IRIDA ANGJELI - DandHDistributing.fall2011
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Benefit Analysis:D&H Distributing Co.
Part I: Benefits MatrixPart II: Inventory of Benefits
By: Adam Davis Irida Angjeli
RMI 3501Dr. Drennan
Fall 2011
Loss Exposure Covered? Coverage/Benefit Provided
Medical ExpensesHospital/Physician Yes BlueCross & BlueShield: PPO & PPODental Yes United ConcordiaVision Yes Vision Benefits of AmericaPrescription Yes Premier Pharmacy NetworkLong Term Care NoRetiree Health Care Yes COBRA, OASDI
Loss of Income due to DeathNon-Accidental, Non-Occupational Death
Yes Life Insurance, ESOP, OASDI, AD&D Insurance
Accidental Death Yes Life Insurance, ESOP, OASDI, AD&D Insurance
Occupational Death Yes Life Insurance, OASDI, AD&D Insurance, Workers’ Compensation
Unemployment Yes Unemployment Insurance
DisabilityShort-Term, Non-Occupational Yes ESOP, 401(k), STD, OASDI, AD&D
InsuranceLong-Term, Non-Occupational Yes ESOP, 401(k), LTD, OASDI, AD&D
InsuranceShort-Term, Occupational Yes ESOP, 401(k), OASDI, AD&D Insurance,
Workers’ CompensationLong-Term, Occupational Yes ESOP, 401(k), OASDI, AD&D Insurance,
Workers’ Compensation
Retirement Yes 401(k), ESOP, OASDI
Other ExposuresEducational Assistance NoWork/life Exposures NoDependent Care NoProperty-Liability NoLegal Expenses No
Inventory of Benefits
Introduction to the Healthcare Plan
D&H Distributing Co. provides a reasonable employee benefits plan to its
employees. For the medical plan, eligible employees are defined as all employees who
work at least 40 hours per week have completed at least 90 days of continuous
employment with the employer. Employees have the option of selecting employee-only
coverage or family coverage. If D&H Distributing Co. is the employer of both spouses,
only of them may elect to cover their dependent child(ren). Eligible dependents are
defined as a legal spouse, unmarried children residing with the eligible employee until
age nineteen (including any stepchildren, legally adopted children, and children for
whom the eligible employee is legally responsible), and unmarried children who are
under age 24 as of the end of the calendar year and attending a college or similar
institution for at least 5 months during the year. For their healthcare plan, D&H
Distribution offers their employees the choice between a PPO 90 and PPO 80 plans. The
enrollment tiers for the plan are Single (employee only) and Family (employee, legal
spouse, legal children). Employees can enroll in the medical plan by making their benefit
election within 30 days of becoming eligible for coverage. For the first plan year in
which employees are eligible to participate, an enrollment form must be returned to the
Plan Administrator before the date specified. An employee that fails to return the
enrollment form will not be covered under any health or welfare programs. The next
time the employee will be able to elect benefit coverage is during the next open
enrollment period starting November 26th and ending December 7th. During open
enrollment, an employee may also choose to opt-out of D&H’s plan and be covered
under their spouse’s employer’s medical plan or remain uninsured. When enrolling for a
medical plan, the employees are given the options to enroll in the dental and vision plans.
Overall Medical Expenses
D&H Distributing Co. offers employees two versions of preferred provider
organization (PPO) coverage that are administered through the Highmark Blue Shield.
