I recently came across this article, published by Business Insurance with the following headline "Few employers offer transgender benefits". This article, along with the growing news coverage around bathroom use for transgender, prompted me to investigate exactly what percentage of the population here is impacted. According to two of the largest surveys ever conducted on the topic, approximately .3 percent or 700,000 people in the United States identify as transgender.
"Let food be thy medicine and medicine be thy food." - Hippocrates When the father of western medicine, Hippocrates, gave us this quote back in the times of Ancient Greece, he was providing one way of solving the public health crisis of our time. I like what Dr. Albert Schweitzer said even better, "It's supposed to be a secret, but I'll tell you anyway. We doctors do nothing. We only help and encourage the doctor within."
When we sit down with the leadership of our clients and their HR/Benefit departments, we usually get heads nodding when we share that 40-50% of Americans born after 2000 will have diabetes. There are plenty of peer-reviewed case studies to show that leading companies who invest in establishing a culture of health and accountability in the right way experience returns that go far beyond the expense side of the ledger.
If your company sponsors a health plan (excluding small plans), and you have administrative oversight of that plan, you must get a Health Plan Identifier (HPID) under HIPAA by November 5th, 2014. You might be saying, I already have a lot on my plate or I would rather wait to do this in November. Sure, you could wait until things get slower around the fall during open enrollment or look into this before the holidays. Or you or a member of your HR/Benefits team could knock it out today.
Here are the instructions our firm put together to assist our clients.
This is being required by our federal government ... don't shoot the messenger ... we are simply trying to urge our clients to do this now.
Listen in and apply these principles to our corporate-wellness initiatives. We could not agree more that intrinsic over extrinsic motivators provide longer-term results. We welcome your comments below and invite you to read Dan Pink's Drive to compare with Thaler and Sunstein's Nudge.
This post is a must read for any plan sponsor who does client work with the federal government and submits employee benefit related expenses associated with contractors on the job. I want to thank Dependent Audit Eligbility veteran, Brennan Clipp, for sharing with me an internal memorandum obtained from the Federal Government's Deparment of Defense ("DOD"). Even if an employer might not contract directly with DOD, we can be certain other government agencies issuing awarding contracts on large public works projects will follow similar protocol. In fairness to our U.S. government, they are simply saying that reimbursement for the cost of fringe benefits are allowable from contractors and dependents of those contractors, as long as the dependent adheres to the eligibility under the plan. Further, "contractor's that fail to implement sufficient procedures to identify and exclude health benefit costs associated with ineligible dependents are in noncompliance with FAR 31.201-6 and CAS 405. They are recommending that contractors put in audit and process procedures to protect against ineligible dependents.
As is a common practice for plan sponsors who do a lot of design and build work for the Federal Government, reimbursement is often a part of contract reimbursement sought for employee benefit expenses related to contractors and their dependents covered under an employee benefit plan. The irony here is that the left hand of government recently gave us expensive health insurance legislation and the right hand of government is warning against seeking reimbursement of those expenses for [ineligible] contractor benefits.
The Memo we obtained here esentially warns a plan sponsor against submitting any healthcare related expenses associated with ineligible employees or dependents who do not strictly adhere to the eligibility guidelines under the ERISA plan. Ms. Clipp's firm warns against an employer taking on this project themselves or leaving it to a service provider that does not follow evidence based guidelines for verification. When done correctly, ineligible dependents can average between 12-18% disenrollment. This does not come as a surprise with unemployment hovering near 10% and escalating healthcare costs. Finally, an ongoing audit process can ensure ineligible insured's do not creep back onto the plan when the guard goes down. Another reason for doing a dependent audit stems from the ERISA fiduciary obligation implicit to other eligible enrollees under the plan.
There are a number of high-quality speciality firms and important cultural and senior management issues to address internally before human resources should launch. The notion of eligibilty management as a cost saving tool is not new, but the federal government's validation of a dependent audit as a cost savings mechanism was strong enough to provoke this notice out to field auditors of the Federal Governement.
If you're not sure of the Top DOD contractos ... here's the list of the top 100:
Amid a flurry of new federal legislation, employers are beginning to gain a better understanding of the new Breaktime for Nursing Mothers law (Section 4207 of PPACA). Employers with 50 or greater employees must provide a reasonable break time for expectant mothers to express milk at the workplace. Many sources say a reasonable break time can be estimated at 30 minutes for every 4 hours. Employers who are under 50 employees who can show signs of hardship through "difficulty of expense" in complying will be exempt. Our employee benefits counsel has confirmed that it is not based on the number of employees at a given location, but rather the total number of employees that work for the company as a whole, subject to Fair Labor Standard Act (FLSA) definitions. Employers will not be required to treat the break as compensable time. While this law is already the standard for many larger employer worksites, many small to mid-size employers cramped for space are scratching their heads. Furthermore, it is logical to question a burden of compliance for certain industries (oil & gas rig, coal mines, etc...) The new guidance confirms the station cannot be a bathroom and that it must be free from intrusion and shielded from view.
While the effective date is coincident with the day President Obama signed PPACA into law, the rules for enforcement have not yet been released. We anticipate Department of Labor (DOL) to provide the penalties for non compliance and give employers a time frame to comply. For more guidance on employer best practices, you can visit the United States Breastfeeding Committee available links.
