular dependent eligibility audits as part of the benefits administration process needs to be handled with finesse for the good of organizational culture.

Some employers may shy away from conducting audits out of concern for creating awkward situations. But frankly, it’s the plan sponsor’s job to help them navigate the waters, educate them and keep them engaged in the process by becoming their best advocates. This will not only help enhance the efficiency and accuracy of employee benefit offerings, but it will result in a smoother ride for everyone involved.

Ensuring that a health and welfare benefits program follows eligibility best practices is the responsibility of the plan sponsor. But employees have a share in that responsibility, too.

SOURCE: O'Connor, P.(28 November 2018) "The benefits issue that costs employers big: Ineligible dependents on company plans" (Web Blog Post). Retrieved from:


What’s in store for voluntary benefits in 2019

What does the New Year have in store for voluntary benefits? Employee purchase programs allow employees to pay for items even if they don't have the funds or credit available. Read this blog post for more 2019 voluntary benefits trends.


Benefit managers are still catching their breath as the curtain closes on this year’s open enrollment season. But smart benefits managers are already evaluating new products and benefit changes for the 2019-2020 season.

Themes around cost-saving strategies concerning healthcare premiums will continue to resonate — but what else will happen in the upcoming year? Voluntary benefits will continue to hold the key for many benefit managers looking to lower costs and maintain value for employees by providing flexibility to a diverse workforce.

Voluntary benefits offer pivotal advantages to employers and employees alike. By offering these programs through an employer, employees often receive better pricing, plan designs and underwriting support compared to what is available on the individual market. Payroll deduction capability and enrollment as part of their normal core enrollment process and portability are also available.

Here are three voluntary benefits to watch in 2019.

Employee purchase programs.

Nearly one-quarter of all Americans do not have adequate emergency savings, according to a survey by consumer financial services company Bankrate. This means that if they need to make a significant purchase, they are likely to withdraw a loan from their 401(k) plan.

Employee purchase programs help employees pay for items they may need immediately, but may not have the funds or credit available. These programs generally allow employees to spread out the payments on the purchased products — such as appliances, car tires or computers — over a period of time through payroll deduction. Young employees who are trying to establish credit while managing student loan repayments — and may be strapped for cash — can especially benefit from an employee purchase programs.

Group legal insurance plans.

Group legal plans are not new, but they are still valuable for employees. For a cost that is less than a cup of coffee, group legal plans provide employees with access to attorneys for will preparation, estate planning, dealing with elderly parents, traffic violations, real estate purchases, and document review and preparation. These plans offset the expense of professional legal representation and the time it takes to locate the right representation to handle legal matters.

These plans may be especially valuable to employees who are thinking of buying a house, adopting a child or planning for their estate. Still, group legal insurance plans are available to all employees, and can provide a buffer for workers who may need to navigate identity restoration after a theft or combat an unforeseen traffic ticket. These plans also save employees time and money when the need for a legal professional arises.

Student loan benefits.

Student loan benefits have been one of the hottest topics in voluntary benefits in 2018 and it’s not going away any time soon. An IRS private letter ruling this past August allowed one company to amend its 401(k) plan to allow employer contributions of up to 5% to individuals who contribute at least 2% to their student loan. This may just be the start to more legislation concerning student loan debt solutions.

In the interim, as the tuition debt crisis grows, employers are seeking ways to support their employees. There are several strategies that can be employed.

Some solutions can be offered at no cost, while others have administrative charges and the cost of contributions to factor in. For employers who have the budget, a student loan repayment plan may be the answer. There are many vendors who can partner with an employer to help develop a plan that is designed to meet the company’s goals.

Employers without a budget can seek a student loan solution partner that offers comprehensive educational tools such as written materials, debt navigation tools, FAQs, one-on-one counselors and webinars. Another option is to offer student loan refinancing. These lenders can help employees manage their debt. Even though refinancing is not for everyone, well-vetted student loan refinancing partners should be considered as part of a comprehensive student loan debt solution strategy. Understanding the approval rate is important, as well as whether there are any other incentives, such as a welcome bonus, that may be applied to the loan principal.

SOURCE: Marcia, P. (28 November 2018) "What’s in store for voluntary benefits in 2019" (Web Blog Post). Retrieved from: https://www.benefitnews.com/opinion/whats-in-store-for-employers-and-voluntary-benefits-in-2019


End-of-year FSA expenses: An employer cheat sheet

Reminding your employees what expenses their flexible spending accounts (FSA) cover can help alleviate the issue of unspent FSA funds at the end of the year. Read on to learn more.


The scenario is all too familiar for employers and human resource managers: The year ends, and employees still have unspent funds in their flexible spending accounts. Whether employees forget that the money in their FSA must be used or it will be lost, or they simply aren’t aware of which expenses can be covered by FSA funds, their frustration at losing money often falls on the employer.

Reminding employees which expenses are eligible to be covered by an FSA can help mitigate headaches for employers and HR departments in the new year and shed light on lesser-known options for making the best use of remaining funds before the end of the plan year.

As a general rule, an eligible expense is any medical expense the health plan doesn’t cover. This includes things such as out-of-pocket costs, co-pays, co-insurance, hospital visits and prescription drugs. Employees also can apply their FSA funds to dental and vision expenses, which often are not covered in health insurance plans.