Both plans are experience rated and are available to eligible employees and their
dependents on a contributory basis. Employees contribute approximately 25% of the
overall cost of the plan. Employee contributions are deducted from their bi-weekly
paychecks on a pre-tax basis. The cost of coverage is subject to change and employees
are notified of any change during the annual open enrollment period. Both PPOs have
the same coverages, conditions, and exclusions. However, they differ in their
deductibles, coinsurance percentages, and out-of-pocket maximums. Plan participants
are not required to select a primary care provider (PCP) under both plans. They have the
choice to of using either a network provider from a list provided by Highmark Blue, or an
out-of-network provider of their choice. Participants who choose receive services from a
provider in the PPO network will receive the highest level of benefits. Neither of the
plans have a lifetime limit. The PPO 90 plan has twice as low a deductible for network
providers as the PPO 80 plan ($250 for Individual and $500 for Family, compared to
$500 for Individual and $1000 for Family). The same regulation applied for out-of-
network providers. The PPO 90 plan has a deductible of $1000 for Individual and $2000
for Family, and the PPO 80 plan has a deductible of $500 for Individual and $1000 for
Family. The PPO 80 plan has a higher annual out-of-pocket maximum, as compared to
the PPO 90 plan for both network and out-of-network provider. PPO 80 has an annual
limit for out-of-pocket expenses of $2000 for Individual and $4000 for Family for
network providers and $5000 for Individual and $10,000 for Family for out-of-network
providers. PPO 90 has an annual limit for out-of-pocket expenses of $1000 for
Individual and $2000 for Family for network providers and $2500 for Individual and
$5000 for Family for out-of network providers. The PPO 80 plan offers lower
coinsurance (80%, after deductible, for network providers and 60%, after deductible, for
out-of-network providers) than the PPO 90 plan (90%, after deductible, for network
providers and 70%, after deductible, for out-of-network providers. In terms of in-
network office visits, for both primary care physicians and specialist, both plans cover
100% of the expenses after a $25 copayment. For out-of-network office visits (primary
care and specialist), PPO 80 covers 60% of the expenses after deductible, and PPO 90
covers 70% of the expenses after the deductible. Both plans have a limit of 90 hospital
visits per benefit period. For inpatient hospital care, the PPO 80 covers fewer expenses
than the PPO 90 (80%, after deductible, for network providers and 60%, after deductible,
for out-of network providers and 90%, after deductible, for network providers and 70%,
after deductible, respectively). Both plans pay for 100% of the cost of preventive care for
in-network providers. For out-of-network provider preventive care, PPO 80 pays less
than PPO 90 (60%, after deductible, and 70%, after deductible, respectively).
Consumer-Driven Health Plan (CDHP) with Health Savings Account (HSA)
D&H Distributing Co. does not offer a CDHP with HSA to their employees. The
reasoning is because the plan administrator thinks these benefits have too high of a
deductible and employee contribution.
Dental
D&H Distributing Co. offers dental coverage that is fully insured through United
Concordia. United Concordia is rated ‘A-’ by AM Best. The eligibility requirements for
the dental plan are the same as those for the medical plan. Employees are offered two
options the “Basic Option” and the “High Option”, with employees contributing 50% and
60% respectively. The employee contribution is acquired via pre-tax payroll deduction.
Both plans cover 100% of diagnostic/preventive services (exams, cleaning, x-rays). Both
plans cover Basic Services (space maintainers, fillings, endodontic, simple extractions)
with the exception of nonsurgical periodontics, which is only covered under the “High
Option” plan. In addition, the “High Option” covers 50% of Major Services (repairs of
crowns, repairs of bridges, denture repair, surgical periodontics, prosthetics, and oral
surgery). The “Basic Option” has a $1000 calendar year maximum per covered person
and a $0 calendar year deductible for both individual and family. The “High Option”
plan has a $2000 calendar year maximum per covered person and is also subject to
annual deductibles ($50 for individual and $150 for family) which is only applies to the
Major Services described above. United Concordia’s standard exclusions and limitations
apply, so the plan covers unmarried dependent children to age 19 and unmarried
dependent students to age 23.
Vision
D&H Distributions Co. provides vision coverage through Vision Benefits of
America (VBA). VBA is not ratted by AM Best. The benefits are provided on employee-
pay-all basis and cover the full cost of one visit per year for in-network providers (VBA
Participating Doctor). Rates are guaranteed for the full two years of the contract and are
based on 100% employee contributions through a qualified section 125 plan. The plan
covers hardware expenses when Customary and Reasonable as determined by VBA. If
employees choose an out-of-network or non-participating provider, they will be
responsible for the cost of visit and will be later reimbursed at a specified rate which is
relevant to cost of expenses.
