Creating a Better Open Enrollment Experience

Leaders from Mercer discuss strategies to enhance the open enrollment season for both employers and employees.

A recent survey revealed issues employees have with open enrollment season, including material too difficult to understand and not enough time to make benefits decisions.

In a webcast, Mercer discussed ways to make the open enrollment period better for employees and employers alike.

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Tyler Harshey, a Mercer actuary focusing on employer and consumer preferences, based in Chicago, first pointed out that passive enrollment maintains the status quo for employees and is easy. If employers like what employees are choosing, and they haven’t made benefit changes, they may want to do a passive enrollment.

However, an active enrollment increases employee participation in their benefits decisions, he said. It is effective when an employer has made changes to benefits; it helps keep employee and dependent information current and it reminds employees of all the employer’s offerings. “Health savings account (HSA) and flexible spending account (FSA) funding elections are annual decisions, so why not pair this active decision making with medical benefits,” Harshey said.

He also suggested employers should consider the order in which benefits are presented. All benefits should be presented in one place, but employers should present medical, dental, vision, HSA and FSA benefits first then life, accident and disability insurance and voluntary benefits last. “In the Mercer Marketplace, we’ve found order matters,” Harshey said. “Employers can see more enrollment in certain plans if they change the order of presentation a bit.”

According to Harshey, choice helps different segments of the workforce. Mercer found among those younger than age 30, 20% are not confident in being able to afford out-of-pocket expenses, and among those age 60 and older, 15% are not confident. In addition, 35% of younger participants prefer to pay higher premiums in exchange for lower out-of-pocket costs, as do 55% of older participants. By salary, employees making $110,000 or more are more confident in being able to afford out-of-pocket costs, but still half prefer a higher premium.

Mercer also found that whether an employer offers three, four or five health benefit options, a significant number of employees enroll in each option, though there is still a skew toward richer benefits. But, according to Harshey, offering more than that could result in diminishing returns.

Offering Decision Support

Harshey suggested employers use decision support tools to help employees—online educational content, phone consultations, cost calculators—but, he said, one-on-one face time is the best. “Keep it simple and quick to use, personalize the experience and embed support tools within the enrollment flow so employees have them at the moment they need them,” he said. “Employees are more likely to use embedded tools than if the tools are on other sites and employees are given a link.” Mercer suggests well-placed videos and text, provider search tools or formulary search tools to decide between two networks or whether medications are on a provider’s formulary. In addition, Harshey said, Mercer uses “robo-advisers” which gather demographic data from individuals to come up with recommendations.

Cindy Schrader, a member of Mercer’s Total Health Management Practice in Philadelphia, suggested employers offer cost transparency tools to help employees become sophisticated shoppers of health benefits. A Mercer survey found 72% of large employers plan to offer high-deductible health plans (HDHPs) by 2019, but only half of all consumers knew where to go to get cost and quality data.

During open enrollment, employers should help employees understand what is shoppable—medical services and pharmacy costs—and employers should show employees how to navigate tools and use the information. Schrader suggested employers should test drive tools before choosing what to offer employee. They should be easy to access and easily understandable.

In addition, she said some employers are giving employees reasons to use the tools. “Employers are embracing loyalty rewards for employees who use the tools,” Schrader said.

Communication Should Be Year-Round

David Slavney, a member of Mercer’s Workforce Change and Communication Practice in St. Louis, Missouri, said health should be a year round conversation.” Health decisions happen outside open enrollment season,” he points out.

As for the cost and quality transparency tools Schrader discussed, she said employers should leverage communication channels that have the ability to personalize data. Employers can use vendors to prompt messaging, based on an employee’s health data.

Plan sponsors can also help employees prepare for conversations with their health care providers. “Make sure they understand their benefits, deductibles and co-pays; pull together a list of questions about certain proposed treatments and illnesses as well as potential treatment alternatives,” Schrader said. “And remind employees of the available tools and resources to help them and their doctors make informed treatment decisions.”

Slavney said communications must simplify the complex. Employers should break communications down to smaller pieces—not a 15-minute video, but a two- or three-minute video. In addition, information should be meaningful and relevant. Employers should segment the employee audience to target messages. “Think about how to break information into chunks to point out things relevant to particular participants. Help them think, ‘If I do this, this will happen, and if I don’t, this will happen,’” he said.

According to Slavney, now is the time to accelerate communications toward digital approaches. Many vendors use mobile applications, and employers should not just tell participants to get a certain app, but tell them how it will help them. He added that employers should use text messaging opportunities, contending that employees react more to texts than emails.

Slavney said traditionally employers have looked at open enrollment as an event just repeated each year, but he encouraged employers to think about their strategy and be experimental, then learn from their experiments to inform future decisions.

