Administration and compliance responsibilities

A proposed responsibility map

This matrix is a planning framework. Actual responsibilities depend on the employer’s plan, applicable law, and signed service agreements. It does not describe an appointed Montridge administrator.

Documentation and disclosures

Determine whether ERISA applies and what written plan materials, summary disclosures, claims procedures, and notices are needed. The treatment of an employee’s individual policy is distinct from the employer-sponsored HRA. Do not assume that individual insurance means there is no employer plan to administer.

Substantiation and payment controls

The arrangement needs reasonable procedures for annual coverage verification and confirmation of coverage for the month an expense was incurred. Reimburse only eligible, substantiated expenses under the plan. Assign reconciliation, exception handling, and access controls to specific responsible parties.

Continuation, fees, and reporting

Assess COBRA applicability rather than assuming all employers have the same duties. Review PCORI fees for the applicable self-insured arrangement and the correct filing process. Determine coverage reporting and, for ALEs, employer offer reporting obligations using current instructions.

Security and employee support

Sensitive employee data belongs in an approved process with appropriate safeguards and access restrictions. An ordinary inquiry form is not a census-upload system. Clarify where employees obtain help, how disputes are escalated, and how records are retained and transferred.

Questions before signing

• Which tasks are included, excluded, or billed separately?
• Who files and who remains responsible for accuracy?
• What happens when an employee moves, loses coverage, or leaves?
• How are errors corrected and deadlines monitored?
• What records can the employer export at termination?