Absence Management Workshop

Transcription

1 Absence Management Workshop April 2016 Presenters Elaine Coffman Account Director Beth Patil Sr. Account Manager MMA Panel Sue Mathiesen - Director of Research Jackie Webster - Account Director Jaime Kinzer - Asst. Manager, Client Services Cristina Sanders - Senior Account Manager

2 Agenda What is Absence Management In Brief: Laws & Considerations Impacting Absence Management FMLA State Laws ADA COBRA Paid Leave, STD and Workers Compensation Internal Absence Management Program (Including Resources) Outsourcing Absence Management Summary Thoughts 1

3 WHAT IS ABSENCE MANAGEMENT

4 Absence Management Compliance with federal, state, company/union leave laws and regulations regarding employee absences State FMLA Leaves FMLA ADA Reporting and tracking are critical first steps in absence management Integration with a carrier or TPA allows for efficient administration, smoother transitions from STD to LTD, more consistent data and, often times, lower overall costs COBRA Workers Comp Employee Company Leaves LTD STD 3

5 Absence Management - Key Definitions FMLA: Employers with 50 or more employees for 20 or more weeks in a year within 75 miles ADA: Employers with 15 or more employees COBRA: Employers with 15 or more employees Workers Compensation: 1 employee (even if it s just part-time) Various state & local laws: Varies by state/local Incidental LOA policies: Extreme variability by employer, with terms/provisions unique to each PTO and sick days/banks STD and salary continuation Misc. personal leaves, both paid and unpaid 4

6 Why is it Important to Manage Absences Well? Significant Cost* Direct cost for incidental absence & disability benefits average 4.9% of payroll (based on those who offer these benefits) Indirect cost (replacement labor and lost productivity) is roughly the same Combined 8% of payroll 54% of Mercer survey respondents* report senior management is concerned with indirect cost Many employers are not tracking cost impact (or properly tracking leaves at all!) Most employers recognize the need to improve the process Costs associated with abuse and mismanagement Impact on quality and safety Liability related to compliance failures under the FMLA and ADA * Source: 2013 Survey on Absence & Disability Management, Mercer 5

7 Direct and Indirect Costs of Absence Management Costs Associated With Unplanned Leave Maintaining additional staff and/or overtime Paid healthcare during time off Short-Term Disability and related costs Administrative effort to ensure consistent enforcement of leave policy across all supervisors and employees Preventable medical expense Performance risks pertaining to specific industries and workplaces. Replacement workers cost more than regular pay Overtime 33% to 44% more Temporary/Contract workers: 15% more When Supervisors fill in: 19% more. Replacement Workers Are Less Efficient 71% as efficient during unplanned incidental absences 79% as efficient during extended absences. 79% as efficient during planned absences. Hidden, or Indirect Costs of Absence Include Poor quality of goods, services resulting from overtime fatigue or understaffing Reduced productivity Excess manager time (dealing with discipline and finding suitable employee replacements) Safety issues (inadequately trained employees filling in for others, rushing to catch up after arriving as a replacement, etc) Poor morale among employees who have to fill in or do extra work to cover absent coworkers 6

8 Liability is a Big Deal FMLA and ADA compliance failures are key focus of the DOL and EEOC Are you covered for potential lawsuits? How do you plan to finance a potential lawsuit? Look under Management Practice Coverage Employment Practice Coverage - Covers Managers, Directors, and Officers of Organizations - Protects against wrongful employment acts (discrimination, harassment and so on) - Most policy terms and conditions include coverage for FMLA and ADA lawsuits - Covers attorneys fees and potential judgment Not automatically included important to check that you have it 7

9 The Cost of a Trial The cost of losing an FMLA case at trial can be significant. Assumes: $40,000/year salary 2 years of unemployment until trial DAMAGES ITEM COMMENT TYPICAL AMOUNT Back pay 2 years Common award in termination case lost wages up to date of judgment $80,000 Front pay 1 year Awarded if employee has not yet become re-employed at time of judgment lost wages looking forward $40,000 Pre-judgment interest on back pay only Always awarded; rate and whether compounded varies; estimate here $8,000 Liquidated damages Plaintiff s attorney s fees and costs Similar to punitive damages equal to amount of front/back pay plus prejudgment interest $128,000 Employer pays if employee wins $125,000 Employer s est. attorney s fees and costs Employer always pays (and is usually larger than employee s fees) $125,000 TOTAL $506,000 See Brown v. Nutrition Management Services Co. (E.D. Pa. 2009) TOTAL $477, * Based on current customers as of 2/13. Fortune 100 list Guardian AbsenceWorks is provided by Guardian and Reed Group. Reed Group, Ltd. is a subsidiary of The Guardian Life Insurance Company of America, New York, NY. Reed Group, Westmoor Drive, Suite 210, Westminster, CO

