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The Crosby Method 

Our methodology is unified and reiterative, making every part equally as crucial. Since each part is connected, each contributes to a solution that works now and adapts to your future needs.

Engage
Above all, we engage our clients. For us, engagement is not a state of being; it is action, an ongoing exchange of ideas that promotes trust and creativity. Throughout our engagement with you, we take time and make an effort to evaluate your current circumstances in addition to the direction of your benefits program and its relation to your broader business goals. To determine how your program fits with your organizational goals, we meet with your executives and when appropriate, with your board. We can facilitate focus groups in order to learn your employees’ attitudes toward your current program and their expectations for improvement. 
 
 

Develop
At this stage, we combine what we’ve learned about your organization and your benefits program with a) your short and long-range benefits objectives, and b) our knowledge of all aspects of health and welfare benefits management, including both brokerage and administration. This assures that our solution will fit your organization and at the same time, take into consideration the most recent innovations and likely trends in the benefits industry, including new regulations, legislation and technologies. 
 
 

Generate
Here is where our solution is implemented. A design is only effective if it translates into a working component that meshes with the rest of your program. We do everything necessary to make certain that both managers and recipients are prepared for any changes. This includes a timeline, which allows for full communications to all parties, clear educational materials and presentations to your employees, and whatever other support and coordination you may need for enrollment and compliance.
 
 

Crosby's commitment is not temporary: we continue to be available whenever you need our support.

June 2007 
Welcome to the Crosby Benefit Systems Newsletter 
 
As summer approaches and things begin to heat up, please take a few minutes to review our newsletter to see a sampling of some of the exciting developments going on both at Crosby and in the benefits industry. As we are committed to developing and improving our company, your input is critical to our continued success. 

Do You Need to Set Up a Second Section 125 Plan For Currently Ineligible Employees?  

Mass Health Reform is moving right along. Some feel The Mass Health Connector’s implementation is going smoothly and as expected. Others are concerned about all the outstanding technical and logistical questions.

What we know is that barring a last minute change, all employers in Massachusetts with 11 or more employees are required to have a Section 125 plan in place effective July 1, 2007. Employers who meet the Section 125 requirements are exempt from the Free Rider Surcharge.

For those employers that currently have a plan in place, we are now recommending that you establish a second Section 125 Plan (with a Plan Document) for employees who are currently benefits ineligible. The Mass Health Connector makes available a model plan document which is specifically suited for this purpose. This will allow you to establish a new plan as of July 1, 2007 for only those employees that are currently not covered by an existing Section 125 Plan and therefore satisfy the requirement.

While employers who choose to amend their current Plan Document to open up eligibility for currently ineligible employees would still be meeting the requirement, creating a separate plan provides a clear separation of the two groups and allows for more flexibility around when you want the Plan Year to start.

At a later date (unless the rule is changed) a copy of your Plan Document(s) must be submitted to The Mass Health Connector. The Mass Health Connector is still working out the logistics for this and employers should simply hold a copy on file until more information is available.

It is important to note that Mass Health Reform does not require employers to offer Reimbursement Accounts for all employees, just the ability to have health insurance premiums deducted on a pre-tax basis.

While we at Crosby are available to answer questions about Section 125 plans and plan documents, we recommend you take advantage of The Mass Health Connector’s website. The Section 125 area of the website (which also includes a fully downloadable guide) provides comprehensive information about Section 125 plans as they relate to Mass Health Reform. As part of the downloadable guide, a model plan document is also available. Alternatively, Crosby can work with you to create a document customized for your organization for a fee.

For questions or more information, please contact Max Crosby.

Did you Know?

Beginning on June 1st, all debit cards issued for use with reimbursement accounts have a new color and our Crosby logo. The new, blue cards (existing cards are maroon) will feature our "Crosby, Benefits People" logo in the top left corner. As we've mentioned before, debit cards are becoming an increasingly useful tool for consumer directed health plans with HSA and HRA components. The card allows for "one stop swiping" as it can draw from an FSA, HRA and HSA - in whatever order your plan dictates. To learn more about how the Flex Debit Card can help your organization, please contact your Crosby consultant. 
 

