PSC bargaining unit members and retired faculty and staff under 80 who have dependents covered by their City health insurance plan have been receiving notices from the NYC Office of Labor Relations over the past few weeks concerning the “audit” of dependent coverage. The audit requires those with dependent coverage to submit certain documents showing that their dependents are eligible; those who do not do so face loss of dependent coverage.
While most bargaining unit members and retirees have had their dependents’ eligibility confirmed without major problems, some have faced difficulties complying with the audit. This article outlines where things stand after the audit’s October 4 deadline, and what you should do if eligibility for your covered dependents has not yet been confirmed. The City has said that no one will be dropped during the process for a Stage 1 appeal.
When the audit was announced this summer, the City had not negotiated with the unions in the Municipal Labor Committee (MLC) about the audit’s procedures. In response, the MLC, which includes the PSC, filed a lawsuit that led to some improvements, including an extension of the deadline to October 4 and the promise of an appeal process. It has become clear since that the City and Aon Hewitt, the consultant hired to carry out the audit, did not have an effective plan for dealing with the volume of responses they have received.
The City has not yet finalized the appeal process, and now says that employees should get their dependents’ documentation to Aon Hewitt by November 4, even if they did not submit anything before the initial October 4 deadline.
The PSC will post information on the City’s appeals process on the union website (psc-cuny.org) as soon as it is available.
The City states that no dependent will lose coverage until the employee through whom they are covered has received a notice of dependent coverage being terminated and a description of the appeal process, and has been given an opportunity to appeal. The City has advised the unions that such letters will not go out until sometime after November 4, and that coverage will not be terminated while an appeal is in progress.
PSC members say that to date, phone calls to Aon Hewitt seeking answers to questions have been frustrating, with members reporting hold times of up to 45 minutes before being connected to a representative.
“Aon Hewitt sold the City a bill of goods about how to conduct the audit, and then didn’t provide the staff or adequate planning to make it work smoothly for members,” said PSC President Barbara Bowen. “The unions had to go to court to achieve even a modest level of accountability in the audit process. The idea of conducting the audit over the summer months was ridiculous.”
In the wake of the October 4 deadline, those with covered dependents will likely find themselves in one of the following four categories:
(1) all documents submitted and eligibility confirmed;
(2) incomplete response submitted, additional documents required;
(3) dependents’ eligibility denied, resulting in notice of cancellation of coverage;
(4) no notice of the audit ever received, which could result in cancellation of dependents’ coverage that members may not discover until after an event where insurance coverage is denied.
Information on each case follows below:
Most who submitted the required documents should have received a notice saying that the eligibility of their dependents has been verified. In this case, no further action is required.
Many of those with covered dependents had to submit an incomplete response. For example, hundreds of City employees have faced delays in acquiring needed documentation because getting copies of birth and marriage certificates from foreign countries can take months. Even those whose documents are here in NYC found that the NYC City Clerk’s Office was unprepared for the flood of requests for copies of marriage certificates. As a result, it has taken the clerk’s office five to six weeks to send out requested copies. “The whole system stinks,” said one PSC retiree. For those who submitted an incomplete response, Aon is now telling callers they have until November 4 to get the additional required materials submitted. Given the backlogs and processing delays that have been seen in the audit so far, you should submit these materials as soon as you have them.
Aon Hewitt now says that all materials must be submitted by fax or by uploading them to Aon Hewitt website – not by mail.
Some members and retirees are receiving “notices of cancellation of coverage for unverified dependents.” In a move that adds insult to injury, this group includes some members who submitted documentation by October 4, and whose covered dependents are clearly eligible. It seems likely that Aon Hewitt advised the NYC Office of Labor Relations to send out these letters before a complete review of all the submissions that had come in. (Throughout the audit process, Aon has told callers that it needs at least two weeks to process submissions.) “This is the kind of thoughtless harassment that has characterized this entire process,” said the PSC’s Bowen. “Those potentially affected are, understandably, very upset.”
If you are also among those who had to submit an incomplete response, submit any additional required documents as soon as you obtain them, following the instructions in the notice you received.
Once the City announces its appeals process (see above), if you have eligible dependents whose coverage is still denied, you should file an appeal.
No Notice Ever Received
Those members with dependents covered by their City health plan as of May 30, 2013, who never received notice of the audit from the City should contact Patricia Young at the PSC office (e-mail firstname.lastname@example.org) so the union can assist you. This is important: If no documents for a covered dependent were ever submitted, coverage of dependents could be cancelled without your knowledge.
(Note: For members who started City health coverage after May 30, 2013, or who got married or had a child after May 30 – and therefore added dependents – those newly added dependents are not subject to the audit. Note also that CUNY retirees over 80 with dependents are not subject to the audit; adjuncts with covered dependents are also not affected, since their coverage comes through the PSC/CUNY Welfare Fund, not the NYC Health Benefits Plan.)