10 Absence Management Highly Technical Absence management has become highly technical Compliance requirements related to FMLA and ADA State laws/city laws complicate matters Policy requirements steps that carriers will require Return to work (RTW) process Employees have learned how to game the system Most employers want to improve their LOA process Different departments manage different aspects - siloed Concerned about what can be done without running afoul of legislative or carrier requirements More interest in outsourcing to gain expertise 9

11 What Is MMA-MI s Role? Tough one FMLA and ADA are employment laws with benefit implications Support you in reviewing outsourcing options and manage implementation Recently conducted comprehensive vendor capability review Support client implementations (vendors, ben admin, training, communication) Benchmarking galore! Recently added resources IBI and Think HR (Free!) Employer Services Group for policy review/development Incorporate into PATH Enterprise Reporting Analytics Integrating absence data with medical/rx, wellness, and workers comp We are not employment law specialists you will need to leverage employment law specialist for compliance issues 10

12 Industry Differences Can you measure? Do you understand costs and potential opportunity for improvement? Could outsourcing help? Source: MetLife Management (ComPsych) 11

13 The Burdens Employers Face Administrative Burden Compliance Challenges Litigation Exposure Lost Productivity & Associated Costs 12

14 Trends In Absence Management 13

15 Trends in Absence Management (cont.) 14

16 Summary Thoughts Imperative that employers understand the compliance requirements related to leaves of absence Best practices can be adopted that will: Improve compliance with legislative requirements Help identify potential employee abuse patterns Reduce length of disability-related leaves Improve employee accountability for following the process 15

17 IN BRIEF: LAWS & CONSIDERATIONS IMPACTING ABSENCE MANAGEMENT

18 In Brief: Laws & Considerations Impacting Absence Management FMLA State Laws ADA COBRA Paid Leave, STD and Workers Compensation 17

19 FMLA

20 What is the Family Medical Leave Act? Overview: Provides up to 12 weeks (26 weeks to care for covered service members) of unpaid leave for employees In a 12 month period calendar year, fixed year, measured forward or rolling backward Reason: Employees or a family members serious health condition or a birth/adoption OR for any qualifying exigency arising out of the fact that a spouse, son, daughter, or parent is a military member on covered active duty or call to covered active duty status Eligibility: Employed at least 12 months and worked at least 1250 hours during the prior 12 months Benefits during FMLA: Health, dental, vision, etc. benefits must be maintained under same conditions as if the employee had been continuously employed Employee must be returned to an equivalent position Employee Notice to the Employer: Right to notice, at least 30 days advance notice if practicable (only verbal notice required) Employer must inquire further to determine FMLA applicability 19

21 Family Medical Leave Act Serious Health Condition Serious health condition means an illness, injury, impairment, or physical or mental condition that involves: Any period of incapacity or treatment connected with inpatient care An absence of more than three calendar days that involves continuing treatment Any period of incapacity due to pregnancy or prenatal care Any period of incapacity due to a chronic serious health condition (asthma, diabetes, epilepsy, etc.) Absences to receive multiple treatments 20

22 Family Medical Leave Act Flow Chart Employee notifies that they need to take leave. When the need for leave is foreseeable, an employee must provide the employer with 30 days advance notice of the need for FMLA leave NOTE: This is considered being notified of leave. Employee Returns the completed Certification of Healthcare Provider Form Employer must give at least 15 calendar days to return the form. Employee returns to work (fitness for duty may be required) in same or similar position. ADA might come into play. Employer posts notice and has policy in handbook Employer determines employee eligibility. Has been employed by the employer for at least 12 months AND has worked at least 1,250 hours (actual hours worked) during the 12-month period immediately preceding start of FMLA leave, and is employed at a work site where 50 or more employees are employed by the employer within 75 miles of that work site. HR provides the employee with Notice of Eligibility and Rights & Responsibility Must be done within 5 business days of being notified of leave HR provides the employee with Designation Notice Must be done within 5 business days of being notified of leave. 21