Some eligible expenses employees might not be aware of include flu shots, prescription sunglasses, sunscreen that is 30 SPF or higher, grooming for service dogs, acupuncture, arch supports and nutritional consultations. Employees can also use money from FSA to cover pregnancy tests and prenatal vitamins, hearing aids, canes and wheelchairs. They can also use funds to cover personal trainer fees, as long as a letter of medical necessity accompanies the claim.

The IRS determines which expenses qualify for FSAs and maintains a list on its website. Most FSA administrators have lists on their websites as well. FSA-holders can either search for individual expenses or scroll through the list to see what opportunities they might be missing. But it’s a good idea for employers to provide those lists for employees.

In addition to reminding employees what types of expenses are eligible for coverage by FSA funds, employers should review if their plan has a grace period, runout or rollover. If so, employers should communicate the details with employees, as this can help them take full advantage of the time they have to incur expenses and submit receipts for reimbursement.

A grace period is the amount of time an FSA-holder has after the end of the plan year to spend unused funds or incur expenses. A typical grace period is up to 2.5 months after the plan year ends. A run out is the amount of time an FSA-holder has after the end of the plan year to submit claims for reimbursement. In this case, expenses must be incurred before the end of the plan year. An FSA rollover allows up to $500 to be carried over from one calendar year to the next.

Employees also might not be aware that they can use FSA funds on a medical dependent, whether that dependent is covered by the FSA holder's health plan or not. For instance, if an employee has a 24-year-old daughter not covered by the employer health plan who needs a co-pay for a doctor appointment covered, the employee can use their FSA.

Lastly, it’s also important to make it clear to employees the distinction between an FSA and a health savings account. While many of the same expenses are eligible for coverage by either an FSA or HSA, make sure to remind employees about a few key distinctions. An HSA is not “use it or lose it.” All funds roll into the new year and do not need to be used up before the end of the plan year. And for an employee to use his or her HSA to cover a dependent’s medical expenses, the dependent must be a tax dependent.

Helping employees make the best use of their FSA funds before the end of the year not only positions the employer as a hero for saving employees’ hard-earned money, but it inevitably saves the employer from a headache heading into 2019.

SOURCE: Peterson, M. (19 November 2018) "End-of-year FSA expenses: An employer cheat sheet" (Web Blog Post). Retrieved from https://www.benefitnews.com/opinion/end-of-year-fsa-expenses-an-employer-cheat-sheet?brief=00000152-14a5-d1cc-a5fa-7cff48fe0001


What Benefits and Perks Do Employees Actually Want?

Employee benefits packages have grown to include much more than just medical, dental and vision coverage. Read this blog post to learn what benefits and perks your employees want.


With open enrollment just around the corner for most companies, employee benefits are top of mind. Today’s offerings have grown to include more than just medical, dental, and vision coverage. Companies are now including perks like scheduling flexibility, tuition reimbursement, and even parental assistance as part of their overall package.

Let’s cut through the hype: what benefits and perks do employees actually care about? As someone who has administered his fair share of open enrollments, I’ve wondered the same thing. But over the years, I’ve learned that you sometimes just need to ask. By running benefits “pulse” surveys, HR teams can get the data and perspective they need to tailor their company’s offerings.

It’s also important to research what’s happening in the marketplace and what your competitors are doing. When was the last time you spoke to your benefits broker? They’ll have the greatest visibility into what types of claims employees are filing and where you might have coverage gaps. Working closely with your broker is one of the easiest ways to ensure you’re meeting employees’ expectations and the job market’s standards.

While studies have shown that traditional medical, dental, and vision coverage are still employees’ top priority, here are some non-traditional offerings that your employees may be clamoring for:

  • Parental assistance and leave: Companies are now enriching their policies with tools that assist new parents, including everything from post-birth specialist care to reimbursements for newborn necessities.
  • Virtual medical care: One of the hottest trends is virtual medical care. Employees can have access to a doctor 24/7 via a laptop or smartphone, all in the comfort of their own home.
  • Tuition reimbursement and assistance: Today, Americans owe over $1.3 trillion in student loans. That’s more than twice what they owed a decade ago. Needless to say, young employees are looking for companies that offer some type of student loan assistance.
  • Mental health: Over 18 percent of adults in the United States experience some form of anxiety disorder. Given the growing national focus on mental health issues, it’s no surprise that workplaces are joining the conversation. Increasingly, businesses are offering workers better access to mental health therapists and coaches.
  • Physical wellness: Two words: gym reimbursements. Sometimes the motivation to work out can be hard to muster, but when your gym membership is paid for by your employer, why not take full advantage? Healthier, more active employees could lead to lower medical insurance costs, too!

Those are just some of the unique benefits that you should consider offering employees. At the end of the day, I’ve learned that each workplace has different needs and wants. Be sure to regularly survey employees on their preferences and keep tabs on what peer companies are offering.

SOURCE: Cosme, J. (14 November 2018) "What Benefits and Perks Do Employees Actually Want?" (Web Blog Post). Retrieved from https://blog.shrm.org/blog/what-benefits-and-perks-do-employees-actually-want


Predictive Analytics Will Be The Silent Game-Changer In Employee Benefits

Have you heard of predictive analytics? Predictive analytics analyzes current and historical data to make predictions about unknown events. Read on to learn how this technology could be used to help fine-tune employee benefits offerings.


