HRA Employer Guide May 2015
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1 HRA Employer Guide May 2015
2 Welcome As the leading administrator for Health Reimbursement Arrangements (HRAs), BenefitWallet provides administrative services to you and your employees. This employer guide should be used as a resource to understand your BlueFund HRA plan offered through CareFirst BlueCross BlueShield (CareFirst). What do you need to do now? 1. Review this employer guide. You also have access to BenefitWallet s dedicated Employer Support Team at and a website to assist you in administering your HRA and funding process. 2. Complete and return the HRA Set-Up Form and ACH Authorization Form by fax to or by to employersetup@mybenefitwallet.com. 3. A 3-digit employer ID will be assigned to your group. The individual designated as the primary business contact will receive s with: 1) a security challenge form to authenticate speaking with the Employer Support Team; 2) web login instructions (including your temporary password). If you need this information resent, please contact the Employer Support Team. 4. Review the online Participant Account Report to verify the processing of your group s eligibility information. 5. Once enrollment is loaded, you will receive an with your Required Minimum Funding (RMF) amount. Refer to the Account Funding section for more detail on RMF. Table of Contents What do you need to do now?... 1 Employer role with HRAs COBRA Notification Process... 2 Security... 2 Enrollment process... 2 Account funding... 3 Contribution approval... 3 Claims processing authority... 3 Claims payment process... 4 HRA payment services... 4 Employer website... 5 Reporting... 5 Contacts... 6 Holiday schedule... 6 Employer role with HRAs To assist in the establishment and administration of employees HRAs, you will be required to provide certain documents, instructions and information. Please note that a delay in submitting the necessary materials could result in a delay of HRA services or prevent BenefitWallet from providing HRA administration. You are responsible for: Ensuring your HRA complies with all applicable provisions of the Internal Revenue Code and any applicable state and local laws. Ensuring that the summary plan description, plan document and any other documentation relating to the HRA are appropriately completed, in compliance with, and maintained in compliance with, the requirements of applicable law and are appropriately and timely adopted. Distributing summary plan descriptions, summaries of material modification and any other documentation with respect to the HRA to participants on a timely basis. 1
3 Filing documentation with the appropriate government agencies, including the Department of Labor and the Internal Revenue Service. COBRA notification process The Consolidated Omnibus Budget Reconciliation Act (COBRA) allows participants to continue their health plan benefits upon termination of employment. If the employer is subject to COBRA, they must offer the participant the opportunity to continue their HRA coverage. However, if the participant does not elect the HRA coverage the employer must notify BenefitWallet immediately to prevent any further claim payouts. If the employer fails to provide proper notification, BenefitWallet will not be responsible for claim payments that are not returned. Security The security of information provided by you and your employees is of paramount concern to BenefitWallet. Each call to our service center is authenticated to ensure information is provided only to authorized contacts. Employer authentication is based on the contact list provided during setup, coupled with the responses to selected security challenge questions. Only indicated, authorized contacts who respond correctly to the recorded questions may discuss employer information. An integral part of security concerns include communications/transmissions and the submission of data. All funding occurs via an ACH pull initiated by BenefitWallet. In the rare instance when an requires employer or employee personal information (see list below), the should be sent using a secure link (i.e. Tumbleweed, Secure Message) or as a Pretty Good Privacy (PGP) encrypted . Employers may obtain a PGP encrypted valid for six weeks from the Employer Support Team. Personal information includes: Name Address and/or zip code address Telephone number Dates (including date of birth or effective date) Account number Tax ID or Social Security Number Enrollment process You are responsible for determining which employees are eligible to participate in the HRA. Once this information is available, BenefitWallet will need: A complete list of those eligible employees, either provided directly or through your health plan Any demographic or other information related to those eligible employees that BenefitWallet may need to administer the HRA Notification directly, or through your health plan, of any changes in employee eligibility information (at least monthly) To modify an employee s HRA eligibility or status, you must provide both the effective and termination date of eligibility prior to the effective date of such changes. 2