23 ADA

24 Americans with Disabilities Act (ADA) Federal law that protects rights of people with disabilities Prohibits employers from discriminating against people with disabilities Requires employers to provide reasonable accommodation to disabled employees (must provide accommodations unless it causes an undue hardship) 23

25 Americans with Disabilities Act (ADA) Amended in 2009 (ADAAA) Broadly defines disability A physical or mental impairment that substantially limits a major life activity A record of a physical or mental impairment that substantially limits a major life activity Perception of a disability Includes silent disabilities, like mental health diagnosis Major life activities include learning, thinking, concentrating, and communicating EEOC says many mental health disorders will be a disability 24

26 Americans with Disabilities Act (ADA) Reasonable Accommodation An effective accommodation that enables the disabled individual to perform the essential functions of the position It is assistance or changes to a position or work environment, or the way that things are usually done, that will enable an employee to do his/her job with the disability, and enables the qualified individual w/a disability to enjoy an equal employment opportunity. Employers must engage in the process Not the best accommodation and not every accommodation Examples: Time off Changes in equipment (headphones, microphones) or other assistive technology Changes in work station location Additional training or modified training 25

27 Americans with Disabilities Act (ADA) Impact on leave administration is more complex return to work accommodation process Opportunity to actually reduce absence costs by bringing people back earlier - Shortens length of disability - Reduces number of LTD claims Managers need to be trained to recognize requests Many STD/LTD carriers offer free ADA resources to help companies with accommodations as it reduces disability costs 26

28 Reduce Absence Costs Return To Work (RTW) Programs 27

29 Reduce Absence Costs Return To Work (RTW) Programs 28

30 STATE LAWS

31 State Laws FMLA allows states to set standards that are more expansive than the federal law and many states have chosen to do so Over 240 laws that could impact a leave of absence State FMLA-type laws (more generous than FMLA) State mandatory disability laws State ADA laws State paid leave laws City or municipality laws that address leave requirements, paid leave and disability leave rules 30

32 State Laws - Example 31

33 COBRA

34 COBRA A leave of absence may effect benefit eligibility and trigger continuation coverage. COBRA requires: A qualifying event (in most cases the beginning of the leave) and A loss of coverage COBRA applies at the end of the leave Loss of coverage occurs when employer is not obligated to reinstate coverage upon return Qualifying event occurs at termination of employment/loss of eligibility Qualifying event date is the date employee failed to return from FMLA 33

35 PAID LEAVE, STD AND WORKERS COMPENSATION

36 FMLA & Paid Leave/Disability Paid Leave Employer can allow employee to take paid leave concurrent with FMLA Employer can require an employee take paid leave for FMLA if it is required for other unpaid leave as well Must clearly notify employees and must be in FMLA policy Short Term Disability Typically STD leave would be considered FMLA Two different definitions of disability For example, disability may only pay 6 weeks for birth of child but employee can take 12 weeks FMLA (no pay the second 6 weeks) 35

37 FMLA & Workers Compensation System to protect workers that become hurt or contract an illness on the job Benefits: Medical Expenses Wage Loss Vocational Rehab Services Compensation for Loss of Use A Serious Health Condition can occur on or off the job Employer should designate workers compensation leave as an FMLA leave 36

38 Interaction with Paid Leave, STD and Workers Compensation STD, FMLA, workers comp are rooted in an inability to work due to a health condition, but benefits differ It is critical that you understand they may have different definitions of disability, timeframes for leave and so on In some cases, benefit protections overlap and in some cases they may not Make sure you document your choice to run leaves concurrently in policies (i.e. workers comp runs concurrent with FMLA) Best to evaluate each situation and potential benefit plan/legal requirement that may apply 37

39 INTERNAL ABSENCE MANAGEMENT PROGRAM

40 Establishing an Absence Management Program 1. Develop Leave of Absence and Return to Work Policy 2. Develop Process & Procedures for Administration 3. Train Managers & Supervisors on Policies & Procedures 39

41 Establishing an Absence Management Program 1. Develop Leave of Absence and Return to Work Policy: Include FMLA, State Leave Laws, STD, LTD, Company Leaves, Workers Compensation Include Return to Work policy and process to address ADA accommodations Include substitution of paid leave policy Include continuation of benefits and payment of premiums Is policy consistent with Union CBA? Precedent? Does policy have carrier approval? 40