Prescription
Employees enrolled under any of the healthcare plans are automatically enrolled
in the Prescription Drug Coverage also administered by Highmark Blue. The PPO 80
and PPO 90 offer identical coverage for only in-network providers. Neither of the plans
have a deductible for prescription drugs for both Individual and Family. The plans cover
for prescriptions of generic formulary, preferred brand name formulary, and non-
preferred brand name formulary drugs, each having a specific co-payment. The co-
payments are as follows; for 31-day supply ($8 for generic, $35 for preferred brand, and
$60 for non-preferred brand); for 60-day supply ($16, $70, and $120 respectively); for
90-day ($24, $105, and $180 respectively). Up to a 90-day supply of mail order drugs
are offered for a smaller copayment ($16 for generic, $70 for preferred brans, and $120
for non-preferred brand). Both PPOs have a $500 lifetime maximum for fertility drugs.
If an employee wishes to purchase prescription drugs from an out-of-network provider,
they can do so and file a claim for reimbursement. However, reimbursement is not
always guaranteed.
Life Insurance
Employee Term Life, Dependents Term Life, Accidental Death and Dismemberment
(AD&D)
D&H Distributing Co. offers basic employee term life insurance on a non-
contributory basis. The employer also offers basic accidental death and dismemberment
insurance on a non-contributory basis. The employees of the firm have the ability to elect
additional employee term life coverage and accidental death and dismemberment
insurance on a fully contributory basis. The above benefits are fully insured through The
Prudential Insurance Company of America, which A.M. Best rates an A+, or superior. To
be eligible for this coverage, employees must be full-time which is defined as customarily
working 40 hours per week.
The Basic Employee Term Life insurance provides benefit limits equal to 100%
of the participant’s annual earnings up to a maximum of $100,000. If the participant’s
annual earnings are not a multiple of $1,000 then the amount of life insurance coverage is
automatically rounded up to the nearest multiple. Optional Employee Term Life
insurance has benefits that are equal to the lesser of: 500% of annual earnings or
$200,000. Both of these coverages have a reduced value once the participant reaches the
age of 70, at which they will only be eligible to receive 75% of their benefits.
Additionally, participants in this plan have the option to purchase Optional Dependents
Term Life Coverage on a fully-contributory basis. Benefits under this insurance are
$25,000 for spouses and $10,000 for dependent children. The basic AD&D insurance
limit is equal to the amount of insurance under the basic employee term life coverage and
the optional AD&D insurance limit is equal to the amount a participant is insured for
under the option employee term life coverage.
Accidental Death and Dismemberment has a schedule of payable benefits that
range from a loss thumb and index finger of the same hand (25% of benefit payable) to
loss of life (100% of benefit payable). In order to be eligible to receive AD&D benefits
the loss must have caused a covered person to sustain a bodily injury, the loss must have
resulted directly from the injury, and the person suffers the loss within 365 days after the
accident (with special provisions for death and coma). Both the basic and optional
AD&D provide for additional benefits if the loss is classified as stemming from or
resulting in: Loss of life from a vehicular accident while wearing a seatbelt, loss of life
from a vehicular accident equipped with a supplemental restraint system, return of
remains, loss as a result of felonious assault, tuition reimbursement for spouse, tuition
reimbursement for dependent child, and day care expenses for dependent child.
Short Term Disability Insurance
D&H Distributing Co. provides their employees with short term disability
insurance on a non-contributory basis. It is funded through self-insurance. This benefit
provides an employee with supplemental income if they are kept from work due to a
covered loss such as injury, sickness, or pregnancy. To become eligible, employees must
be classified as full-time and must have completed 12 months of continuous employment
at D&H Distributing Co.
The benefits are payable after a covered loss has occurred and are provided to
employees on a weekly basis at 60% of their prior earnings. The benefits are payable up
to a maximum of 12 months, at which the long term disability insurance will take effect.
Long Term Disability Insurance
Long Term Disability Insurance is provided to the employees of D&H
Distributing Co. through The Prudential Insurance Company of America, which A.M.