4 Late notification of HRA eligibility or incorrect eligibility information may result in erroneous benefit claim payments. You will be responsible for any erroneous benefit payments (including the collection of any erroneous payments from the individual) that occur because of late or incorrect eligibility information provided by you or by a third party on your behalf. Once an HRA is set up, indicative data changes may ONLY be made by the employee. Employees can make these changes on the member website or by calling the BenefitWallet Customer Service Center. Account funding HRAs are notional accounts that require a minimum level of pre-funding by the employer. The HRA funding process requires you to: Advance benefit payments on behalf of the HRA by transferring funds from your general assets to the HRA in an amount equal to 10% of expected annual HRA benefit payments (also known as the required minimum funding amount). There is a required minimum funding amount of $250. Make the initial required minimum funding deposit prior to the effective date of the initial HRA plan year. An invoice will be sent and funds in the amount of the RMF will be pulled via ACH from your designated employer account one to two weeks prior to the plan effective date. Complete and return the employer ACH Authorization Form. Weekly transfer: BenefitWallet will initiate a transfer via ACH from your designated bank account on a weekly basis. Each week, we will send an invoice via and initiate an ACH to transfer an amount equal to that week s claims. The amount transferred will be the amount necessary to return the existing deposit balance to the required minimum funding amount. Monthly transfer: BenefitWallet will recalculate the required minimum funding amount based on the expected annual HRA enrollments on a monthly basis for all of your HRA participants active at that time. If the recalculated required minimum funding amount exceeds the previous required minimum funding by 25% or more, the previous required minimum funding amount will be replaced by the new calculation. Conversely, on a quarterly basis if the re-calculated RMF amount is less than the current RMF by 25%, we will manually refund the overage. Authorize BenefitWallet to write checks for the payment of allowable HRA claims. NOTE: BenefitWallet will not issue claim payments of any kind or approve debit card payments if the existing deposit balance falls below $0.00. Contribution approval Contribution approval is ONLY required for HRAs when funds are available to employees on a cycle (e.g. weekly or quarterly) and an employer is funding the HRAs throughout the year. When contributions are scheduled to be made, employers must approve the contribution amounts prior to each contribution cycle. In order for funds to be applied to employees accounts, approvals must be completed by logging onto the HRA employer portal at Contribution approval requirements: The contribution approval process is required for both initial and ongoing funding. Do not forget to approve contributions for the initial funding of accounts. Contribution approval timing: Contribution invoices are posted on the Employer Dashboard for your approval approximately three days before the contribution date. It s a good idea to schedule a reminder on your calendar. Once HRA contribution amounts are approved, funds typically appear in employees accounts the next business day. Contribution approval is NOT required for HRAs that provide the full contribution amount to employees on the first day of the plan year (uniform coverage). Claims processing authority The employer is the plan administrator of the HRA as described under ERISA. BenefitWallet is not authorized to waive, alter or modify any terms or conditions of the HRA. Both the employer and BenefitWallet are claims fiduciaries of the HRA, as that term is used under ERISA, with respect to the following activities: 3
5 BenefitWallet will determine whether an HRA expense is qualified under the Internal Revenue Code and regulations thereunder, and any IRS written rulings, notices and advisories. BenefitWallet will make payments or distributions based on the framework of policies, interpretations, rules, practices and procedures provided for in your HRA plan documents and as otherwise agreed upon or directed by you. BenefitWallet (including its subcontractors) will not have any discretion, control or authority with respect to benefit determinations. You retain the authority to decide appeals. Claims payment process BenefitWallet will process claims within three business days of the date they receive a claim request from a participant. Checks, if applicable, will be issued within two scheduled daily check payment cycles, upon receipt of claims in good order. Claims are in good order when the reimbursement request contains all pertinent information, including information required to substantiate the claim. If the participant does not have sufficient funds in his/her HRA at the time the claim is submitted, the reimbursement request will be held and processed in accordance with the time frame described above, starting with the date that such funds are available. If a participant is not able to substantiate a claim or if a debit card payment is subsequently deemed ineligible for reimbursement, BenefitWallet will attempt to collect these amounts from the participant. If BenefitWallet is unsuccessful collecting these amounts, you will be responsible for collecting such amounts. BenefitWallet will make data available to you that identifies the participant and the unsubstantiated or ineligible reimbursement amount. BenefitWallet will