Last year’s World Series between the Houston Astros and the Los Angeles Dodgers came down to a seven-game battle based not only on talent, athleticism and coaching but also on data. Just as Sports Illustrated suggested back in 2014 via predictive data, the Astros were the victors.

The publication of Moneyball: The Art of Winning an Unfair Game spurred not only Major League Baseball teams to deploy predictive analytics, but also businesses to take a harder look at what their data means. It's no longer part of the hype cycle: Statista forecasts (paywall) that the predictive analytics market worldwide will reach $6.2 billion in 2018 and $10.95 billion in 2022.

I believe we are also at a transformational point in improving corporate employee benefits and our employees’ lives by embracing predictive analytics. HR is swimming in rich data. Instead of guesstimating needs across multiple generations of employees, employers can turn to their own data to fine-tune what they are offering as benefits solutions. Companies spend 25-40% of an employee’s salary on benefits. It simply makes strategic and financial sense to get it right.

Bring Employee Benefits Out Of The Dark Ages

Hiring and retaining great talent is at the very soul of almost every company’s strategy. Not surprisingly, more companies have turned to predictive analytics to give them a leg up in recruitment. However, HR benefits have lagged behind. As John Greenwood reported to Corporate Adviser, “More than half of reward and employee benefits professionals see predictive analytics as a game-changer, but 90 percent are still using spreadsheets to manage data, research from the Reward & Employee Benefits Association shows.”

One reason for benefits lagging behind recruitment in adopting predictive analytics is that the way companies choose new benefits varies greatly from business to business. Given that the majority of HR departments keep data in disparate spreadsheets, even if some HR departments conduct employee surveys or historical cost analyses, they often do not integrate the data about their workforce. If a new benefit offering is chosen based on a needs analysis, only some know the “why” behind a request from the workforce. Knowing how many employees are logging into a benefits platform is helpful; market standard benefit utilization reports provide this level of information. Yet they do not give insight into the underlying reason for an employee to utilize a benefit. The user of deeper analytics is required to look deeper into employees' behavior.

We have found firsthand that many HR departments do not have a full understanding of how their employees are utilizing their benefits across the entire offering suite. A one-size-fits-all or a one-off strategy no longer is effective. Companies must understand not only their employees’ needs but also the underlying data related to these needs to provide a valuable benefits offering.

Put Your Existing Data To Use

For the past five years, I have watched our clients glean valuable insights into what the real underlying issues are for their employees and what must be done to address these pressing needs. I also have been watching companies realize that what they thought were the core problems at hand sometimes were not.

For example, one of our national high-tech clients, with over 50,000 benefit-eligible employees, believed that a high number of their employees had children struggling with autism. This belief was initially based on input from some of their employees. After approximately 16 months, the client reviewed the masked utilization data from their benefit platform. The data illustrated that the overwhelming majority of employee families (tenfold) in fact faced challenges associated with youth anxiety, a concern that had never been expressed to HR previously. Once they reviewed what employees were doing within our platform, their results mirrored the National Institute of Mental Health’s report that approximately 31.9% of U.S. children ages 13-18 struggle with anxiety disorders.

Their own data helped them understand much more specifically where their employees’ stress lay, and their HR department was able to focus communications around it.

Getting Started

Mining and viewing use data across all benefits is ideal. This enables an employer to determine if the benefit suite is serving employees effectively. We have found that as quickly as year over year, users' behaviors shift. If a company solely chooses a benefit based on what they saw as most heavily utilized the previous year, they are not being strategic.

For that reason, HR should utilize past and current data to better predict future patterns of need for a truly strategic approach to benefit choice. With this insight, they can make better choices and serve their workforce more effectively.

Given the limitations across many employee benefit vendors today, to start initially:

1. Embrace KPIs. Agree upon them internally, and measure benefit vendors on them.

2. Work with your current vendors to determine what data they provide to support your internal analysis. Ensure you have access to all the data you need, and if not, consider a vendor change.

3. Hold possible new vendors to similar data standards, and create a transparent relationship from the start.

4. Collect current and historical data. Existing vendors can provide this history, so make sure to collect at least 2-3 years of information.

These analytics need to go deeper than basic demographics to show patterns of activity. In order to understand the benefit needs of your workforce, you'll want to analyze trends across multiple data sets: medical, pharmacy, worker's compensation, biometric screenings, utilization patterns, FMLA requests and demographic trends. From there, you can start to pinpoint what your employees need -- and the “whys” behind the needs -- in order to make a measurable impact.

While predictive analytics is still in the nascent phase in the benefits and vendor worlds, the easiest and most proactive thing any employer can do is to focus on other insights vendors can provide related to the workforce and benefit use beyond simple utilization. In doing so, you will be able to support your employees both in their work lives and their personal lives by providing them with the benefits they need to be at their best.

SOURCE: Goldberg, A. (2 October 2018) "Predictive Analytics Will Be The Silent Game-Changer In Employee Benefits" (Web Blog Post). Retrieved from: https://www.forbes.com/sites/forbestechcouncil/2018/10/02/predictive-analytics-will-be-the-silent-game-changer-in-employee-benefits/#26648166e182


How to Optimize Open Enrollment for Workers

How is your business facing the many challenges associated with healthcare programs? Issues like the ever-changing status of the ACA and rising cost of prescription medications continue to impact every type of employee. Read on to learn more.