Best rates as an A+, or superior. To be eligible for Long Term Disability insurance, the
employee must be classified as salaried and have worked for at least 12 months of
continuous employment. The benefit payable to participants is equal to 60% of their
monthly earnings but cannot exceed the maximum monthly benefit of $4,000.00 and can
be utilized up to the normal retirement age. Additionally, an elimination period of 90
days applies to this benefit meaning a participant must be continuously disabled for 90
days before the payment of benefits will occur. Additional benefits under long term
disability insurance include critical illness coverage, survivor benefit, worksite
modification, and rehabilitation services. The aforementioned benefits are aimed at
returning a covered employee to work as quickly as possible with the exception of the
survivor benefit which is paid to survivors of a participant that was disabled for a long
term.
Retirement
D&H Distributing Co. provides eligible employees with two retirement account
options to provide payments to retirees. The two options are a 401(k) and an Employee
Share Ownership Plan (ESOP) account.
The ESOP plan employed by D&H Distributing Co. is a special type of defined
contribution plan that enables employee ownership of the company. This plan is
administered through an ESOP Administrative Committee. The ESOP is funded through
a trust set up by D&H Distributing Co. and has 4 executive level employees’ named as
Trustees to the plan. Eligibility is granted to the employee on the first of the month after
he/she has worked for 90 consecutive days provided they are a non-union worker. This
account is funded by employer contributions in the form of stock to each of the enrolled
employees’ accounts. The account is 100% vested to the employee after 6 years and is
done so on a 20% vesting schedule. Upon retirement at the normal age of 65 years, 100%
of the value of the account is payable to the retiree in a variety of ways. The payment
options are: Lump sum, Installments, Joint & Survivor Annuity, Lifetime Annuity, and
Lifetime Annuity with guaranteed period. This gives the employee a variety of ways to
collect the benefits provided under the ESOP arrangement including ways for the named
beneficiaries to continue to collect payments after the retiree has died.
The second option that employees have to receive financial security after
retirement is the 401(k) option provided by D&H Distributing Co. Similarly, the 401(k)
plan is administered through a 401(k) Plan Administrative Committee and has the same 4
executives named as the Trustees to the plan funds. This plan has the same eligibility
requirements of the ESOP program. The amount of compensation an employee may defer
to the 401(k) account is capped at $16,500 for 2010 and will be indexed upward under
federal law. The employer intends on matching 25% of employee contributions for the
plan year ending April 30, 2011 up to an employee contribution of 6% of compensation.
Any amount contributed to the 401(k) by the employee in excess of 6% of compensation
can be added to the account but will not be matched by an employer contribution. In
order to be eligible for the employer match an employee must have made a salary deferral
contribution to their account and they must have been employed with D&H Distributing
Co. up until the last day of the plan year. The vesting of benefits for the employee is the
same as in the ESOP arrangement, with 100% vesting at the normal retirement age, after
a long term disability, and upon death.
As stated above, both the ESOP and 401(k) plans provide loss of income benefits
upon disability or death of the employee. Disability in these plans are defined as an
inability to do any substantial amount of work of any sort because of a physical or mental
condition that can be medically determined and that can be expected to last more than a
year. If the disabled employee becomes eligible for Social Security disability benefits,
they will automatically satisfy the requirements of the plan to become eligible for said
benefits. If the participating employee dies, the full amount of the balance will be payable
to the named beneficiary. For a married participant, the beneficiary under these two plans
is automatically the spouse and can only be changed with written consent from the
spouse. An unmarried employee must designate a beneficiary through a beneficiary form
provided by the Plan Administrator.
Part III: Benefit Analysis
Introduction
D&H Distributing Co., Inc. operates as a technology distributor for IT and
electronics for small and midsize business and consumer markers. The company offers a
variety of server and infrastructure, mobile applications, consumer electronics and
gaming products. The company sells its products through several channels, including
solution providers, resellers, system builders, college bookstores, retailers, video gaming
dealers, home installers etc. D&H Distributing is a privately owned company. It
currently employs 1100 full-time employees in Harrisburg, Atlanta, California, and
Chicago. At present, D&H’s health and welfare benefit plan consists of 823 contracts
with Highmark Blue, 1734 members. Many employees choose to opt-out because they
are covered by their spouse’s employer benefits. D&H provides Short Term Disability,
Long Term Disability, Basic Life, and Basic Accidental Death and Dismemberment
benefits on a non-voluntary benefits. Therefore, the employees are automatically
enrolled in these benefits after being full-time employed for one month. In addition, 67%
of the employees participate either in ESOP or 401K plans.