42 Establishing an Absence Management Program 2. Develop Process & Procedures for Administration: Centralize process, if not already doing so Experts should operate process Gather/develop appropriate forms and documents Create procedures on how to handle: - Identification of potential leave situations/employee rights - Distribution of notices (required and functional) - Responding to calls/requests/appeals - Reporting, recording and tracking absences/leaves (including intermittent) - Tracking benefit payments and benefits eligibility/cobra - Notification of life/disability portability and conversion info - Staffing for absences/leaves - Cases of abuse and discipline 41

43 Establishing an Absence Management Program 2. Develop Process & Procedures for Administration: (cont.) 42

44 Establishing an Absence Management Program 3. Train Managers & Supervisors on Policies & Procedures Outline roles and responsibilities Relay consequences for non-compliance Educate in advance - Technical requirements at federal, state and local levels - Identification of type(s) of qualifying leave - Handling of approvals, denials, appeals Provide direction on how to identify a leave as a potential reasonable accommodation (if FMLA doesn t apply, ADA might) Roles as fiduciaries, and risks that poses 43

45 Absence Management Program: Resources ThinkHR Employee Leave Toolkit - FMLA Administration Checklist - Sample Templates - Fillable Forms - Customizable Word Documents - Sample Policies Interactive Federal & State Leave Law Charts Training for Managers and Supervisors - FMLA, Employment Law, ADA, and more! ThinkHR Live HR experts to answer questions and provide advice 44

46 Absence Management Program: Resources MMA Webinar February 2016: An Employer s Guide to FMLA and COBRA Department of Labor (DOL) FMLA site: Federal vs. State Family and Medical Leave Laws: DOL Sample Notices ADA Guidance sites: Vendor (STD, LTD, Workers Comp, FMLA) resources Legal resources for a fee (including assistance with various state laws) Company attorney MarBarLaw Other firms working on retainer specifically for FMLA 45

47 Absence Management Program: Resources MMA Employer Services - Human Resources Consulting Human Resources Audits FMLA Guidance and Policy/Handbook Review and Development Employment Issues Job Descriptions Onsite training for managers and supervisors Onsite training for employees on company expectations/policies Safety and Loss Control consulting IBI and other Benchmarking Resources Consult with your MMA Account Director to learn more Overall support for HR and business leadership in enhancing organizational culture and wellbeing 46

48 OUTSOURCING ABSENCE MANAGEMENT

49 Common Reasons for Non-Compliance Failure to notify employees of FMLA rights Failure to notify employees that leave will be counted towards the employees FMLA entitlement Counting FMLA absence toward the company s absentee policy for disciplinary purposes Taking disciplinary action for using FMLA Failure to grant leave Failure to reinstate employees to the same or equivalent position including shift Termination Failure to make eligibility determinations within 5 days of the request for leave Failure to request a FMLA certification in writing, not giving at least 15 days to complete and return the certification, and not setting forth the consequences in writing of not returning a completed certification 10 Failure to follow the FMLA regulations regarding challenging the validity of a certification 48 48

50 Benefits of Outsourcing You don t know what you don t know HR support in understanding and navigating the complicated laws Highly structured process with significant compliance support Employee accountability to an outside source (may reduce abuse) Outlier costs to outsource replace internal costs Eliminates punitive exposure for managers and supervisors Assistance in event of a DOL audit Opportunity to include ADA assistance 49

51 Considerations Around Outsourcing Absence management is highly technical Outsourcing allows vendor to manage process Ensures use of appropriate/most current forms Penalties for non-compliance Reduce the legal risk of non-compliance with leave regulations When integrated with STD and/or LTD, can reduce employee absences and increase return to work productivity Easy to use portals Initiate & manage claims from beginning to end Track time including intermittent leaves Many offer access to reporting and analytics 50

52 Considerations Around Outsourcing (cont.) Costs vary based on full service, self service, ADA support ADA is vague and difficult, services when outsourcing typically include: Compliance and Communication Assist employers with the creation of policies, procedures and supervisor training Provide employers with research and insights Helps with requests for accommodation Response to Requests Recommendations from tenured and ADA certified clinical and vocational resources Support the interactive process between employer and employee Additional knowledge resource 51