SBANE Innovation Awards

The Smaller Business Association of New England (SBANE) recognizes that innovation is at the heart of economic prosperity. Each year it seeks to single out those companies that have transformed their innovative ideas into a company, product or service that delivers value to customers. Crosby was proud to sponsor this year's awards and to participate in the judging process, winnowing down the 179 nominees into the list below of the final seven SBANE Award winners. Congratulations to:
 

  • Acumentrics 
  • Ahura Scientific, Inc. 
  • Eliza Corporation 
  • LogMeIn, Inc. 
  • NeuroLogica Corporation 
  • SupplyScape Corporation 
  • Volicon, Inc. 

If you would like to have your organization nominated or would like to nominate someone else for next year's Innovation Award, please contact Jean Sicurella and she will contact you during the next nomination cycle in February of 2008. 

The Flex Debit Card: The Good, The Bad and The Ugly

The Flex Debit Card is a great way to increase value for your participants' Flexible Spending Account (FSA). It is an added convenience that helps participants get direct access to their Medical FSA funds. The IRS requires all Flex Debit Card purchases to be substantiated, either electronically or via paper receipts. 

To ensure that your employees' Debit Card experience is a positive one, it is important that all possible electronic adjudication methods are implemented and that your communications timing is appropriate for the card rollout and your particular population.

The Good: In most cases, participants will not be asked to submit receipts for these transactions*: 
 

  • Office visit co-payments for your group health plan  
  • Prescription drugs approved by your group health plan  
  • Eligible items purchased at Walgreens, Wal-Mart, Sam’s Club, Longs Drugs, VisionDirect.com and Drugstore.com  
  • Recurring expenses; if you substantiate it once, you will not need to substantiate it again  

*Please Note: Substantiation may still be required if a vendor's card machine has not been setup with a correct merchant code. Also, at times, Crosby may need to obtain an employee's updated health plan information if the participant has had a plan change.   

The Bad: Participants will be required to send in receipts to substantiate these transactions:  

  • Over-the-counter drugs NOT purchased at Walgreens, Wal-Mart, Sam’s Club, Longs Drugs, VisionDirect.com or Drugstore.com  
  • Office visit payments not matching the flat co-payment  
  • Transactions at a dentist's office  
  • Optometry expenses  
  • Medical equipment  

The Ugly: If participants do not substantiate these expenses, here is what they can expect:  

  • Two requests for substantiation via email or USPS
  • If the requests are not satisfied within 30 days of the transaction, the transaction will be deemed ineligible
  • The card will be temporarily deactivated
  • The participant will need to send in a check to refund the plan for ineligible transactions

For more information, please contact your Crosby consultant or the Service Center at 800-462-2235.

More on the Flex Debit Card. . . 
 
There are some big changes taking place for Flex Debit Card users beginning in early 2008. During the last year, many retailers, including Walgreens and Wal-Mart, have implemented Inventory Information Approval Systems (IIAS) after the IRS ruled in July 2006 that these systems are an acceptable form of adjudication. IIAS systems determine whether an item is FSA eligible at the time of purchase. IIAS systems must adhered to these rules:  
  • Substantiation of transactions must take place at time of card authorization
  • Non-213(d) eligible items may not be authorized
  • Transactions are subject to recordkeeping requirements

These systems rely on tags which correlate to Merchant Category Codes (or MCCs). Then, eligible items swiped at check-out counters are approved. All non-eligible items must be purchased using an alternative form of payment

This past January, IRS Notice 2007-02 was released offering transition relief and requiring that all supermarkets, grocery stores, discount stores, wholesale clubs, mail order vendors and web-based merchants offering health care related products implement an IIAS system by January 1, 2008. If these types of retailers do not comply by January 1, 2008, they are not allowed to accept Flex Debit Cards. 

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