The late Peter Jennings reports on our broken healthcare system:
So many people spend their health gaining wealth, and then have to spend their wealth to regain their health. - A.J. Reb Materi, Our Family
While all of the major carriers have announced they will cover the cost of flu vaccinations for their fully-insured customers, some of my self-funded clients questioned the value of paying $20.00 for each regular or swine flu vaccination for each employee. Well as a patient stricken with the infamous Swine Flu, I thought I would share the cost of my personal experience: Cost of a Primary Care Visit, Chest X-Ray, and Nasal Swab = $134.77
Cost of Tamiflu = $108.11
Total Medical & Rx Cost = $242.88 (In-network contracted rate)
Amount Paid Under my HSA Account = $242.88
COST OF NOT INFECTING ANYONE ELSE: PRICELESS
While the above scenario clearly shows the cost avoided under your healthplan for $20 worth of prevention, we haven't even factored in the greatest cost for a company .... lost productivity. Since my PCP recommended 5 days quarantine from my wife and kids (and everyone else), I had to undergo 5 days of isolation and lost productivity. Since I had my laptop at home and could work 50% of the time, I will factor that into the equation. Total cost of medical, rx, and lost productivity = $5,742.88.
Should you cover the cost of a flu vaccination ... the answer is a resounding YES. Your employees will know they work for a company that invests in its greatest asset ... their people ...VALUE OF LOYALTY TO YOUR ORGANIZATION: PRICELESS
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The science of behavioral economics is readily available for deployment in the workplace. If we play a role in the health and retirement options available to our employees, we are "Choice Architects". Listen to Professor Thaler describe the concept of "Nudge" and what it means to be a "Choice Architect". Since Nudge: Improving Decisions About Health, Wealth, and Happiness exploded onto the scene this summer, politicians in the United States and United Kingdom have embraced the book's belief that with a gentle guidance from designers, employers, or even the government, people can make better decisions independently. The work of coauthors Richard Thaler, the Ralph and Dorothy Keller Distinguished Service Professor of Behavioral Science and Economics in the Chicago Graduate School of Business, and Cass Sunstein, the Harry Kalven Jr. Visiting Law Professor, has become part of the political conversation around the world, finding allies on all sides of the political spectrum.
The key may be that the central idea in Nudge does not fall neatly into any political camp. Instead, it requires what Thaler calls "libertarian paternalism," a phrase that, he admits, sounds like an oxymoron. "By 'libertarianism,' we mean protecting people's right to choose," Thaler says. "By 'paternalism,' we mean caring about people's outcomes. We want to devise policies that will make people better off–choices that they themselves think are better."
If video does not appear in your browser click link: http://www.uchicago.edu/features/20081006_nudge.shtml
Source: University of Chicago - Graduate School of Business (P. Houlihan)
This video is for any HR professional that is in need of help in changing the culture and mentality of the senior management team. The companies that make the "Best Companies to Work" list understand this. Their culture is typically driven by a way of doing things in the organization that comes from the top down. Employee benefit programs alone play only one part of what keeps you on the "Best Companies" lists over the long haul. http://www.youtube.com/watch?v=4ZlfReH8znM
How "Green" Are Your Benefits? You work as a leader at your company and consider yourself a socially conscious member of society ... you might even drive or have thought about purchasing a hybrid or electric vehicle. Your firm has been repositioning itself in the marketplace with statements about the company's carbon footprint, recycling initiatives, electronic annual reports and even the ever popular "think before you print" email signatures. Well before you can slip on your Birkenstocks ... have you ever considered what part you can play to align your benefits strategy with this business strategy. So just how "Green" are your employee benefits?
Here are three ways you can manage your benefits to bolster the corporate statement on social responsibility:
1) Add a Section 132(f) transportation benefit
This could make sense if you require employees to pay for parking, ride bicycles are take the bus to work or have employees that live or work near a transit station. The benefit is called a Qualified Transportation Fringe Benefit. It works much like a Section 125 plan and allows employees to set aside pre-tax amounts to pay for qualified transportation fringe benefits. These include (1) qualified parking (2) transit passes, and (3) transportation in a commuter highway vehicle like DART. The use of these compensation reduction agreements is allowed under IRS Section 132(f) and provides qualified transportation fringe benefits resulting in federal (and possible state) income tax savings for employees and FICA savings for both employees and the employer.
The recent Obama stimulus package increases the maximum monthly pre-tax contribution for mass transit up to $230 per month. This amount nearly doubled from prior periods allowing commuting Americans to save up to $1,000 a year in taxes and an employer up to $100 per employee per year in payroll taxes. Employers that adopt this benefit and make reimbursements must establish a bona fide reimbursement arrangement implementing reasonable procedures to establish that their employees have, in fact, incurred expenses for transportation in a commuter highway vehicle, transit passes, or qualified parking. Since most HR departments have limited staff, we advise outsourcing the communications, enrollment, and administration to a reputable service provider.
2) Eliminate outdated paper-based enrollment
Web-based software as a service has now proliferated to the point where the unit costs for conducting online enrollments are now affordable for most employers. The costs are usually based on a set up fee and a per employee per month fee based on a unique log-in or eligible benefit employee. Unit costs will decrease as your eligible enrollment increases. A corporate intranet or web-based kiosk can always be made available for those without internet access at home or office. Some clients prefer to do web based open enrollment and manual ongoing status changes or conduct new hire and status changes online throughout the year.
We're not foolish enough to discount paper completely, as it serves its purpose for directing individuals and calling attention to major changes. A wise paper manufacturer rep once told me ... "we WILL go paperless in our society when we stop using toilet paper". I told you he was wise.
3) Inform service providers of your corporate social responsibility initiatives
This last recommendation is all about investigating whether your service providers are able to adhere to your global brand positioning on taking environmental responsibility. You will find most of your service providers would rather opt to send an Explanation of Benefits (EOB) via the web or through the portal than in the mail. Additionally, savings in mail are available if you can furnish your service providers email address and use this as the default, where applicable. Ask your benefits broker or consultant to investigate how much in fee concessions can be leveraged as your service providers communicate everything from EOB's to 401(k) statements electronically.
You'll be not only improving your carbon footprint but might be saving your company some money along the way.