(Published January 5, 2009)
Happy New Year! Welcome back, and hope you had a good whatever it is you celebrate.
I have a new year's resolution for you. Now that you've come back and are, as one of my co-workers puts it, "all fired up and ready to go," it might be a good time to check on your record-keeping and record-auditing. Let me tell you about a couple of situations I found myself dealing with just before the end of the year.
In one case, I got a phone call from a woman who was calling on behalf of her father, one of our retirees. He had just gotten a HIPAA notice from his insurance carrier giving the dates of his coverage, and she wanted to know why his insurance had been cancelled. I went into our HRIS system, brought up his record, and immediately saw what had triggered the cancellation.
"Ma'am, is your father still living?" I asked.
"Of course," she responded.
Not according to our records. We showed him as having died two years prior. When we researched, we found that his wife had died, and somehow her date of death was indicated in his record also. The frightening part, however, is not that someone incorrectly input the record — anyone can make an error, and keying errors, while regrettable, are a fact of life. The scary part is that it was two years before anyone noticed and took action to cancel his benefits.
The second instance was not really anyone's fault. A young man came in to add his wife to his insurance policy, since she had lost her old insurance. We had a deuce of a time getting the HIPAA certificate from her old carrier — I think we waited almost three weeks. But it finally was faxed to me; I put it together with the enrollment form he had completed and put it in the box to be processed.
A month later, he came back wondering why he'd never received an ID card from the insurance carrier. I looked him up and it wasn't showing that he'd ever been added to the plan. Even with the open enrollment load, that was still an awfully long time to wait, and our processors are usually much faster than that. On checking, we found that during the three weeks that we were waiting for his wife's HIPAA certificate, the young man's manager had transferred him from a class that is eligible for benefits to one that is not. He did not realize that his new class was not benefits eligible, and it didn't occur to me to check and see if his status had changed. But he'd shown up on our COBRA report, and the processor responsible for terming coverage when the COBRA letters went out, had done her job.
We allow his new class to continue their benefits under limited circumstances, and as it turned out, he met the requirements. So we gave him the appropriate agreement to sign, and his coverage, retroactive to the beginning of the month, was processed.
In the first instance, I find it appalling that in two years, no one noticed that we were carrying a "dead" man on our plan. Someone should have audited those records more frequently than once every two years. The result would probably have been the same — cancellation of the coverage triggering a HIPAA cert and, thus, a phone call — but we'd have had the correction made months ago, if not sooner. Better yet, someone should have been more careful in doing the keying in the first place!
In the second instance, I really can't see that anyone was to blame — other than the carrier who neglected to send in the HIPAA cert. The employee has not been here long enough to realize that his status change would mean that he received his benefits from a different office. The processor had put the information in and had no reason to follow up. The processor who termed him for COBRA was doing exactly what she was supposed to do. And I had no reason to imagine that his status had changed or would be changing in that three-week period — I'd confirmed his eligibility when he first contacted me to make the addition. It's not a situation that is likely to repeat itself.
But I'm still going to be working to find a system of checks that would prevent this from happening again, in the unlikely event that it happens again!
Have a great new year, everyone!
Catherine Bannon is an HR consultant in Marshfield, MA (catherine.bannon@gmail.com). Bannon worked for 10 years in HR management before starting her consulting practice.
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