Automatic Reimbursement Feature?

[Guest ngoff]

We have a new group coming on with us and they have a Flex Plan. With their old carrier they had an automatic reimbursement feature where their claims were submitted through the regular health plan and anything that was not covered like deductibles would automatically be put through their Flex Plan for reimbursement through the Health FSA. It was my understanding that participants had to submit these uncovered charges to us with a request form that had a statement on the bottom saying that the claim has not been reimbursed elsewhere, etc. Do they have to have that statement every time or can they sign off on something at the beginning of the plan year so we can do the automatic reimbursement for them? Any regulations on this? Anybody have any information regarding this situation?

[Guest Lee Ann Jenkins]

I've been agonizing over this for years. I've been running the Flex Department for a TPA since before the advance reimbursement rules went into effect. The first time I implemented this "automatic" feature, I required that an authorization be signed with each claim submitted. The wording was such that the employee verified that whatever was left over from the claim he was submitting was not reimbursable from any other source. After a few years, and with the implementation of more "high tech" methods of submitting claims, we had to come up with something else. Now I get each employee who wants to use this "automatic" forwarding feature to sign an authorization form at the beginning of each plan year. The statement he/she signs spells out that if they or any of their family members who will be having claims processed by our company has any outside coverage for any portion of the expenses to be submitted, they are not eligible for this service. If they don't have outside coverage, then they sign the statement which also spells out that they must notify us if their outside coverage situation changes at any time during the year. Then and only then will I let claims roll over from our claims system to the Flex system for reimbursement. I've never been questioned on this practice, so I'm not entirely sure it's 100% legal, but the effort to do it right is there along with the participant's signature.