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Have you received a DOL audit notice? What would be your biggest audit concern?
Employers who are subject to COBRA can also be subject to a DOL audit of the documents, procedures and processes related to those benefits.
With The Patient and he DOL’s audit scope has expanded to include Affordable Care Act (ACA) compliance. Employers (plan sponsors) should maintain a binder or electronic file that provides easy access to written records of all the ACA compliance steps and procedures they’ve made.
If you receive an audit notice, it is most important that you find answers and proper documents before the examiner arrives.
Review your personnel records and confirm:
- How many qualifying events occurred in the audit timeframe
- Documentation that qualified beneficiary was notified of their rights to continuing health coverage
- Your process of notifying plan administrator that a qualifying event occurred
- Coverage that each qualified beneficiary elected
- COBRA premium payments that have been paid or are due from the qualified beneficiary
- Reasons for termination of COBRA coverage properly elected by the beneficiary
On a regular basis, employers should audit the plans and processes to assure compliance, which now includes the ACA.
Organized and efficient procedures will result in an easy resolution to the DOL audit.
Be prepared with the right documents regardless of grandfathered status.