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CT Paid Leave Authority committee advances revisions to private plan audit guide, aims to increase audits
Summary
The committee reviewed proposed edits to the private plan audit guide that would tighten documentation requirements, add meetings with claims administrators and draft‑report reviews, and set a target to ramp private plan audits to 20–25 annually; the changes will be sent to the full board for public notice.
The CT Paid Leave Authority committee on Tuesday reviewed recommended revisions to its private plan audit guide that staff say will strengthen documentation checks and improve audit communication with employers. Michael, the staff presenter leading the audit work, outlined the changes and said the agency plans to send the edits to the full board for public notice and comment next week.
Michael summarized the agency’s four audit types — application audits (reviewing the employee vote and application process), contribution audits (tracking paycheck deductions and use of funds), claims audits (reviewing claim handling and sample files) and financial solvency audits (assessing reserves for self‑insured plans). "Private plan numbers are growing," Michael said, noting six private plan audits in 2023 and 18 scheduled in 2025 (two not yet launched). He said staff aim for 20–25 audits a year to cover roughly 23% of private plans annually.
The recommended guide edits fall into style, process and substantive categories. Style changes include consistent formatting, clearer yes/no checklist boxes instead of ambiguous "x" marks, and streamlined timelines. Process changes add meetings — staff will hold a claims‑administrator meeting before requesting claim files and a draft‑report meeting with employers to discuss findings before issuing a final report — and remove a free‑form notes section that proved less useful in practice.
Substantive changes proposed would require employers to provide proof that policy or plan documents and the statutorily required annual notice were distributed to employees, and would verify that information provided before an employee vote was accurate and not misleading. Michael said the agency will tighten survey wording to improve response rates, move review of approved claims into claims audits rather than contribution audits, accept publicly available shareholder reports as one form of solvency evidence for financial audits, and check that employer account contacts are correct.
In question-and-answer, Michael characterized audit results as "mostly compliant" but identified recurring issues. He said some employers misunderstand the requirement that employee votes be anonymous, explaining that "it is not anonymous to have the person who decides whether someone's hired or fired seeing the results." He described lax tracking of employee contribution funds, denial letters that sometimes omit a claimant’s right to appeal or request reconsideration with the Department of Labor, and technical claim‑calculation issues such as rounding or use of earnings periods not aligned with plan documents.
Michael said staff learned from audits that not every error fits a preexisting category of systemic or procedural deviation, so the guide will stop forcing that classification in every case. He told the committee that, after the committee’s review, staff expect to take the edits to the full board to post for public notice and comment.
The committee did not vote on the guide at the meeting; Michael said the next procedural step is posting the draft to the full board for public notice.
