"Employers with self-funded GHPs should ask their claims administrators if they are engaging in cross plan offsetting with respect to the employers' GHPs. If so, employers should consider stopping that practice and asking the claims administrators to reprocess prior benefit claims.... Employers should perform a compliance audit of their employer mandate reporting process to ensure that the proper reports with the appropriate codes are being filed with the IRS and provided to employees.... Employers should make sure that their claims administrators are following the ERISA claims rules with respect to any partial or complete denial of a benefit claim."  MORE >>