Administrators of employer-sponsored healthcare programs face myriad challenges these days, from the rising cost of medications to the fluctuating status of the Affordable Care Act and state healthcare exchanges. As we head into the 2019 open enrollment season, it’s clear that these issues will continue to impact every type and rank of employee in the coming year.

To that end, I’ve outlined several key trends in open enrollment that frazzled HR leaders should explore before enrollment season begins. If it’s too late to make changes to your program this year, use these key points as a basis for measuring and evaluating current programs so you can begin planning for a more engaging, transparent and streamlined process next year.

You don’t have to take it all on yourself.

Employers are realizing that as great as some decision support and health advocacy tools may be, attempts to make employees better healthcare consumers have been only marginally effective.  High-performing (aka narrow) networks may be a viable solution as they enable better rates negotiated with the carriers and providers while reducing waste, errors and unnecessary costs. It’s the steerage option, but plan designs can provide incentives for employees to elect these plans and networks. In turn, the HPNs can provide:

  • more concierge-like service;
  • better coordinated care between providers for high-cost claimants—where much of runaway costs reside; and
  • support to ensure compliance with treatment protocols—for chronic conditions such as diabetes, CAD, COPD, etc.

In turn, these plans have the potential for shaving points off healthcare cost trend.

But it’s vital that communication strategies help reduce fears of reduced network choices (avoiding bad memories of restrictive HMO networks) while increasing confidence in the ability of the HPNs to drive results that actually enhance care while also reducing costs.

The best strategy is to provide easy-to-understand examples and scenarios that represent typical situations based on your company’s demographics and employee personas.

Use all the channels you have.

Education and engagement need to be done through a variety of channels to address the specific needs and preferences of demographic groups. Employees need to compare their options based on anticipated needs to look at both premiums (per paycheck costs) and out-of-pocket costs (deductible, copays, coinsurance), as well as employer-provided HSA contributions and incentives. The premium doesn’t tell the whole story—some people over-insure themselves by paying a higher premium for coverage that they may not use because they fear a higher deductible and out-of-pocket maximum.

Cost-comparison tools, interactive personalized assessment tools, microsites that are mobile-optimized with clear, consistent messaging, and extremely brief interactive videos make the message relevant to each individual.

Remember too that your company portal is both a useful tool in ensuring a personalized message to the employee, and a way for you to collect aggregated data about your employees’ interests, needs, action or inaction, and the user experience.

Don’t try to hit all the bases.

Trying to communicate too much information at one time tends to obscure the key message. Focus only on providing information needed to make effective enrollment decisions and use other points during the year to educate about broader topics like wellness.

A common failure is going paperless and forgetting that you really need to drive employees to resources to get them to pay attention. There may be very robust online content and resources but a very low rate of use of that valuable information. Remember that spouses at home often may be making the majority of the healthcare decisions for a family or, at the very least, for themselves. So going too far with the paperless approach can miss getting the message—and the needed information—to those key stakeholders.

Don’t fear transparency.

It’s intriguing to me that some employers are wary about communicating their level of cost-sharing with employees and how it benchmarks against peer companies. Employees often assume they are paying a far larger share than they are. There are other ways of being transparent about cost-sharing beyond the employer-employee split. For instance, we created an infographic for a client to explain the concept of self-insurance and are using it in an ongoing educational series with fact sheets and videos, getting across the idea that the decisions each of us make about our health and informed healthcare purchasing affect the costs in our individual as well as collective pockets.

The bottom line is that helping employees get smart about how they use healthcare and choose insurance options will save your company money. That’s not as callous as it sounds. If employers can’t find more and better ways to control healthcare and benefits costs, they’ll simply have to shift more of the burden to employees. Healthcare access is onerous enough. No one wants to make it harder or deprive workers of needed care. Healthy, satisfied, financially stable workers are better for business, productivity and the overall economy. Commit to exploring these key trends and making meaningful improvements to open enrollment in 2019 and beyond.

SOURCE: Brooks, B. (16 October 2018) "How to Optimize Open Enrollment for Workers" (Web Blog Post). Retrieved from http://hrexecutive.com/how-to-optimize-open-enrollment-for-workers/


8 ways to maintain HSA eligibility

Employers sponsoring high-deductible health plans with HSAs have to ensure their HDHPs maintain their HSA eligibility. Continue reading for eight ways employers can maintain HSA eligibility.


For employers sponsoring high-deductible health plans with health savings accounts, ensuring that the HDHP continuously remains HSA qualified is no easy task. One challenge in this arena is that most of the rules and regulations are tax-related, and most benefit professionals are not tax professionals.

To help, we’ve created a 2019 pre-flight checklist for employers.

With 2019 rapidly approaching and open enrollment season beginning for many employers, now’s a great time to double-check that your HDHP remains qualified. Here are eight ways employers can maintain HSA eligibility.

