Q. A few of our employees have added their spouses to our health
A. Yes, you can verify the eligibility of dependents covered under your health benefits plan. There are two ways to do that. You can conduct a dependent audit of all employees covered by the health benefits plan to verify eligibility of all dependents, including spouses and children. Or you can do spot checks—if the terms of your health benefit plan give the employer discretion to set administrative procedures.
If spot checks are permitted, be careful about deciding when a spot check is appropriate. To avoid a claim that you’re targeting particular individuals for discriminatory reasons, establish guidelines setting forth the type of information that would warrant a spot check and then uniformly perform the spot checks in accordance with those guidelines, without regard to any employee’s protected class.
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