53 Considerations Around Outsourcing (cont.) If a multi-state employer, vendor will manage laws based on employees location Are adequate internal resources available to effectively manage leaves? Market options have improved over the last several years Options through life/disability carriers - Pro s: Availability of Options/BenAdmin/Integrated intake makes it easier for employees (single call to report a new disability or FML event, single medical certification process) - Con s: Often requires another line of coverage/ Do you want to be tied to that vendor? Stand alone options Leveraging software option 52

54 Considerations Around Outsourcing (cont.) Total outsourcing requires data exchanges, following vendors process and consideration around takeover of historical leaves 120 Implementation Process Data requirements for EDI feeds beyond benefit information Payroll to FMLA Vendor Ben Admin to FMLA Vendor: - Payroll to Ben Admin: Work Hours! - Group structure built on ben admin platform - Job classifications, supervisory and divisional structure, contact information 53

55 Outsourcing Considerations: Historical Data Option 1: History and takeover (best practice) Usually need to create history on excel spreadsheet Option 2: History and NO take over Take over of existing leave can be expensive Option 3: Clean slate (no history and no takeover) Example: If your effective date is 1/1/2014 and you elect clean slate, an employee who was out on leave for 11 weeks from 9/1/ /16/2013 would be entitled to an additional 12 weeks (26 weeks for military caregiver leave) if the employee were to file a new leave with the vendor as of 1/1/2014. Option 4: Clean slate open leave tracking Option 5: Clean slate takeover only Vendor administers any open family medical leave for an employee who is already on leave or has files a leave for a future date after vendor begins leave administration 54

56 Salary Continuation & FMLA - Process Monday Friday 9:00 am 9:00 pm EST Employee contacts HR and calls Hartford at to report a claim Reporting FMLA Only Reporting Short Term Disability (STD) with Leave Hartford confirms employee information in system and gathers necessary information to initiate leave. Employee questions are answered. Hartford will trigger initiation of leave management. Hartford gathers necessary STD claim information and advises employee this will also begin the FMLA claim. Depending on triggers, Hartford will take the following actions, as appropriate. Hartford makes eligibility decision and generates employee packet of information including: Initial claim letter FMLA Eligibility and Rights and Responsibilities Notice Certificate of Healthcare Provider form (CHCP) for stand alone leaves only (as appropriate) Hartford sets date for 15 day determination deadline and return to work call out. When necessary, Hartford STD Claim Analyst makes two attempts to gather medical information from physician. If unsuccessful, Hartford calls employee on the 4 th business day. Hartford makes leave determination based on documentation received. This includes the incomplete and insufficient CHCP form and late medical certification process. Hartford sends designation notice for federal and/or state leaves. STD Claim Analyst receives completed claim and makes determination*. Five business days prior to the end of the approved continuous leave period, Hartford will call the employee to determine whether the employee is returning to work or will need to extend their leave. Hartford generates a letter notifying the Employee & Employer of the outcome of the return to work call. STD claim continues until employee: Returns to work No longer meets the definition of disability Exhausts available STD benefits. *STD claim approval must be received by ABC HR by the payroll cutoff date in order for the employee to receive payment on that paycheck. If an approval is not received by the cutoff date, then the employee will be paid retroactively on the first paycheck after STD claim approval is received. If an extension is requested, the employee is asked to provide a CHCP within 15 business days. If necessary, Hartford will generate extension notice to employee based on new leave end date. Hartford sets 15 day determination deadline and return to work call out. Leave Management process continues until the employee: Returns to work; Does not provide timely certifying documentation; or Exhausts available leave time. Hartford generates the following notifications upon exhaustion of the last job protected leave: 10 days prior Approaching Exhaust letter sent Day of Final Exhaust letter sent. Confidential & Proprietary The Hartford 55

57 Outsourcing Partner Type 56

58 OPTIONS THROUGH LIFE/DISABILITY CARRIERS

59 Many Life/Disability Insurance Carriers Offer Help Makes sense as many leaves are also short term disability leaves All carriers offer different services and options FMLA administration Software for administration ADA administration or advice Concierge service/access to experts for questions Most carriers require the disability business or at least one line of coverage Options limited by group size Pricing ranges from $2 - $5 pepm Need to consider you are tying LOA to the disability vendor 58