1. Ensure in-network plan deductibles meet the 2019 minimum threshold of $1,350 single/$2,700 family.

To take the bumps out of this road, evaluate raising the deductibles comfortably above the thresholds. That way, you won’t have to spend time and resources amending the plan and communicating changes to employees each year that the threshold increases. Naturally, plan participants may not be thrilled with a deductible increase; however, if your current design requires coinsurance after the deductible, it’s likely possible on a cost neutral basis to eliminate this coinsurance, raise the deductible and maintain the current out-of-pocket maximum. For example:

Current Proposed
Deductible $1,350 single / $2,700 family $2,000 single / $4,000 family
Coinsurance, after deductible 80% 100%
Out-of-pocket maximum $2,500 single / $5,000 family $2,500 single / $5,000 family

This technique raises the deductible, improves the coinsurance and does not change the employee’s maximum out-of-pocket risk. The resulting new design may also prove easier to explain to employees.

2. Ensure out-of-pocket maximums do not exceed the maximum 2019 thresholds of $6,750 single/$13,500 family.

Remember that the 2019 HDHP out-of-pocket limits, confusingly, are lower than the Affordable Care Act 2019 limits of $7,900 single and $15,800 family. (Note to the U.S. Congress: Can we please consider merging these limits?) Also, remember that out-of-pocket costs do not include premiums.

3. If your plan’s family deductible includes an embedded individual deductible, ensure that each individual in the family must meet the HDHP statutory minimum family deductible ($2,700 for 2019).

Arguably, the easiest way to do so is making the family deductible at least $5,400, with the embedded individual deductible being $5,400 ÷ 2 = $2,700. However, you’ll then have to raise this amount each time the IRS raises the floor, which is quite the hidden annual bear trap. Thus, as in No. 1, if you’re committed to offering embedded deductibles, consider pushing the deductibles well above the thresholds to give yourself some breathing room (e.g., $3,500 individual and $7,000 family).

For the creative, note that the individual embedded deductible within the family deductible does not necessarily have to be the same amount as the deductible for single coverage. But, whether or not your insurer or TPA can administer that out-of-the-box design is another question. Also, beware of plan designs with an embedded single deductible but not a family umbrella deductible; these designs can cause a family to exceed the out-of-pocket limits outlined in No. 2.

Perhaps the easiest strategy is doing away with embedded deductibles altogether and clearly communicating this change to plan participants.

4. Ensure that all non-preventive services and procedures, as defined by the federal government, are subject to the deductible.

Of note, certain states, including Maryland, Illinois and Oregon, passed laws mandating certain non-preventive services be covered at 100%. While some of these states have reversed course, the situation remains complicated. If your health plan is subject to these state laws, consult with your benefits consultant, attorney and tax adviser on recommended next steps.

Similarly, note that non-preventive telemedicine medical services must naturally be subject to the deductible. Do you offer any employer-sponsored standalone telemedicine products? Are there any telemedicine products bundled under any 100% employee-paid products (aka voluntary)? These arrangements can prove problematic on several fronts, including HSA eligibility, ERISA and ACA compliance.

Specific to HSA eligibility, charging a small copay for the services makes it hard to argue that this isn’t a significant benefit in the nature of medical care. While a solution is to charge HSA participants the fair market value for standalone telemedicine services, which should allow for continued HSA eligibility, this strategy may still leave the door open for ACA and ERISA compliance challenges. Thus, consider eliminating these arrangements or finding a way to compliantly bundle the programs under your health plan. However, as we discussed in the following case study, doing so can prove difficult or even impossible, even when the telemedicine vendor is your TPA’s “partner vendor.”

Finally, if your firm offers an on-site clinic, you’re likely well aware that non-preventive care within the clinic must generally be subject to the deductible.

5. Depending on the underlying plan design, certain supplemental medical products (e.g., critical illness, hospital indemnity) are considered “other medical coverage.” Thus, depending on the design, enrollment in these products can disqualify HSA eligibility.

Do you offer these types of products? If so, review the underlying plan design: Do the benefits vary by underlying medical procedure? If yes, that’s likely a clue that the products are not true indemnity plans and could be HSA disqualifying. Ask your tax advisor if your offered plans are HSA qualified. Of note, while your insurer might offer an opinion on this status, insurers are naturally not usually willing to stand behind these opinions as tax advice.

6. The healthcare flexible spending account 2 ½-month grace period and $500 rollover provisions — just say no.

If your firm sponsors non-HDHPs (such as an HMO, EPO or PPO), you may be inclined to continue offering enrollees in these plans the opportunity to enroll in healthcare flexible spending accounts. If so, it’s tempting to structure the FSA to feature the special two-and-a-half month grace period or the $500 rollover provision. However, doing so makes it challenging for an individual, for example, enrolled in a PPO and FSA in one plan year to move to the HDHP in the next plan year and become HSA eligible on day one of the new plan year. Check with your benefits consultant and tax adviser on the reasons why.

Short of eliminating the healthcare FSA benefit entirely, consider prospectively amending your FSA plan document to eliminate these provisions. This amendment will, essentially, give current enrollees more than 12 months’ notice of the change. While you’re at it, if you still offer a limited FSA program, consider if this offering still makes sense. For most individuals, the usefulness of a limited FSA ebbed greatly back in 2007. That’s when the IRS, via Congressional action, began allowing individuals to contribute to the HSA statutory maximum, even if the individual’s underlying in-network deductible was less.