Throughout this project, Linda Messner helped us gather information and analyze
D&H Distributing Co. current benefits plan. Linda Messner is the Human Resources
director, and her responsibilities include benefits plan design, communication,
administration, and regulatory compliance. Other than Linda, the benefits committee
consists of Dan Schwab, Robert J Miller, Michael Schwab, and Jeffrey Davis. Linda
brings the employees’ perspective into picture when designing the plan, because she
thinks a strong benefits plan builds a strong employer-employee relationship. The
benefits committee gives important inputs regarding the benefits plan and helps Linda
design it. Their recommendations regarding plan design are presented to the Chairman
and CEO of the company, who makes the final decision.
Overall Design Deliberations in Employee Benefits
Goals
When asked about why D&H Distributing Co. provides a benefits package for
their employees and their employees’ dependents, Linda replied that it helps the firm stay
viable and retain their talent. It is implemented in the company’s culture that good
benefits are crucial, because it is important to take care of employees and their families.
However, this does not mean that employees choose to work at D&H only for the
benefits plan. Thus, the company’s benefits plan does not essentially function as a selling
point for potential employees.
D&H’s benefits committee acknowledges the prominence of designing a plan that
balances the benefit goals with their budget. The committee stresses designing a plan
that adopts employee needs rather than their wants. Linda mentioned that unless a
benefit was requested by a considerable number of employees, it would not be offered.
The HR team is constantly educated about any additional benefits, since they are
accountable for their administration. She noted that people administering the plan were
careful not to violate their fiduciary responsibility under ERISA. In the upcoming years,
D&H is working to apply employee wellness programs, in hopes of decreasing
premiums. Since the health care benefits are experience rated, Linda feels that providing
incentives to healthy employees will decrease the cost of premiums overall.
Demographics
When designing their benefits plan, D&H took into account factors such as
average employee age, marital and family status, and different locations. The average
employee is about 40 years old, and there is a high divorce and single parent rate. The
benefits committee discovered that many employees had different types of dependents,
ranging from: single child, multiple children, spouse only, and spouse and children.
Linda noted that a single parent family does not have the same benefits costs as an older
couple; therefore, to share the cost more equitably, the benefits committee implemented a
five tier healthcare plan. The tiers are employee, employee and child, employee and
spouse, employee and children, and employee and family. Additionally, D&H has very
few part-time employees. The firm is able to attract and retain full-time workers, while
discouraging part-time workers, by only providing benefits for the previous.
Funding and Financing Considerations
The majority of benefits provided by D&H are fully insured, with the exception of
Short Term Disability being self-insured. For the medical plan, the firm chooses to fully
insure through Highmark Blue. D&H operates in various states; thus, Highmark Blue was
the ideal health benefits provider for the company. The Blue Card Network makes it
possible for the sales representatives, who work across the country, to use their healthcare
benefits in any of the Blue’s providers nationwide. The premiums are experience rated;
therefore, they increase with the cost of healthcare consumption. It is difficult for D&H
to control losses, as many medical conditions that drive up the premium cost can be
unavoidable (premature baby, certain cancers). However, the firm is working towards
implementing an employee wellness program, where employees will be given incentives
(lower premium, monetary rewards) if they loose weight, eat healthy. This will provide
D&H with potential to save on premium costs which range from $5.5 million - $6 million
annually (employer is responsible for approximately 80% of premium). The firm also
chose to fully insure their Dental, Vision, Life, LTD, and AD&D benefits. The benefits
committee believes that the cost of self-insuring healthcare and the other benefits
mentioned above would be overbearing, since the company is rather small and not able to
compensate for catastrophic losses. D&H chooses to self-insure the STD benefits
because of positive claims experience. Also, the firm wants to practice self-insuring, in
hopes of self-funding other benefits in the future.
