COMPTROLLER'S SEAL STATE OF CONNECTICUT

STATE OF CONNECTICUT

NANCY WYMAN
COMPTROLLER
OFFICE OF THE STATE COMPTROLLER
55 ELM STREET
HARTFORD, CONNECTICUT 06106-1775
MARK OJAKIAN
DEPUTY COMPTROLLER

COMPTROLLER'S MEMORANDUM NO. 2007-08

March 23, 2007

TO THE HEADS OF ALL STATE AGENCIES

ATTENTION:   Personnel and Payroll Officers, Chief Administrative and Fiscal Officers and Business Managers
SUBJECT:   Health and Life Insurance Premium Payments

I. INTRODUCTION

Pursuant to Connecticut General Statues Section 5-257 and 5-259, the State Comptroller is granted the authority to procure and deliver life and health insurance benefits to State employees and retirees. Under this authority, the Comptroller's Retirement & Benefit Services Division (RBSD) is responsible for employee enrollment records and the payment of premiums to the insurance carriers. To that end, the purpose of this memorandum is to provide information pertaining to recent changes to the active employee premium payment process. Further, this memorandum addresses the collection of employee premium shares in association with the administrative obligations of agency personnel/payroll offices within the Core-CT system.

This memorandum pertains only to active employee health and life insurance. Note that the definition of an active employee includes those on approved leaves where health and life insurance benefits are continued for the duration of such leave.

II. DISCUSSION

The Office of the State Comptroller (OSC) provides health and life insurance benefits to eligible employees through the Core-CT Benefits Administration module. The Benefits Administration module maintains enrollment data and calculates employee and employer premium share payroll deductions or billing amounts based on the employee's pay frequency. Agencies are responsible to ensure the accuracy of the information. Through an interface with Core-CT, enrollment data is sent weekly to the insurance carriers. The insurance carriers are paid a monthly premium payment from OSC based on the enrollment data the Core-CT system has provided.

The health and life insurance premium payment remittance process is run centrally once each month and provides two basic functions. First, based on the plan and coverage class in the employee's record at the time the process is run, it determines the amount of monthly premium OSC owes to the carrier and the expected employee/employer shares based on each employee's pay frequency or benefits billing status. Second, the process records the amount of premium received from the payroll or billing system to verify and audit that each employee has met their premium obligation.

It is important to note that timely processing of HR and benefit actions in the Core-CT system is critical since the State remits premiums to the carrier based on the enrollment record in force at the time the process is run. Untimely processing of HR and benefit actions is the leading cause of employee benefit disruptions. While recognizing that some retroactivity is unavoidable, the State's health insurance plan is fully insured; therefore, there is no opportunity to make retroactive changes beyond a two month period in an effort to correct over- or under-paid premiums or other such enrollment issues.

III. PROCEDURES

A. Employee Premium Calculation/Verification

Employees are required to make premium payments based upon the plan and coverage class of each benefit. Premiums are calculated automatically by the Core-CT system and either deducted directly from their paycheck or paid by check through the benefits billing system if on a qualified unpaid leave or worker's compensation.

Employees who miss all or a portion of their deductions, pay late in billing or fail to pay in billing, risk disruption of their coverage. It is each agency's obligation to ensure that employees are properly enrolled and are paying the correct premium. Accumulated unpaid premiums for a period of two months or more will result in the termination of health and or life insurance benefits.

B. Auto Queries

To assist agencies in identifying employees who may have missed a premium payment in a proactive manner, five new auto queries have been created. Four of the queries identify employees enrolled in health and/or life coverage without a payroll deduction. Note that the query results do not include individuals who have unpaid premium and are actively enrolled in benefits billing. These queries are run every other Friday immediately following the payroll confirmation. The fifth is the delinquent accounts query which identifies individuals who have unpaid premiums in benefits billing. The delinquent accounts query is run each Monday. Should an employee be reported in any of the queries, a review of their record is required to determine their status and the proper course of action to ensure that appropriate premiums have been paid.

The RBSD maintains a benefits email list of agency personnel who receive the auto queries. Each agency is permitted up to three email addresses. Agencies wishing to add or change the email addresses on file may send an email request to: osc.benefitcorrections@po.state.ct.us ; place "Benefits Auto Query" in the subject line.

C. Premium Reports

In addition to the new auto queries, a new audit report has been created. This report is designed to allow agencies to audit employee premium payments for a specified date range. It lists employees where the employee or employer amount paid via payroll and/or in benefits billing doesn't match the expected premium. The report contains historic data from March 1, 2007 forward. Note that since March 2007 is the first month that the new remittance process is available, the audit report cannot be run until after the April 2007 remittance calculation is run.

