alexa

We are significantly redesigning our calendar year health plan effective 10/1/2002 (don't tell me; I've already suggested waiting until 1/1!) We are eliminating all of our HMO's (50% of our workforce participate in these) and also eliminating our POS and indemnity options. We will be going to 1 national PPO plan with single and family coverage. There will be greater employee cost sharing as well My question has to do with our 125 plan. We are allowing employees to opt out of coverage or to keep thier current coverage. Must we allow them to go to single if they currently have married coverage? I assume that they can't go from single to married snce that will cost more? Also, what would a significant increase in cost be %wise? 20%? I understand that they cannot change their health FSA election prior to next year's open enrollment (1/1/2003) Any insights into this would be greatly appreciated along with very good reasons to wait until 1/1/2003 to implement the new plan.

We are significantly redesigning our calendar year health plan effective 10/1/2002 (don't tell me; I've already suggested waiting until 1/1!) We are eliminating all of our HMO's (50% of our workforce participate in these) and also eliminating our POS and indemnity options. We will be going to 1 national PPO plan with single and family coverage. There will be greater employee cost sharing as well question has to do with our 125 plan. We are allowing employees to opt out of coverage or to keep thier current coverage. Must we allow them to go to single if they currently have married coverage? I assume that they can't go from single to married snce that will cost more? Also, what would a significant increase in cost be %wise? 20%? I understand that they cannot change thier health FSA election priro to next year's open enrollment (1/1/2003) Any insights into this would be greatly appreciated along with very good reasons to wait until 1/1/2003 to implement the new plan.

I have a collectively bargainned DB plan where for anyone retired after 10/1/1995, efective 11/1/2002 the retirement income is recalculated effective 11/1/2002 to be $ 70 per month of Credited Service; prior to 11/1/2002, the multiplier was $ 68 This is a benefit that was collectively bargained and the plan was amended for the prospective increase. Assuming as part of current negotiations, this is rescinded, would this violate anti-cutback rules if the current benefit remains the same; i.e. increase not given?

Thanks We have 50,000 participants so I guess it's best to go with new 45 day proposed reg requirment as a safe harbor and good faith interpretation of EGTRAA changes

I thought the new proposed regs require more info than just a notice if benefits are significantly curtailed? Are we required to give a 45 day advance notice or can we still use old 15 day since regs are only proposed?

Is an accrued benefit statement required upon a complete freeze of benefits under a DB Plan? If an accrued benefit statement is not a requirement what is? Can we still use 15 day notice requirement rather than 45 day new proposed regs since recent regs on notice requirements are only proposed regs?

We are majorly redesigning our group health plan It is my understanding under an interim DOl reg that a summary of material reduction must be given 60 days after changes adopted What is adoption date? Effective date of change? We are working with several CBA's (i.e. collective bargaining units) to negotiate these changes. Would date union ratified chnages be the adoption date? In a retirement plan it is much easier, adoption date is date plan amendment signed Any input would be appreciated Thanks

The new SPD rules require plans to include a summary of fees on a participant's individual account the payment of which is a condition to the receipt of benefits I assume this means stuff like loan setup & maintanance fees, hardship withdrawal fees, in-service distribution fees, etc... We were charging a quarterly recordkeeping fee that is being waived this year by our provider, I assume this is not included in the SPD nor investment related fees, correct?

We have some employees who would like to have their unused sick/vacation leave deposited into their 401(k) plan. If we do not have a use-it-or-lose-it policy , is there a problem? We allow employees to carry-over some vacation and sick time. Also, I had read something about it being futile in certain states like CA which has specific rules vesting al vacation pay? Also, I understand since treated like an employer nonelective contribution is subject to benefits, rights & features testing? For anyone who has implemented this, I'd like your input.We have 1/2 dozen bargainning units with varying leave policies. Thanks