As the result of the rising cost of healthcare, D&H decided to finance the majority
of benefits on a contributory basis (except STD and LTD). They shared a cost-benefit
analysis with their employees to help them understand and make an educated choice
based on their projected medical costs. Many employees found contributing 20%
towards the lower cost PPO 80 was reasonable. The disability benefits had to be
corresponding with state and federal insurance programs. The firm chose to offer STD
and LTD on a non-contributory basis. By providing them free of cost to the employees,
the firm ensured that employees received the necessary coverage.
Problems, Issues, Concerns, and Considerations in the Design of Health Benefits
Issues, HMO vs. PPOs
Highmark Blue administers the healthcare benefits at D&H; Highmark decides
whether a medical procedure is necessary. This shifts responsibility from the employer to
the insurer. Overall, the firm has not experienced major issues with Highmark as the
insurance provider, as they have handled claims efficiently. However; sometimes certain
physicians pull out of The Blues network because they feel that they are not compensated
enough. The Blues charge lower premiums compared to other insurance companies,
which results in lower compensation for physicians. In a PPO plan, the employees are
not required to select a primary care physician; therefore, physicians opting out of the
network have not presented a big issue to D&H. In the interview, Linda mentioned that
D&H was initially debating whether to provide an HMO or PPO plan to the employees.
The committee decided to select two PPOs instead of an HMO (even though an HMO
offers cheaper premiums) to dismiss the employees from having to go through a
gatekeeper (primary care physician). By offering two PPOs through Highland Blue,
D&H provides more flexibility to their employees. According to Linda, the plan
functions in the best interest of the plan participants.
Funding Considerations
Fully insuring their medical plans allows D&H to transfer all loss expenses to
Highmark Blues, in exchange for a premium paid annually. The employer transfers all
administrative responsibilities to Highmark; therefore the firm does not have a say on
what visits or treatments are paid for. As mentioned previously, The Blue Card Network
allows for plan participants to use their healthcare benefits anywhere in the country.
Access to experience rating through Highmark allows D&H to target wellness initiatives,
which can have the potential of further cost savings.
Cost Inflation
During the years 2008-2010, D&H negotiated a 7% rate cap with Highmark Blue.
After that, the firm faced premium rate increase as high as 25%. The plan changes only
led to a 10% premium increase for participants in the PPO 80, since the employer did not
fully transfer the cost increase to the employees. On the other hand, the PPO 90’s
employee contribution premium increased by 15%. To cope with this issue of cost
inflation, D&H increased the participant’s out-of-pocket expenses (deductibles and
copays) and limited fertility benefits. Linda mentioned that even though the deductibles
and copays were increased, they are still much lower compared to the industry averages.
There has been an ongoing debate in D&H’s benefits committee regarding a
switch from a fully insured medical plan to a self-insured medical plan. If their medical
plans were self-insured, the firm would not have to pay the annual high premium of
approximately $5.5 million to Highmark Blue. Instead, the employer would solely be
responsible for paying for the losses as they occur. This can be a positive (if losses are
under $5.5 million a year) or negative (if losses exceed $5.5 million a year). As of now,
D&H plans to stick to fully insured plans because they are not confident in managing
catastrophic losses.
Considered Benefits
The benefits committee at D&H Distributing Co. is consistently analyzing their
benefits package in order to provide the highest levels of coverage while keeping costs at
an economically feasible level. One of their main focuses at this point is to develop and
implement a wellness program by 2013 that would provide a discount on the employee’s
share of the premium. Currently, D&H has a smoking cessation program that provides a
20% discount on healthcare premiums for every employee that is a non-smoker. This
provides the employees with an incentive to quit smoking, which is proven to reduce the
cost of healthcare over the employee’s lifetime. The benefits committee has experienced
success with this program and they are looking to increase this program to include
participation in fitness programs, in-house preventative screenings, an on-site walking
track, and healthy food options for employees. D&H Distributing Co. is determined to
achieve a 2% reduction in the cost of healthcare by incentivizing participation in the
wellness program.
