October 20, 2016
By: Mary Anne Cody
Mary Rosen, the Associate Regional Director of the United States Department of Labor for New England including Upstate New York gave a presentation Wednesday on common issues with health care plans. She also described six tips for common plan errors and three new initiatives the DOL is working on.
This seminar hosted by Anthony Stevens was a very good opportunity to hear what issues the Federal DOL is focused upon.
Based upon common errors seen by the DOL the six tips for health care plan fiduciaries to consider are:
1. Carefully select and monitor service providers
2. Make required disclosures to participants and beneficiaries
3. If a request for disclosure is made, disclose as much as possible
4. Understand your plan and your responsibility
5. Make timely contributions and monitor use of plan assets
6. File reports with Government and keep good records
Federal Department of Labor Health Care Plan Initiatives described by Ms. Rosen:
1. Health Benefit Security Project:
A comprehensive national health enforcement project combining the ESBA (Employee Benefits Security Administration) health plan enforcement initiatives with the new protections under the Patient Protection Affordable Health Care Act of 2010.
2. Self-Funded Health Case Fees Initiative:
This project seeks to uncover hidden fees in self-funded health plans. The project includes the review of fees commonly found in self-funded health plans including base medical service fee, recovery of overpayments, subrogation, corporate group and third party revenue, medical benefits drug rebate payments, stop-loss premiums and other fees and services.
3. Emergency Services Project
A project to determine if health care plans are complying with the Patient Protection requirements of the Affordable Care Act with respect to the coverage of emergency services. This project will 1) identify large self-funded health plans 2) that provide coverage for emergency services and 3) determine if services will be covered and whether the plan is properly reimbursing for out-of-network emergency room visits.