The U.S. Department of Labor (DOL) has been increasing audits of employee welfare benefit plans–including group health plans–sponsored by companies of every size. An audit can happen at any time, so it’s important to stay on top of compliance. The checklist below can help you prevent and be prepared for a DOL audit.
- Maintain all documents related to welfare benefit plans in one location.
- Designate one person at the company to take charge of the welfare benefit plans.
- Respond in a timely fashion to all participant and beneficiary questions.
- Review and understand all plan documents.
- Make sure all benefit plans covered by the Employee Retirement Income Security Act (ERISA) comply with relevant laws, such as Health Care Reform and the Health Insurance Portability and Accountability Act (HIPAA).
- Distribute summary plan descriptions (SPDs), with accompanying benefit plan component documents such as benefits booklets and certificates of insurance, to all plan participants within 90 days of becoming covered under the plan.
- Administer all ERISA-covered benefit plans, including group health plans and other welfare plans, in accordance with a written plan document.
- Respond to participant and beneficiary requests for an SPD and plan document within 30 days after a written request.
- Inform participants of any material change to the plan either through a revised SPD or in a separate document, called a summary of material modifications (SMM).
- Distribute required notices, such as COBRA (continuation of health benefits) and SBC (summary of benefits and coverage) notices, within required timeframes.
- If Form 5500 must be filed, be sure to complete all components accurately and file before the required deadline.
Establish written procedures for disputes and claims resolution.
The section on DOL Audits within the Client Resource Center HR Library features other tips for navigating through a DOL health plan audit and a list of documents that are typically requested from employers as part of the process.