The D&H Benefits Committee has not considered implementing a Long
Term Care plan. But because the business has remained relatively stable during the recent
recession and many employees consider their position as their life-long career, we believe
it is within D&H’s benefits strategy to expand their benefits program to include Long
Term Care insurance. Once D&H has adapted to the changing environment of healthcare
due to Healthcare Reform and PPACA, we strongly urge them to consider implementing
LTC coverage and take a proposal to market.
Problems, Issues, Concerns, and Considerations in the Design of Other Non-
Retirement Benefits
D&H Distributing Co. does not provide benefits outside of retirement and health
coverages other than short-term and long-term disability insurance. The short-term
disability coverage that they provide is on a self-funded basis because they have the
ability to estimate the losses that are covered. In addition to their actuarial estimates of
the probable losses related to short-term disability, D&H uses self-funding in this
situation as a type of experiment. The Benefits Committee handles the administrative
aspect of this coverage and if no major issues arise then they intend on exploring self-
funding for some of the other benefits they provide. Long-term disability is funded
through an insurance contract because of the potential for long tail claims. The actuarial
estimates and financing requirements of self-funding long-term disability are outside of
the scope of D&H’s Benefits Committee at this time.
Regulatory Compliance
HIPAA
The main concern for D&H’s Benefits Committee with regards to HIPAA
regulation is the Privacy Rule and the Security Rule. The Benefits Committee is
comprised of employees of the firm and therefore the data they use while analyzing the
plan and overseeing the operation of the plan must be kept free of personal information.
To comply with the Privacy Rule and HIPAA, all information concerning claims history,
preexisting conditions, and other individually specific health data is kept free from
indicators that could potentially link the information to the person. D&H utilizes an intra-
net with security safeguards to administer the various plans under their benefits program.
This protects health and claims data from unauthorized viewers. D&H has not had any
HIPAA related non-compliance issues because of their secure intranet and the Benefits
Committee’s commitment to keeping the personal data of their employees private.
COBRA
D&H Distributing Co. offers the benefit extension as required under COBRA
regulation. The administration of COBRA continuation coverage is done by Highmark
Blue Cross Blue Shield therefore the cost of compliance has been factored into the
administrative expenses of the plan. D&H has not experienced many issues regarding
compliance with COBRA and their strong performance during the recent recession has
prevented them from making significant layoffs. For many other businesses the recession
has caused large employee layoffs, which increases the amount of individuals and
dependents that elect for COBRA continuation. Fortunately, this has not been the case for
D&H. The Benefits Administrator for D&H did not have any issues concerning COBRA
compliance other than introducing protocols and procedures for administering/approving
the continued coverage and educating the employees on their ability to elect this
coverage.
ERISA
D&H Distributing Co. has remained compliant will all aspects of ERISA
legislation including fiduciary responsibility; plan communication, reporting
requirements, and discrimination testing. In order to ensure that the fiduciary duty is
satisfied, D&H has employed a member of the HR department whose sole responsibility
is administration of the health and welfare benefits plan. The plan communication
requirement is satisfied through electronic distribution of Summary Plan Descriptions
(SPD) for all of the available plans. They are updated annually and sent to employees
eligible for coverage as well as new hires. The Benefits Committee does the health and
welfare benefits plan reporting requirements of the IRS and Department of Labor
annually. They filed the necessary paperwork for their insured contracts as well as the
self-funded short-term disability coverage. Currently, D&H is exploring their ability to
self-fund all of the benefits provided to their employees and that process involves
considering ERISA compliance and the additional reporting requirements. Lastly, D&H
satisfies non-discrimination testing by providing their employees with uniform benefits.
Regardless of compensation, employees have the option of two PPO plans, have a
defined cap on their disability payments, and are subject to the same employer-
contribution percentage in the ESOP and 401(k) plans.