Regulators Provide Relief for Hurricane Harvey Victims

The IRS is loosening hardship withdrawal and loan rules, and the DOL announced postponed deadlines for Form 5500 filing, among other things.

The Internal Revenue Service (IRS) announced that defined contribution (DC) employer-sponsored retirement plans can make loans and hardship distributions to victims of Hurricane Harvey and members of their families.

Participants in 401(k) plans, employees of public schools and tax-exempt organizations with 403(b) tax-sheltered annuities, as well as state and local government employees with 457(b) deferred-compensation plans may be eligible to take advantage of these streamlined loan procedures and liberalized hardship distribution rules. Though individual retirement account (IRA) participants are barred from taking out loans, they may be eligible to receive distributions under liberalized procedures.

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Retirement plans can provide this relief to employees and certain members of their families who live or work in disaster area localities affected by Hurricane Harvey and designated for individual assistance by the Federal Emergency Management Agency (FEMA). Currently, parts of Texas qualify for individual assistance. For a complete list of eligible counties, visit https://www.fema.gov/disasters. To qualify for this relief, hardship withdrawals must be made by January 31, 2018.

The IRS is also relaxing procedural and administrative rules that normally apply to retirement plan loans and hardship distributions. As a result, eligible retirement plan participants will be able to access their money more quickly with a minimum of red tape. In addition, the six-month ban on 401(k) and 403(b) contributions that normally affects employees who take hardship distributions will not apply.

This broad-based relief means that a retirement plan can allow a victim of Hurricane Harvey to take a hardship distribution or borrow up to the specified statutory limits from the victim’s retirement plan. It also means that a person who lives outside the disaster area can take out a retirement plan loan or hardship distribution and use it to assist a son, daughter, parent, grandparent or other dependent who lived or worked in the disaster area.

Plans will be allowed to make loans or hardship distributions before the plan is formally amended to provide for such features. In addition, the plan can ignore the reasons that normally apply to hardship distributions, thus allowing them, for example, to be used for food and shelter. If a plan requires certain documentation before a distribution is made, the plan can relax this requirement as described in Announcement 2017-11.

The IRS emphasized that the tax treatment of loans and distributions remains unchanged.

Relief from the DOL

In addition, the Department of Labor (DOL) says it is working with the IRS to provide relief regarding certain verification procedures that may be required under retirement plans with respect to plan loans to participants and beneficiaries, hardship distributions and other pension benefit distributions.

The Department also says it recognizes that some employers and service providers acting on employers’ behalf, such as payroll processing services, located in identified covered disaster areas will not be able to forward participant payments and withholdings to employee benefit plans within the prescribed timeframe. In such instances, the Department will not—solely on the basis of a failure attributable to Hurricane Harvey—seek to enforce the provisions of Title I of the Employee Retirement Income Security Act (ERISA) with respect to a temporary delay in the forwarding of such payments or contributions to an employee pension benefit plan to the extent that affected employers, and service providers, act reasonably, prudently and in the interest of employees to comply as soon as practical under the circumstances.

The DOL relaxed deadlines for filers of Form 5500s. This relief is in addition to Form 5500 Annual Return/Report filing relief already provided by the IRS. Form 5500 series returns that were required to be filed on or after August 23, 2017, and before January 31, 2018, have until January 31, 2018 to file.

In general, ERISA provides that the administrator of an individual account plan is required to provide 30 days advance notice to participants and beneficiaries whose rights under the plan will be temporarily suspended, limited or restricted by a blackout period. The regulations provide an exception to the advance notice requirement when the inability to provide the notice is due to events beyond the reasonable control of the plan administrator and a fiduciary so determines in writing. The DOL says natural disasters, by definition, are beyond the control of a plan administrator. With respect to blackout periods related to Hurricane Harvey, the department will not allege a violation of the blackout notice requirements solely on the basis that a fiduciary did not make the required written determination.

Finally, the DOL says it recognizes that plan participants and beneficiaries may encounter an array of problems due to the hurricane, such as difficulties meeting certain deadlines for filing health benefit claims and COBRA elections. The guiding principle for plans must be to act reasonably, prudently and in the interest of the workers and their families who rely on their health plans for their physical and economic well-being. Plan fiduciaries should make reasonable accommodations to prevent the loss of benefits in such cases and should take steps to minimize the possibility of individuals losing benefits because of a failure to comply with pre-established timeframes.

In addition, the department acknowledges that there may be instances when full and timely compliance by group health plans and issuers may not be possible. It says its approach to enforcement will be marked by an emphasis on compliance assistance and include grace periods and other relief where appropriate, including when physical disruption to a plan or service provider’s principal place of business makes compliance with pre-established timeframes for certain claims’ decisions or disclosures impossible.

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