7. TRICARE

TRICARE provides civilian health benefits for U.S Armed Forces military personnel, military retirees and their dependents, including some members of the Reserve component. Especially if you employ veterans in large numbers, you should become familiar with TRICARE, as it will pay benefits to enrollees before the HDHP deductible is met, thereby disqualifying the HSA.

8. Beware the incentive.

Employers can receive various incentives, such as wellness or marketplace cost-sharing reductions, which could change the benefits provided and the terms of an HDHP. These types of incentives may allow for the payment of medical care before the minimum deductible is met or lower the amount of that deductible below the statutory minimums, either of which would disqualify the plan.

SOURCE: Pace, Z.; Smith, B. (22 October 2018) "8 ways to maintain HSA eligibility" (Web Blog Post). Retrieved from https://www.employeebenefitadviser.com/opinion/8-ways-to-maintain-hsa-eligibility


5 things small business owners should know about this year's open enrollment

Often for small business owners, offering competitive employee benefits is crucial to the way they attract and retain employees. Read this blog post to learn more.


As a small business owner, offering competitive employee benefits is a crucial way to attract and retain strong talent. Whether you currently provide them and are planning next year’s renewal, or you are thinking of offering them for the first time, here are five things you should consider before your employees enter the open enrollment period for next year on November 1st:

1. Small businesses don’t have to wait until open enrollment to offer benefits to their employees

While your employees won’t be able to enroll in health insurance plans until November comes along, small business owners don’t have to wait at all to secure health insurance for their employees. The sooner you act, the better, to guarantee that you and your employees are protected. According to recent studies, healthier employees are happier employees, and as a result, will contribute to a more productive workplace. And a more positive and constructive work environment is better for you, your employees, and your business as a whole.

2. Health literacy is important

Whether you’ve provided health insurance to your employees before, or you’re looking into doing so for the first time, it is always worthwhile to prioritize health insurance literacy. There is a host of terminology and acronyms, not to mention rules and regulations that can be overwhelming to wrap your head around.

Thankfully, the internet is full of relevant information, ranging from articles to explainer videos, that should have you up to speed in no time. Having a good understanding of insurance concepts such as essential health benefits, employer contributions, out-of-pocket maximums, coinsurance, provider networks, co-pays, premiums, and deductibles is a necessary step to being better equipped to view and compare health plan options side-by-side. A thorough familiarization with health insurance practices and terms will allow you to make the most knowledgeable decisions for your employees and your business.

3. Offering health insurance increases employee retention

Employees want to feel like their health is a priority, and are more likely to join a company and stay for longer if their health care needs are being met. A current survey shows that 56 percent of Americans whose employers were sponsoring their health care considered whether or not they were happy with their benefits to be a significant factor in choosing to stay with a particular job. The Employee Benefit Research Institute released a survey in 2016 which showed a powerful connection between decent workplace health benefits and overall employee happiness and team spirit—59 percent percent of employees who were pleased with their benefits were also pleased with their jobs. And only 8 percent of employees who were dissatisfied with their benefits were satisfied with their jobs.

4. Alleviate health insurance costs

High insurance costs can be an obstacle for small business owners. A new survey suggests that 53 percent of American small business owners stress over the costs of providing health care to their employees. The 2017 eHealth report reveals that nearly 80 percent of small businesses owners are concerned about health insurance costs, and 62 percent would consider a 15 percent increase in premiums to make small group health insurance impossible to afford. However, there are resources in place to help reduce these costs, so they aren’t too much of a barrier. One helpful way to cut down on health insurance costs is to take advantage of potential tax breaks available to small business owners. All of the financial contributions that employers make to their employees’ premiums are tax-deductible, and employees’ financial contributions are made pre-tax, which will successfully decrease a small business’ payroll taxes.

Additionally, if your small business consists of fewer than 25 employees, you may be eligible for tax credits if the average yearly income for your employees is below $53,000. It is also beneficial to note that for small business owners, the biggest driver on insurance cost will be the type of plan chosen in addition to the average age of your employees. Your employees’ health is not a relevant factor.

5. Utilize digital resources

You don’t have to be an insurance industry expert to shop for medical plans. There are resources and tools available that make buying medical plans as easy as purchasing a plane ticket or buying a pair of shoes online – Simple, transparent. Insurance is a very complex industry that can easily be simplified with the use of the advanced technology and design of online marketplaces. These platforms are great tools for small business owners to compare prices and benefits of different plans side-by-side. Be confident while shopping for insurance because all of the information is laid out on the table. Technological solutions such as digital marketplaces serve as useful tools to modernize the insurance shopping process and ensure that you and your team are covered without going over your budget.

SOURCE: Poblete, S. (15 October 2018) "5 things small business owners should know about this year's open enrollment" (Web Blog Post). Retrieved from https://www.benefitspro.com/2018/10/15/5-things-small-business-owners-should-know-about-t/


Choosing the Right Flexible Benefit for Employees

HSA? FSA? HRA? Deciding which employer-sponsored benefits will best suit a company and their employees’ needs can often leave employers lost and confused. Continue reading to learn more.


Trying to decide which of the many employer-sponsored benefits out there to offer employees can leave an employer feeling lost in a confusing bowl of alphabet soup—HSA? FSA? DCAP? HRA? What does it mean if a benefit is “limited” or “post-deductible”? Which one is use-it-or-lose-it? Which one has a rollover? What are the limits on each benefit?—and so on.

