TWENTY-TWO COMMANDMENTS FOR A SUCCESSFUL DEA
- Compliance with Federal, State, local, and union regulations and contract commitments.
- Consideration of the diverse cultural variations in your workforce.
- Full buy-in from your executive staff and other stakeholders.
- Scenario testing of your implementation decisions.
- Multi-year eligibility compliance planning.
- Maintaining good employee relations.
- Early communications for buy-in.
Twenty-Two Commandments for a Successful DEA
While this list may not address every issue, it is a good checklist to review when planning an audit or to test your audit plan against before starting the audit. This equally applies to companies and TPAs or Brokers. Consider everything you can think of during the planning cycle and not wish that you had during the audit when a situation
1. Audit planning should include input and buy-in from all stakeholders.
2. Review and update your summary plan description and all other company documents to clearly define, in layman's terms, the eligibility guidelines.
3. Company executive, management, and officers should lead the way. No one is exempt from the audit.
4. Communicate early and often to get maximum awareness and buy-in from your employees.
5. Non-responsiveness and late submittals should have clear and standardized consequences supported by the executive staff...no exceptions.
6. Provide a compassionate audit exit plan so those found to be ineligible can be directed toward affordable private coverage.
7. When establishing ineligibility consequences, a santity check of role-playing scenarios with the most and least valuable employees. Don't create consequences that you can not live with.
8. Pre-audit plannig should consider all scenarios so that a standardized implementation will be undnerstood and implementated without the need for ADHOC policy development during the audit
9. Consider sharing some of the savings with the subscribers.
10. Compliance maintenance should be part of a multi-year plan.
11. Eligibility should be established by a dual criteria of relationship and financial responsibility.
12. Be sure that your audit plan is in full compliance with all laws and legal agreements.
13. Make sure that your Fiduciary is well aware of their responsibility for maintaining compliance.
14. Customize your audit to conform to your company or client's culture.
15. Make the hard decisions during the planning cycle as to consequences associated with well dfined levels of fraud and don't deviate.
16. Send a clear message to all subscribers that the company is serious about ineligibility and will enforce defined actions.
17. Leave no open issues with subscribers un-resolved.
18. Recognize that some issues need special review and executive awareness before declaring a dependent ineligible.
19. Make sure the document review staff are well trained in the impact and sensitivity of their task.
20. Understand that the american concept of family and dependents may not be fully understood by those of other cultures.
21. Companies should not overlook that some subscribers who knowingly enrolled ineligible dependents may also have other behavior that is unethical...ineligibility may just be the tip of the iceberg.
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