Jennifer Hagen

Since this world of non-discrimination testing is so gray, I have a good one for you. I work for a large physician group. The majority of our workforce are HCEs. We have one health plan with no class distinctions listed in the plan document. All physicians and employees are eligible for the same plan with the same eligibility rules. Here is the contribution structure for non-physicians and the CEO: EE-100%, EE+SP-$400, EE+CH-$250, FAM-$550. Now this is only for the Employees. For physicians we pay 100% of all plans including dependents. Is this plan considered discriminatory? We have passed 125 testing as we are not required to report the premiums paid if the ER pays 100%. Now if the physician works less than FT hours, we do charge them for that portion of the ERs cost of their benefits so in a way we are not treating them the same. In my past life we recommended another physician group to gross up salaries for the physicians so that we show that we are treating everyone the same. What is your recommendation? We have never done 105(h) testing and not sure if we need to do so. Appreciate it! Jennifer Hagen

Since this world of non-discrimination testing is so gray, I have a good one for you. I work for a large physician group. The majority of our workforce are HCEs. We have one health plan with no class distinctions. All physicians and employees are eligible for the same plan with the same eligibility rules. Here is the ER contribution structure: EE-100%, EE+SP-$400, EE+CH-$250, FAM-$550. Now this is only for the Employees. For physicians we pay 100% of all plans including dependents. Is this plan considered discriminatory? We have passed 125 testing as we are not required to report the premiums paid if the ER pays 100%. Now if the physician works less than FT hours, we do charge them for that portion of the ERs cost of their benefits so in a way we are not treating them the same. In my past life we recommended another physician group to gross up salaries for the physicians so that we show that we are treating everyone the same. What is your recommendation? We have never done 105(h) testing and not sure if we need to do so. Appreciate it! Jennifer Hagen