LTC 538-2018 Health Dependent Eligibility AuditMIAMI BEACH OFFICE OF THE CITY MANAGER
NO. LTC#
LETTER TO COMMISSION 538-2018
TO: Mayor Dan Gelber and Members of th
FROM : Jimmy L. Morales, City Mana
DATE: October 4, 2018
SUBJECT: Health Dependent Eligibility Audit
BACKGROUND
Statistics shows that approximately 2-10% of enrolled dependents in a typical employer's medical
plan are ineligible for coverage. With an average cost per dependent of $3,500, the financial
impact of these ineligible dependents is significant, both in terms of current and future claims
costs. Covering ineligible dependents drives up the cost of health care for all its participants.
Every employer is at risk for carrying ineligible dependents on their health and dental plans which
may consist of ex-spouses, common law partners , grandchildren, and extended family members.
The City engaged BMI Audit Services for a comprehensive Dependent Eligibility Audit, which
began in January 2018, as a cost savings exercise designed to identify, report and dis-enroll
ineligible dependents from our medical and dental plans. The benefits of a Dependent Eligibility
Audit include:
• Best practice for risk avoidance ;
• Improved internal controls to assure accurate enrollment records, documentation and
communications;
• Immediate measurable results as ineligible dependents are removed from coverage;
• Confirmation that plan participants understand eligibility requirements and definitions; and
• Avoidance of potentially large and unexpected costs if "stop-loss" claims are denied for
ineligible dependents.
BMI provided the City with an Audit Process Guide outlining materials required for the audit, roles
and responsibilities of each party involved in the audit, and a timeline for the audit process . The
first mailing to health plan participants began January 5, 2018 and the audit closed April 30, 2018.
The eligibility file that was used to perform the review included the following breakdown within its
1,304 families. (For purposes of this audit, a family includes the employee and all dependents in
the same household.)
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Dependent Eligibility Audit
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Member Type Record Count
Employee 1,304
Dependent Child 1,578
Legal Spouse/Domestic Partner 1,085
Total# of Employees 1,304
Total# of Dependents 2,663
Total# of Members {Employees+ Dependents) 3,967
AUDIT FINDINGS
The City achieved a 96.93% employee response rate to the dependent verification process.
Below is a chart summarizing the status at the completion of the audit for each of the 1,304
families:
Audit Status #of Employees % of Employees
Complete -All Documentation Received by BMI 1,264 96.93%
Incomplete -Documentation Missing in Response 22 1.69%
No Response 18 1.38%
Total Family Count 1,304 100.00%
Using the parameters of plan eligibility criteria, BMI confirmed that 73 dependents were ineligible
for failing to meet all requirements set forth in the City's heath and dental plan documents. See
the chart below for specific results:
% of Ineligible
Reason for Ineligible Status #of Dependents Findings
Dependent is overage and does not meet criteria to continue coverage 6 8.22%
Employee and listed spouse are not married 2 2.74%
Employee and listed spouse are divorced 9 12.33%
Emloyee and listed domestic partner are no longer partners 1 1.37%
Employee has requested to remove this dependent from coverage 55 75 .34%
Total Dependents with Ineligible Status : 73 100.00%
Below is a demographic breakdown of the confirmed ineligible dependents:
% of Ineligible
Member Relationship of Ineligible Dependents #of Dependents Findings
Dependent Child 54 73.97%
Legal Spouse/Domestic Partner 19 26.03%
Total Dependents with Ineligible Status: 73 100.00%
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Dependent Eligibility Audit
Page 3
Of the 73 dependents who failed to meet plan eligibility requirements, 36 did not require coverage
termination due to events which took place after the City provided the initial dependent listing to
BMI Audit Services prior to the outset of the audit. Examples of those events include:
• Coverage was already terminated on December 31, 2017 for dependents who attained
age 26 after January 1, 2017.
• Coverage was already terminated due to employment termination which followed the
commencement of the dependent eligibility audit.
• Coverage was already terminated due to a qualifying life event which took place before
the completion of the dependent eligibility audit.
For the remaining 37 dependents who were identified by the audit to be ineligible, the City
promptly terminated coverage. Additionally, coverage was terminated for 19 dependents for
employees who did not respond completely prior to the audit's deadline, despite multiple
communications.
There were 18 employees that did not respond in writing on behalf of their dependents, which
resulted in 28 dependents being dropped from the plan.
Estimated Calculated Savings and Return on Investment (ROI)
Although actual cost can vary, the industry average estimated cost per dependent is $3,500 . This
is the estimated average cost per dependent used by BMI for this analysis:
#of Confirmed Ineligible Dependents: 37
#of Dependents Not Completing or Responding {19 incomplete+ 28 no
response): 47
Estimated Average Annual Cost per Dependent: 3,500
Audit Fee: $34,018.36
Estimated First -Year Savings from 84 Dependents Removed: $294,000
First-Year ROI: 764.24%
Even for the employees that were non-responsive by the close of BM l's audit period of April 30th,
the City extended a final amnesty period of 25 days to those employees to comply with the
required documentation to keep their dependents insured. At the end of that period, letters of
intent to terminate coverage were sent to employees who had ineligible dependents enrolled in
their health and/or dental plan. For a subset of these employees who received letters, many had
an ineligible dependent enrolled in the plan who had incurred more than $1 ,000 in health and/or
dental claims. This subset of employees was asked to attend a pre-determination meeting with
members of the Human Resources Employee Relations Division in anticipation of potential
disciplinary action. During the pre-determination meeting , employees were provided an
opportunity to turn over the required documentation which was not submitted during the audit and
they were also given an opportunity to explain how the ineligible dependents became enrolled in
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Dependent Eligibility Audit
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the City's plan. These pre-determination meetings yielded an additional 5 employees that
complied with the audit 's requirements. However the most drastic outcome was the termination
of one employee from City employment because he falsely claimed two ineligible dependents on
the City's health plan for over 10 years .
Overall , the Dependent Eligibility Audit conducted by BM I was a success. They conducted an
audit that was free of bias or outside influence. Most importantly, BMI had an extraordinary focus
on privacy, security, and confidentiality of data and documents received by plan members. BMI
was able to validate the accuracy of enrollment information , a process that had not taken place
in many years. The good news is that our medical and dental plan now has up-to-date accurate
dependent data files and any newly added dependents will be validated to maintain accuracy .