60 Carriers Pricing/Size Limits/Service Options Carrier Size Line of Coverage Options Fees range from $ $5.00 PEPM and are based on expected incidences of FMLA claims Aetna Fully Insured STD or ASO STD with an insured line FMLA ADA - Additional Fee Standalone Concierge Cigna 250+ STD FMLA ADA Included in Fee Hartford 200+ One insured line of coverage FMLA ADA Additional Fee Liberty Mutual 100+ One insured line of coverage FMLA ADA Additional Fee MetLife 500+ STD FMLA ADA Included in Fee Reliance Standard ASO or Fully Insured STD/LTD FMLA ADA Included in Fee Unum 100+ Fully Insured STD or LTD FMLA ADA Additional Fee (2,000+) Standalone Concierge late

61 Understand What You Are Buying Important to understand the details How do they account for FMLA history in takeover? Important for history and take over of intermittent leaves What liability do they take for their administrative issues? What clinical resources are available for leave purposes? How proactively is state leave law tracked and managed? Will you have a dedicated leave management team? What are process steps to identify abuse? What training do they provide to staff? Managers? What is the intake process and how are all leaves managed? How do they address union rules? (carve-out union decisions) Understand lead time and termination notice requirements Understand all potential fees 60

62 Summary Insights Carriers are enhancing service models all the time Some offer training, job description support, etc. Understand their expertise Some carriers have built in-house capabilities Other carriers outsource or share common ownership with absence management specialty venders Costs are coming down and services are improving If you haven t gotten a quote recently, might make sense to check out in the next year Ask detailed questions understand your responsibilities, the carrier s responsibilities and the process 61

63 STAND ALONE OPTIONS

64 Stand Alone Options Creates a separate process from STD Handful of stand alone vendors offer leave of absence management services ADP (purchased SHPS several years back) ComPsych Basic Discovery Benefits Sedgwick Matrix Reed Group Specialty TPAs that specialize in absence management Specialty vendors work only with very large groups (1,000+) 63

65 LEVERAGING SOFTWARE SOLUTIONS

66 Software Solutions Software solutions used to be limited As the LOA process became more challenging, the software options have improved Software solutions help organize process and provide resources employer still manages LOA process Source: 2013 Survey on Absence and Disability Management, Mercer 65

67 Scope of Services Vary by Solution Tracking types of leaves common FMLA administrative functions also common Some solutions allow input for union rules, corporate absence policies and will assist in determining leave types Some solutions will automatically generate FMLA forms when needed and include library of other communications Different LOA software solutions offer different reporting functions make sure reporting meets your needs Some solutions offer access to state/city laws answering series of questions will direct you to laws that apply 66

68 Array of Options You still might be limited by group size Some specialty TPAs lease their software/ad hoc services The Reed Group offers Leavepro provides leave management and tracking MD Guidelines provides general guidelines related to specific disabilities provides ammunition when leave request is excessive Leave Advisor online database/resource of leave laws (Federal, State and City) Clinical consultant access per case fee Some software targets mid to small group markets AbsenceSoft cost effective, robust tracking, leave management software 67

69 Affordable with Real Capabilities AbsenceSoft Software option provides FMLA and all State Leave Laws administration Concurrently tracks company policies Provides real-time calculation of time used and time remaining Automates workflow, tasks and reminders Stores all correspondence and documentation electronically Easy entry and upload of employee data ADA tracking interactive process/ada accommodation option Cost is attractive Under 1,000 lives - $299/month unlimited users 1,000 3,000 lives - $599/month unlimited users Implementation fee may apply (self-implementation free) scalable Buy up option medical guideline access 68

70 Summary Insights Can save money by instituting a tightly managed process addressing abuse Access to experts for complicated labyrinth of rules Understand the process the outsourcer takes in managing all aspects of leave process Expect at least 120 days for implementation Ask about reporting and communication regarding leaves in process, expected return dates, etc. Be prepared transition to outsourcing or changing vendors can be rocky for the first few months 69

71 SUMMARY THOUGHTS

72 Summary Thoughts Leave of absence management is highly technical and complex Most employers are not completely confident in their leave of absence management process Outsourcing options and software solutions have improved over the years and costs are varied If you need to keep LOA management in house, make sure to review and improve the processes. If process is not centralized, there are likely inconsistencies in play DOL audits are on the rise and employers need to be prepared 71

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