The Payment and Discrepancy Report has been upgraded to include carrier premium payment information. The Discrepancy section of the report lists all employees who have not paid their share of premiums for the current month.

Records for employees that show up on the aforementioned reports must be reviewed to ensure that appropriate premiums have been paid. These reports will be monitored centrally to ensure compliance.

Both the Payment and Discrepancy report and Audit report are accessible via the following menu path in Core-CT: Benefits > Reports > Payment and Discrepancy Report. Enter a run control id and the report selection options will appear on the ensuing screen.

D. Correction of Employee Underpayments

Once it has been determined that an employee has underpaid premiums, a payroll/billing audit spreadsheet must be completed and sent to the Core-CT Help Desk: core.support@ct.gov The spreadsheet must then be reviewed and approved by the Central Benefits Unit (CBU). Once approved, the repayment of premiums will commence as follows:

Unpaid premium amounts must be paid via the method calculated. Specifically, if the underpayment is attributable to a payroll deduction, repayment will be made via payroll deduction using the arrears process. Arrearages will be paid back according to the following limits per pay period until paid in full: Medical plans - $60, dental plans - $20, basic group life plans - $25, and supplemental group life plans - $25. However, employees may choose to pay the entire amount in one lump sum. The arrearage amount is in addition to the normal premium deduction. Review the Core-CT Retroactive Benefits Job Aid for further information regarding the arrears process.
http://www.core-ct.state.ct.us/user/hrjobaids/ben/default.htm

For amounts attributable to benefits billing, the employee must pay by check. Amounts must be paid back in an amount no less than one month's billing premium. For example, if the past due amount is $200 representing two months of overdue premium, the employee must pay no less than $100 towards the overdue amount along with the current month's payment. The employee would pay $200 for two months, and then resume normal billing payments of $100.

E. Correction of Employee Overpayments

Similar to underpayments, if an employee is found to have overpaid, a payroll/billing audit and a retroactive adjustment spreadsheet must be sent to the Core-CT Help Desk: core.support@ct.gov

F. Retroactive Transactions

The CBU will not permit the processing of retroactive transactions greater than 60 days. Exceptions will be considered under very limited circumstances at the discretion of the CBU. In addition, prior to entering into a stipulated agreement, arbitration award or other such agreement/settlement with an employee having the potential to impact benefits, contact the CBU. This will ensure that the settlement terms are consistent with the CBU's ability to implement terms and conditions that may impact health and/or life insurance benefits. Note that agencies may need to resort to other administrative remedies on their employee's behalf if they fail to consult the CBU prior to processing a retroactive transaction with or without a settlement agreement.

See the Core-CT Retroactive Benefits Job Aid for additional information. http://www.core-ct.state.ct.us/user/hrjobaids/ben/default.htm
For further assistance, contact the CBU via email at: osc.benefitcorrections@po.state.ct.us

G. Non-payment of Premium

Employees are required to pay their share of premiums in a timely basis. Therefore, employees who have an outstanding premium balance for a period of 60 days, have failed to maintain the repayment terms outlined in Section D and have not responded after having been notified in writing that they have overdue premiums, must have their coverage terminated for non-payment of premiums. The termination is retroactive to the date the last full premium was received.

Prior to terminating coverage under this section, the employing agency must send the employee a written notice via certified return receipt mail informing them that their coverage will be terminated unless they meet the repayment terms from Section D. The notice must include the total amount due, a payment due date (15 days from the date the notice is received by the employee). In addition, the notice must inform them that if the repayment does not begin by the due date that coverage will be terminated for non-payment and that COBRA is not available. Once coverage is terminated, the employee may re-enroll in health insurance coverage during the open enrollment period or other such qualifying event immediately following the termination. Life insurance reinstatement is subject to Evidence of Insurability should the employee wish to re-enroll.

To terminate coverage in the Core-CT system, use the manual BAS activity of TNP (Termination for Non-Payment). Note that TNP is not a COBRA qualifying event.

A template of the termination of coverage letter is available as a benefits job aid on the Core-CT website. http://www.core-ct.state.ct.us/user/hrjobaids/ben/default.htm

H. Additional Information

Additional information is available in the Core-CT Benefits Job Aids and the March 2007 HRMS User Group Presentation available on the Core-CT website. For additional information on the benefits billing process, see Comptroller's Memorandum 2004-3a.

IV. CONCLUSION

Questions concerning this memorandum may be directed to the Central Benefits Unit at (860) 702-3535 or by email at: osc.benefitcorrections@po.state.ct.us

Very truly yours,

Nancy Wyman
State Comptroller

NW/TW/SA

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