The Department of Labor (DOL) is beginning to focus on health plans as a result of Healthcare Reform. For years, the DOL has indicated its intent to review or audit such plans. Until recently, they have only done so very rarely. That appears to be changing. Attached here: DOL Audit Documents and Information Requested.pdf is a sample of 33 pieces of information the DOL wants to see and review as part of an audit. For example:
- Copies of Plan Documents and SPPs
- Copies of health insurance policies
- Copies of notices, including special enrollment rights, Women's Health and Caner Rights, and Michelle's Law notice
- Log of Certificate of Credible Coverage
- COBRA notices and a log of notices used
- Summary of Benefits and Coverage (SBC)
Virtually every employer would have difficulty perhaps serious difficulty providing these documents. It may be time to get one’s house in order, before the DOL comes to audit.