Q
| Why is PEBB conducting the Dependent Eligibility Verification program?
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A
| The Board must be a responsible steward of employee and employer funds. Covering ineligible individuals in PEBB health plans increases costs for all PEBB members and the state. The goal of the DEV program is to ensure only those who are eligible have PEBB coverage.
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Q
| Didn’t I verify my dependents’ eligibility when I enrolled for benefits in October?
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A
| No, during Open Enrollment, you enrolled yourself and others for coverage. The purpose of the DEV program is to determine if enrolled individuals are eligible for coverage.
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Q
| Who and what were involved in Step 1 of the program?
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| A | All members who cover dependents in PEBB benefits were required to complete an online self-verification process and to submit the results. Members who determined their dependents were not eligible in Step 1 of the DEV program were able to remove them from coverage.
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| Q | Who and what are involved in Step 2 of the DEV program? |
| A | Step 2 involves providing documentation that substantiates eligibility. About 5,500 members who cover dependents were selected for Step 2. About 34% of those selected were selected at random. The rest of the group comprises members who were required to self-verify dependent eligibility in Step 1 and didn’t, and those who checked "disagree" with the results of Step 1.
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| Q | Don't members already provide proof of eligibility? |
A
| It’s typically not required. And members may forget to request coverage changes after Open Enrollment. For example, a member whose divorce is finalized midyear may forget to request a coverage change until the next Open Enrollment.
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Q
| How can I be sure my personal information will be protected in the DEV program?
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A
| The program meets all data security and privacy requirements of HIPAA. These are the same requirements medical providers, insurance companies and benefit plan sponsors must meet to protect patient health information.
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Q
| Will the DEV program offer savings?
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A
| Groups that conducted similar programs realized cost reductions averaging five percent. A five percent reduction of PEBB benefit costs equals millions of dollars each year. Such savings far exceed the $231,000 cost for the 2011 DEV program.
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Q
| Why did PEBB “outsource” this work?
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A
| Recent budget reductions cut PEBB staff from 19 to 17 employees. Remaining staff – who are all state employees – absorbed the workload to continue efficient operation of the benefit program for 130,000 members, while also complying with furlough requirements.
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Q
| Why did PEBB select Mercer to provide these services?
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A
| The Benefit Board selected Mercer to provide actuarial and benefit consulting services in 2005 based on a competitive, national request for proposals. For the DEV program, Mercer offered a comprehensive, tested, timely and accountable set of services through the existing contract.
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| Q | What gives PEBB authority to conduct and use a third party for DEV? |
| | The following sources lay out PEBB’s authority to conduct this project and share information with a third party for that purpose.
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PEBB has adopted administrative rules authorizing the DEV program: OAR 101-020-0026(4), published in the Oregon Bulletin for April 2011. PEBB has authority for such rules under ORS 243.125(3).
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PEBB has statutory authority to retain consultants to perform its functions. PEBB has entered into a contract with its consultant Mercer to conduct the DEV. Mercer may not use PEBB member information for purposes other than assisting PEBB.
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PEBB’s statutory duties include providing adequate health plan coverage “on the best basis possible with relation both to the welfare of the employees and to the state,” ORS 243.125(1), and “to meet the needs and provide for the welfare of eligible employees and the state,” ORS 243.135(1); PEBB’s statutory goal is “to provide a high quality plan of health and other benefits for state employees at a cost affordable to both the employer and the employees,” ORS 243.125(2); The Board has adopted a vision for PEBB that includes, as a key component, benefits that are affordable to the state and employees. The DEV program is one of many critical tools for combating cost increases associated with a group health plan.
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The Board has a legal duty to keeping its health plan in compliance with tax laws and with PEBB’s legal standards for dependent eligibility. For example, if PEBB allowed an ineligible individual to be covered, then PEBB’s cafeteria plan could fail to meet IRS standards and all employee members would have significantly increased taxable income.
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HIPAA privacy rules permit PEBB, as a plan sponsor, to share a member’s personal information for purposes of eligibility verification if the member’s privacy is protected. In addition, PEBB’s contract with Mercer protects the privacy of members’ personal information.
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