While there are many details to cover for each of these benefit options, perhaps the first and most important question to answer is: which of these benefits is going to best suit the needs of both my business and my employees? In this article, we will cover the basic pros and cons of Flexible Spending Arrangements (FSA), Health Savings Accounts (HSA), and Health Reimbursement Arrangements (HRA) to help you better answer that question.

Flexible Spending Arrangements (FSA)

An FSA is an employer-sponsored and employer-owned benefit that allows employee participants to be reimbursed for certain expenses with amounts deducted from their salaries pre-tax. An FSA can include both the Health FSA that reimburses uncovered medical expenses and the Dependent Care FSA that reimburses for dependent expenses like daycare and childcare.

Pros:

  • Benefits can be funded entirely from employee salary reductions (ER contributions are an option)
  • Participants have access to full annual elections on day 1 of the benefit (Health FSA only)
  • Participants save on taxes by reducing their taxable income; employers save also by paying less in payroll taxes like FICA and FUTA
  • An FSA allows participants to “give themselves a raise” by reducing the taxes on healthcare expenses they would have had anyway

Cons:

  • Employers risk losing money should an employee quit or leave the program prior to fully funding their FSA election
  • Employees risk losing money should their healthcare expenses total less than their election (the infamous use-it-or-lose-it—though there are ways to mitigate this problem, such as the $500 rollover option)
  • FSA elections are irrevocable after open enrollment; only a qualifying change of status event permits a change of election mid-year
  • Only so much can be elected for an FSA. For 2018, Health FSAs are capped at $2,650, and Dependent Care Accounts are generally capped at $5,000
  • FSA plans are almost always offered under a cafeteria plan; as such, they are subject to several non-discrimination rules and tests

Health Savings Accounts (HSA)

An HSA is an employee-owned account that allows participants to set aside funds to pay for the same expenses that are eligible under a Health FSA. Also like an FSA, these accounts can be offered under a cafeteria plan so that participants may fund their accounts through pre-tax salary reductions.

Pros:

  • HSAs are “triple-tax advantaged”—the contributions are tax-free, the funds are not taxed if paid for eligible expenses, and any gains on the funds (interest, dividends) are also tax-free
  • HSAs are portable, employee-owned, interest-bearing bank accounts; the account remains with the employees even if they leave the company
  • Certain HSAs allow participants to invest a portion of the balance into mutual funds; any earnings on these investments are non-taxable
  • Upon reaching retirement, participants can use any remaining HSA funds to pay for any expense without a tax penalty (though normal taxes are required for non-qualified expenses); also, retirees can use the funds tax-free to pay premiums on any supplemental Medicare coverage. This feature allows HSAs to operate as a secondary retirement fund
  • There is no use-it-or-lose-it with HSAs; all funds employees contribute to stay in their accounts and remain theirs in perpetuity. Also, participants may alter their deduction amounts at any time
  • Like FSAs, employers can either allow the HSA to be entirely employee-funded, or they may choose to also make contributions to their employees’ HSA accounts
  • Even though they are often offered under a cafeteria plan, HSAs do not carry the same nondiscrimination requirements as an FSA. Moreover, there is a less administrative burden for the employer as the employees carry the liability for their own accounts

Cons:

  • To open and contribute to an HSA, an employee must be covered by a qualifying high deductible health plan; moreover, they cannot be covered by any other health coverage (a spouse’s health insurance, an FSA (unless limited), or otherwise)
  • Participants are limited to reimburse only what they have contributed—there is no “front-loading” like with an FSA
  • Participant contributions to an HSA also have an annual limit. For 2018, that limit is $3,450 for an employee with single coverage and $6,900 for an employee with family coverage (participants over 55 can add an additional $1,000; also, remember there is no total account limit)
  • Participation in an HSA precludes participation in any other benefit that provides health coverage. This means employees with an HSA cannot participate in either an FSA or an HRA. Employers can work around this by offering a special limited FSA or HRA that only reimburses dental and vision benefits, meets certain deductible requirements, or both
  • HSAs are treated as bank accounts for legal purposes, so they are subject to many of the same laws that govern bank accounts, like the Patriot Act. Participants are often required to verify their identity to open an HSA, an administrative burden that does not apply to either an FSA or an HRA

Health Reimbursement Arrangements (HRA)

An HRA is an employer-owned and employer-sponsored account that, unlike FSAs and HSAs, is completely funded with employer monies. Employers can think of these accounts as their own supplemental health plans that they create for their employees

Pros:

  • HRAs are extremely flexible in terms of design and function; employers can essentially create the benefit to reimburse the specific expenses at the specific time and under the specific conditions that the employers want
  • HRAs can be an excellent way to “soften the blow” of an increase in major medical insurance costs—employers can use an HRA to mitigate an increase in premiums, deductibles, or other out-of-pocket expenses
  • HRAs can be simpler to administer than an FSA or even an HSA, provided that the plan design is simple and efficient: there are no payroll deductions to track, usually fewer reimbursements to process, and no individual participant elections to manage
  • Small employers may qualify for a special type of HRA, a Qualified Small Employer HRA (or QSEHRA), that even allows participants to be reimbursed for their insurance premiums (special regulations apply)
  • Funds can remain with the employer if someone terminates employment and have not submitted for reimbursement

