Have You Performed a Department of Labor Self Audit?


As sense of anxiety rushes through you before you open the somewhat thin letter that is addressed to you and your company form the Department of Labor.  Time slows, you feel the affordable fibers of the letter and your eyes are drawn to the corner of the envelope unfamiliar with the markings within the DOL seal.  You open the envelope, overwhelmed with the magnitude and all you see is within ten (10) business days and submit all documents.

You pause again.  You remember this is not an action thriller and that you have a very busy day ahead of you.  You open and read the nine-page document with true disbelief.  Your first thought is how could I have been better prepared?

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Next Steps to a DOL Self-Audit

A little preparation goes a long way with a DOL Audit.  The DOL has recovered over 777 Million dollars in 2016 and with increased enforcement, many more dollars and aggravation will be paid by employers.  Below you will find 5 areas were employers need to review for a DOL Self-Audit.


Top 5 Missing Areas/Documents Employers Need for a Benefit DOL Audit 

The top ten documents and areas to locate and file when performing your self-audit

  1. Summary Plan Descriptions (SPDs) & Plan Documents
    1. The Plan Administrator, you the employer, are responsible for SPDs. Do not confuse a Certificate of Insurance as an SPD and pick up the phone and confirm you have these in place.  Clarus can help anyone in the United States, if needed.
    2. Form 5500 and supporting documentation.
    3. Properly furnished and distributed by DOL Guidelines
  2. Wellness Program Guidelines
    1. Are you compliant with HIPPA’s rules governing accessibility of rewards and communicating it properly?
  3. Summary Plan Description Distribution and Delivery Rules
    1. In line woth DOL rules?
    2. COBRA Qualified beneficiaries
    3. Approved distribution channels
    4. Electronic distribution disclosures signed?
  4. Required Federal Notices and Disclosures
    1. Newborns’ and Mothers’ Health Protection Act
    2. Women’s Health & Cancer Rights Act
    3. Annual Children’s Health Insurance Program (CHIP) Notice
    4. HIPPA Special Enrollment Rights
    5. Pre-Existing Condition Exclusion Disclosure
    6. Mental Health Parity Act and Addiction Equity Act
  5. PPACA and the “Winding Road”
    1. Grandfathered?
    2. Mandates for Non-Grandfathered
    3. New Executive Mandates/Adminstration

As you are working on your audit and find that you are getting more compliant with every day,  please remember to do these three things to lower your chances

  1. Take the time to respond to your employees and participants questions in a timely manner.
  2. Make sure your Form 5500 is completed properly.
  3. Keep your documents up to date and organized.