PPACA and Health Reform
D&H Distributing Co. has, through their provider Highmark BC/BS, remained
compliant with the first wave of regulation required by PPACA that began on September
23, 2010. Free preventative care and increased dependent age have caused an increase in
cost to D&H Distributing Co. of approximately 3%. The firm is preparing for the
graduated regulations of PPACA by implementing many of the policies and procedures
for compliance before the prescribed date. One of the issues that arose for D&H is the
required W-2 reporting of the value of employee benefits, which was unsuccessfully
implemented during the optional 2011 plan year. The Benefits Committee was well
aware of this regulation but it ultimately became a software issue for the company.
D&H’s software engineers are still working on this issue but are confident that it will be
resolved by the time W-2 reporting is mandatory. As described above, D&H Distributing
Co. has always had a strong emphasis on rich benefits for employees and their families so
they have not considered withdrawing their benefits plan in exchange for the free rider
penalty.
Recommendations for the Future
While analyzing D&H Distributing Co.’s current benefits plan, we have noted
certain factors that could help strengthen the moderately inclusive plan. Our
recommendations consider the monetary issues and personnel available to administer the
additional benefits.
Voluntary Benefits and Work/Life Benefits
During our interview with Linda, she mentioned that D&H does not currently
offer voluntary benefits. However, they would like to provide voluntary benefits on an
employee-pay-all basis and deducted on a pre-tax basis from bi-weekly paychecks. These
benefits include subsidized or on-site childcare, education reimbursement, flexible work
schedule (telecommunication), personal financial planning.
Self-funding
D&H has a long history of experience and a high number of covered lives;
therefore, it would be feasible for the firm to self-fund their healthcare benefits. They are
currently experience rated, which makes them sensitive to their losses. They can use this
information to set up a healthcare fund and hire a Third Party Administrator (TPA) to
deal with the complexities of administering a self-funded plan. Additionally, we suggest
D&H purchases stop-loss insurance in case of catastrophic claims.
Communication
In order to diversify their offerings beyond PPOs, we suggest D&H benefit
committee to survey the employees regarding expanding their options to include an
HMO, High Deductible Health Plan, or POS plan. Although the employees enjoy the
flexibility of the PPO plans, it would be important to see if more employees would be
willing to participate in the plans proposed above if the cost-sharing arrangements were
different. The firm should communicate to the employees the importance of participation
in any of the benefit plans through e-mails and updates on the benefits’ intra-net.
Conclusion
The current benefit package is the result of years of experience with providing
rich benefits to employees and their families. This has enabled D&H to attract and retain
top talent, which has contributed to their steady expansion over the decades. Now it is an
important time for the benefits committee due to Healthcare Reform and their aspiration
to self-fund. With their deep commitment to their employees, D&H will continue to
provide above average benefits.
Works Cited
All A.M. Best’s ratings were retrieved from <http://www3.ambest.com/ratings/default.asp>
December 9, 2011
Linda MessnerBenefits Administrator, Human Resources DepartmentD&H Distributing Co.2525 N. 7th StreetHarrisburg, PA 17110
Dear Linda,
We would like to thank you for taking time out of your busy schedule to hold an interview with us regarding D&H’s health and welfare benefits program. Your willingness to answer all of our questions enabled us to not only complete our project, but also gain a better understanding of the processes and involvement required to design and implement an employee benefits program. Without your assistance our work on this project would not have been possible. It was a pleasure to work with you and we look forward to speaking again soon.
We wish you and your organization the best of health this holiday season!
Best Regards,
Adam DavisIrida Angjeli
Students, Temple UniversityDepartment of Risk Management and Insurance
December 9, 2011
Dan SchwabCo-PresidentD&H Distributing Co.2525 N. 7th StreetHarrisburg, PA 17110
Dear Dan,
We would like to extend our gratitude to you for your willingness to provide us with D&H’s health and welfare benefits documentation. Your willingness to provide all of the information we asked for enabled us to gain an understanding of the benefits package that an employer offers to attract and retain valuable employees. Without your assistance our work on this project would not have been possible. It was a pleasure to work with you and we look forward to speaking again soon.
We wish you and your organization the best of health this holiday season!
Best Regards,
Adam DavisIrida Angjeli
Students, Temple UniversityDepartment of Risk Management and Insurance
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