Cons:

  • HRAs are entirely employer funded. No employee funds or salary reductions may be used to help pay for the benefit. Some employers may not have the funding to operate such a benefit
  • HRAs are subject to the Affordable Care Act. As such, they must be “integrated” with major medical coverage if they provide any sort of health expense reimbursement and are also subject to several regulations
  • HRAs are also subject to many of the same nondiscrimination requirements as the Health FSA
  • HRAs often go under-utilized; employers may pay an amount of administrative costs that are disproportionate to how much employees actually use the benefit
  • Employers can often get “stuck in the weeds” with an overly complicated HRA plan design. Such designs create frustration on the part of the participants, the benefits administrator, and the employer

SOURCE: London, B. (25 October 2018) "Choosing the Right Flexible Benefit for Employees" (Web Blog Post). Retrieved from https://blog.ubabenefits.com/choosing-the-right-flexible-benefit-for-employees


Why You Should Be Benchmarking (and How Hierl Can Help)

As an employer, you have more than likely heard the term ‘benchmarking’ thrown around. It is becoming a critical tool in the development of competitive benefits programs, often helping drive down costs. At Hierl, we are strong advocates for benchmarking. Why? We believe good business decisions can only be made with accurate, meaningful information. Benchmarking is a fantastic way for us – and you – to measure where you stand in all aspects of your benefits against your industry’s standards and competitors. That’s why, in this installment of CenterStage, we interviewed our Executive Vice President, Scott Smeaton.

From an Employer's Eyes - The 3 Scenarios

“When we meet with a business that has not done benchmarking, we are sure to complete that process for them, showing them where they stand in their marketplace,” explained Scott. He emphasized that there are three scenarios that can happen once great advisors, such as those at Hierl, step in and get those results for the employer:

(1)The employer sees that everything around them has changed, they haven’t kept up with the times, and they’ve left money on the table.

(2)The employer is having a difficult time attracting and retaining key employees. With benchmarking, they can view where they should enhance their benefits to be more competitive in their marketplace.

With unemployment as low as it is, many businesses we meet with come from a third, different mindset:

(3) They want to look at their benefits from a total reward or total compensation strategy, where the benefits and the costs of providing benefits become part of a larger picture – time off, vacation, wages, etc.

These three approaches to benefits strategy are why, at Hierl, we strive to blend any and all concerns into a benefits plan strategically designed to get our clients where they need to be to compete for labor. “With a recent client of ours, they were specific about wanting their plans to be in the top 25% of all the plans out there – from a plan design perspective and from a premium cost-share perspective. Using benchmark, we were able to illustrate to this client what they needed to do to accomplish that goal specific to their industry and geographic location,” Scott explained. Benchmark is a powerful tool that can be in any employer’s toolbox, if only you partner with someone like Hierl.

He continued, “When we do our clients’ benchmarks, we take the results further than simply a generic comparison against their competitors. We look at our clients’ specific plan designs, analyzing their deductibles, their coinsurance, their out-of-pocket maximums, their prescription drug copays, and other specifics, as well as how much of the premium the employees must pay out of their paycheck to have coverage. We break down each into five competitive areas: national, regional, state, industry, and employers of similar size.”

Addressing Employers’ Fear of Cost

Some employers may not want to see the results because their current offering isn’t competitive, and it would cost money to adjust their programs to be closer to market. If getting closer to market to compete for labor is their goal, we work with them to create a three- to five-year plan to get there, making incremental adjustments each year. Another common finding is that employers are paying more of the premium than their competitors. Some acknowledge that’s what they want to be doing; others appreciate the information and adjust their cost share so they can reallocate those premium dollars to other benefits, wages, or expenses. This can be an eye-opener, and they likely would not have realized the difference without doing a benchmark test.

Another benefit of benchmarking is how we use the information to educate and engage employees, helping them understand the effort their employer is making to be competitive in the market and how fortunate they are to have the benefits they do compared to others. We use the data during employee meetings to drive the point home. The response is often amazing. We’ve had employees go to their employers and thank them after the employee meetings admitting that they didn’t realize how competitive their benefits are. This also highlights that their employer cares about its employees’ needs and wishes with their benefits, helping the employer retain their key talent.

Partner with Advisors that Listen

If your benefits program isn’t up-to-par – or you’re not even sure where it stands against others in your marketplace – then benchmarking is something you should seriously consider. Even more so, partner with advisors that will want to improve employee perception of your benefits as much as you do. Everyone at Hierl is extremely passionate about helping employers – large or small – identify what it takes to build a successful employee benefits program. To do that, we use the data and listen to the direction the employer wants to go, while also keeping in mind what the employees are looking for. Something we offer to our clients is to survey not only their company through benchmark but to also survey their employees, regarding how they feel and engage with their benefits. Every other year, we go in and do this test with our clients’ employees to ensure the benefits plans we design for our clients are fully comprehensive and hitting every mark. We’re not your traditional broker. We bring tools and resources to the conversation that make a difference. We’re driven to educate and improve both the employer and employee experience, driving down the overall cost of benefits at the same time.

To learn more about Hierl’s services or to begin your benchmark process, please contact our Executive Vice President, Scott Smeaton, at 920.921.5921 or ssmeaton@hierl.com.