The plan covers only collectively bargainned so no ACP testing required

We limit HCE's to 10% 401(k) pre-tax employee contributions in 1 of our collectively bargained plans to pass 401(k) testing. We do not currently match We are thinking about adding an after-tax feature to our plan due to HCE participants inquiring. Can we allow a 15% after -tax ? Are there any restrictions/limits on after-tax other than making sure we don't exceed 415 limits which now have been raised to 100% of compensation? I do understand that we will have more administration as a result of adding this feature. Can you point me to cite if any restrictions

The actual in-house procedure that we follow in determining whether qualified or not, simialr to a QDRO procedure. It is my understanding , like the QDRO Procedure, we can reference it in SPD but then need to give out separate prodecure to participants upon request. Currently we do have a QDRO procdure but alas no QMCSO Procedure and a sample would be helpful rather than starting from scratch. Thanks!

Does anyone have a sample QMSCO Procedure they would share? Thanks

No, we are self insured & only use them for claims I am concerned about the HMO's we have in 18 states If it means contacting each of them can do; was just wondering if there were a central list available rather than having to do that

Would anyone have a good sample QMSCO Procedure that they would like to share Thanks

We are in process of rewriting our Health Plan SPD for the new SPD rules among other things 1 of the numerous requirements is to include state laws on hospital lengths of stay for childbirth in addition to the federal NMHPA disclosure. We have employees in 50 states. Does anyone have a good state-by-state summary of this or can point me in direction of where I can obtain? Thanks

Do any states tax pre-tax 125 amounts?

I am looking for a sample of a Statement of Compliance to have our DC plans vendor certify to each quarter that they have been administering the plans in accordance with plan and trust documents. Has anyone done anything similar? Thanks

Are Employee Assistance Plans subject to the new HIPAA EDI & Privacy rules?

Thanks benefits attorney Yes I was referring to this cite when I read the claims regs We do have such a procedure spelled out in the collectively bargained agreement (it is not Taft Hartley). Parts of the procedure reference our LTD plan document, specifically on timing matters Currently our plan document has the old 60 day stuff Is it ok to leave this alone or do we need to amend plan doc for the new 45 day rules?

The DOL claims rules that were finalized on 11/21/2000 , They changed the timeframes for processing of claims for both health & disability plans.

Not to seem dense, what is a HIPAA compliant paper trail Thanks Alexa

We have 2 LTD plans that cover collectively bargainned unions. As long as their is a claims review process in place spelled out in combination of agreement/plan document, are these LTd plans exempr from the new claims rules? Any insight would be appreciated

We are a large employer (not in the healthcare industry) in 50 states that self-insures it medical plan and also has about a dozen HMO's in some states. We outsource the administration to UHC for the self-insured part of our medical plan. The problem I am having is trying to determine what is considered PHI (protected health information) internally that falls outside of TPO (treatment, payment or healthcare operations) Would anyone have a good list? Also in our HR dept. we separate our health benefits administration group from the group that handles FMLA and other employment based issues. Our workers comp(although headquartered in a separate state reports into headquarters) & LTD functions are part of benefits health admin in corporate We have employees(HR reps) in the field who may come into play with PHI on a day-to-day basis It seems to me at first glance that this may be monumental companywide I read that workers' comp is exempt from the privacy rules? What about disability plan administration and FMLA? I also understand that "firewalls " must be in place between anyone who handles PHI for the health plan and other benefits/employment administration. Does anyone have any good recommendations here? Our FMLA group from time to time may have interaction with our helath benefits admin group and the same for our disability administrators (they actually report into Benefits Admin as well) We get involve dquite a bit in helping ees try to resolve claims/payment issues -does this fall under the "payment" exclusion? Thanks for any and all insights

We are in the process of designating a Privacy Officer for HIPAA What have others been doing?; i.e. who in your firm is the "designee"? We have come to the conclusion that we may need to create a new position for this We are an employer who sponsors a health plan; we are not a healthcare entity Would anyone have a good job description for a Privacy Officer Thanks