Employers routinely audit the administration of the group health plans they sponsor.  These audits include whether the plan is being administered to its terms and whether individuals receiving coverage under the plan are actually eligible for such coverage.  These audits are part of a compliant fiduciary process under ERISA.  That said, who is checking to assure that the group health plan is not being over-billed?  Said another way, who is reviewing facility bills before they are paid by the group health plan to assure that the bills do not contain non-compliant charges (i.e., charges that cannot be billed pursuant to CMS and related guidance)?  The fact is that over 90% of medical bills contain billing errors, and consumer medical debt is the number one cause of personal bankruptcies in the United States.  As a plan fiduciary under ERISA, employers must follow a reasonable process to weed out non-compliant charges prior to the group health plan paying those charges.  

Key Takeaways: 

• The problem: discussing non-compliant charges
• Difference between an audit and a compliance review
• "Compliance" to what? ERISA, ACA and, CMS guidelines
• Technology and implementation