not provide or negotiate for refunds of unused services or unneeded items and is not responsible for determining whether a participant received a cash refund from a merchant or provider for items or services originally purchased or paid for using the debit card. HRA payment services BenefitWallet offers the following payment services: Debit card services allow a participant s account balance to automatically transfer to a debit card integrated with the participant s account. The debit card can be used at any eligible merchant provided the merchant has properly configured the merchant code to identify itself correctly or is IIAS-compliant. Cardholders are subject to the terms and conditions described in the cardholder agreement, which is provided with the debit card. Employers decide whether or not to offer debit cards to their employees during the initial set up. Reimbursement services are made to participants via a check or direct deposit. Participants who do not have debit cards will be automatically reimbursed for any patient liability based on claims data provided by CareFirst. 4
6 Employer website You can access the employer website via The Employer Dashboard contains employee look-up information to resolve issues as well as Frequently Asked Questions. The individual designated as your primary business contact will receive logon information for this site. He/she may then set up sub-user IDs for other authenticated business contacts. Reporting BenefitWallet offers several reports to assist with your HRA plan administration. These reports are designed to show funding status, detailed participant information, and aggregate account information at the group level. Each report can easily be exported to Excel, CSV or XML, allowing employers to easily combine this data into any standard data management tool. The reports are organized into three categories: Employers needing assistance with their password should contact the Employer Support Team at Account balance and administrative reports Claims reports Funding and contribution reports Account balance and administrative reports Participant accounts: Provides details by employee of the election/benefit amount, claims paid, available balance and more. Utilization and forfeiture report: Displays employees remaining account balance and other account details after the end of the plan year and run-out period. This report differs from the savings account forfeitures report, which displays only accounts that have gone through the forfeiture process and subsequently have $0.00 balances. Group audit report: Shows a snapshot of your group s setup, including business contacts, plan design, contribution information, copays and funding. Employers should periodically review this audit report. Claims reports Weekly claims detail report: Validates funding requests and lists all paid claims supporting the weekly invoices and ACH transfers. Rejected claims write off report: Allows employers to view employees ineligible claims that have been written off. Employers should refer to this report to determine which claims are unsubstantiated claims and therefore need to become taxable. Claims needing documentation report: Lists all claims that still need appropriate documentation, including health care payment card claims and reimbursement requests made online or through the mail. 5
7 Rejected claims requiring refunds report: Lists all claims that have been rejected or partially rejected. Reasons for rejection include ineligible expenses and dates of service outside the plan year parameters. These claims require a refund to the plan. Funding and contribution reports Contribution funding details report: Provides details on contributions, including amount, deduction date, etc. This report can be helpful if you are an employer who makes incremental contributions throughout the year. Contribution report: Provides a list of contributions for a particular employee. Use the following parameters to select the employee and the time period desired: Start date End date Social Security Number Contacts Your Employer Support Team is available Monday Friday from 8:00 a.m. to 8:00 p.m. EST at or employersetup@mybenefitwallet.com. Your employees also have access to a dedicated customer service department at , Monday Friday from 8:00 a.m. to 11:00 p.m. (EST). Holiday schedule BenefitWallet will be closed for the following holidays in 2015: New Year s Day: Thursday, January 1, 2015 Memorial Day: Monday, May 25, 2015 Fourth of July: Saturday, July 4, 2015 Labor Day: Monday, September 7, 2015 Thanksgiving Day: Thursday, November 26, 2015 Christmas Day: Friday, December 25, 2015 The following fields are displayed online and may be exported to Excel, CSV or XML files: Last name First name Social Security Number Employee ID Contribution date Invoice number Invoice type Contribution amount Contribution type Settle status Type CareFirst BlueCross BlueShield is an independent licensee of the Blue Cross and Blue Shield Association. Registered trademark of CareFirst of Maryland, Inc. BenefitWallet is a product owned by Xerox HR Solutions LLC, an independent company that is solely responsible for their products and will be providing services to CareFirst members. BenefitWallet does not sell BlueCross or BlueShield products Xerox HR Solutions, LLC. All rights reserved. CST2452-9E (5/15)
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