Frequently Asked Questions


While the majority of calls we receive in our Dependent Verification Center are from employees calling to check to see if their documents have been received and are acceptable, employers have questions too. Here are some of the most frequently asked questions we receive from employers:

What, if any, administrative grace period is allowed for data entry/processing time as a result of a dependent eligibility verification project failure? For example, if the dependent is reported as failed on 08/30 and we send the failure to the client on 09/03 and they process the termination on 09/06, can they terminate the dependent's coverage effective 08/31?

Unfortunately, the 06/28/2010 interim final rules on rescission have no exception for an administrative grace period. So, any termination of coverage that occurs with a retroactive date is considered a rescission and can only take place if there has been fraud or intentional misrepresentation of a material fact—unless, of course, it is supported by the additional attestation language discussed earlier.

If a dependent's coverage is canceled due to failure to comply with the dependent eligibility verification project (lack of or insufficient documentation) and they formally appeal in the interim with no coverage, there is a claim denial, how is this to be handled? Does the employer have to reinstate at the point of denial notification?

Ineligibility is an acceptable reason for termination of coverage. If a medical claim's service date is after the termination of coverage, the claim should be denied due to ineligibility. Note, however, that the individual will have full claims and appeals rights with regard to the medical claim according to DOL FAQs from 01/2002, Q&A 3.

The final rules state that a dependent is not allowed to be dropped from coverage during a claim and appeal situation if he or she has a concurrent health care claim. What, if any, responsibility does the dependent verification team have in confirming that dependents have concurrent health care claims at the time of being dropped based on determination that they did not meet the requirements of the verification window?

Due to the fact that the dependent has been dropped prior to the claim and appeal period, there is no responsibility on behalf of the dependent verification team to confirm that a concurrent health care issue is taking place. There are challenges associated with not only collecting this information, but also ensuring that the information is valid and accurate. Alight feels this may expose our risk of compliance.

In the end, we will track through our benefits center anyone who calls in stating he or she has a concurrent care issue. We will then provide a report at the end of the verification period for our clients' discretion on whether or not they wish to remove coverage for any particular dependents notified through this process.

The final regulations state that employers should give 30 days' notice prior to any retroactive coverage termination. Will this lengthen the dependent verification process?

No, the dependent verification service sends out a termination notice at the end of the communicated verification end date. However, there is a grace period built in into our process to allow for additional submissions. This notice serves as reasonable notification prior to the date of coverage termination to notify the associate. It will be important to adjust our time frames within the timeline accordingly to account for this notification to allow for sufficient timing.

If a company's plan requires that dependents not be enrolled in other coverages, what proof of coverage will Alight collect to confirm this? What about a signed affidavit?

This is a plan requirement that is virtually impossible to confirm through our verification process. While we can certainly support an affidavit, we do not recommend adding this piece of documentation into your verification sets. Our reasons include:

Are foster children legally required to be covered under the health care reform legislation?

The DOL clarified in a Q&A on their website the type of children who must be covered up to the age of 26 as a result of health care reform. Foster children are included in the list. In summary, only children defined by Internal Revenue Code section 152(f)(1) need to be covered until the age of 26. These children include sons, daughters, stepchildren, adopted children (including children placed for adoption) and foster children.

However, being a foster child is governed by each state's laws, so the age at which coverage ends will vary. Some states are 21, some are 18, etc. It makes sense that once the individual is no longer a foster child per agency or the court order that health care reform no longer applies. Note that neither Congress nor the agencies have addressed this point.