December 5, 2008
TO:
State Health Benefits Program and School Employees’ Health
Benefits Program Participating Employers
FROM:
Florence J. Sheppard
Deputy Director, Benefit Operations
SUBJECT:
Dependent Eligibility Verification Audit
Chapter 89, P.L. 2008, mandated that the State Health Benefits Program (SHBP)
and School Employees’ Health Benefits Program (SEHBP) “shall conduct a
continuous review of the various public employers participating in the State
Health Benefits Program for the purpose of ensuring that only eligible employees
and retirees, and their dependents, are receiving health care coverage under the
program.” Furthermore, under this Act, any person who knowingly enrolls, or
attempts to enroll, individuals that they know are ineligible are guilty of a crime
and subject to prosecution. Accordingly, the SHBP/SEHBP will be performing an
audit to verify the eligibility of dependents participating in both programs.
The SHBP/SEHBP has retained Aon Consulting to perform a Dependent
Eligibility Verification Audit (DEVA). Each employee/retiree who covers a
dependent under their health plan will receive a letter from Aon with specific
instructions. They will have until a specified date to furnish Aon with the required
legal documentation confirming that their dependents are eligible for coverage
under the programs.
Since ineligible dependents are one reason health care costs are increasing, this
audit is a way to verify that those listed as dependents in the Programs meet the
definition of “dependent” as described in N.J.A.C. 17:9-3.1.
Providing ineligible dependents with health coverage is not always intentional on
the part of the employee/retiree. For this reason, as part of the DEVA, the
SHBP/SEHBP is allowing an amnesty period during which employees/retirees
will have the opportunity to voluntarily identify any ineligible dependents and
therefore avoid any penalties or other legal action. After the close of the amnesty
New Jersey Is An Equal Opportunity Employer
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Printed on Recycled and Recyclable Paper
Dependent Eligibility Verification Audit
December 5, 2008
Page 2
period, there will be legal consequences as outlined under Chapter 89, P.L. 2008
for employees/retirees who are found to have knowingly enrolled, or attempted to
enroll ineligible dependents under the programs.
The DEVA will be conducted in phases with State employees and retirees being
audited beginning in January 2009. School employees and retirees will follow in
mid-2009 and local government employees and retirees starting in late 2009.
You as an employer have no responsibilities in connection with the DEVA.
However, in order to maintain the integrity of the DEVA, any health benefit
application submitted on or after January 1, 2009 from an existing or new
employee adding a dependent for coverage will be rejected by the Division
of Pensions and Benefits unless proper legal documentation is submitted
confirming the dependents relationship to the employee.
The attached chart outlines the necessary documentation required to be
submitted with the health benefit application for each classification of dependent.
We appreciate your cooperation in contributing to the SHBP/SEHBP’s efforts to
continue to provide quality healthcare at a reasonable cost.
Enclosure
Revised Documentation Chart - May 2009
Required Documentation for SHBP/SEHBP Dependent Eligibility Verification Audit (DEVA)
Dependents
Eligibility Definition
Documentation Required
Spouse
A member of the opposite sex to whom you are legally
married.
¾
¾
Photocopy of marriage certificate and
A copy of the top half of the front page of the employees’ most
recently filed federal tax return that includes your spouse (you may
black out all financial information and all but the last 4 digits of your
social security number).
Civil Union Partner
A person of the same sex with whom you have entered
into a civil union.
¾
Photocopy of the New Jersey Civil Union Certificate or a valid
certification from another jurisdiction that recognizes same-sex civil
unions and
A copy of the top half of the front page of the employee’s most recently
filed NJ tax return that includes your partner (you may black out all
financial information and all but the last 4 digits of your social security
number) or
A copy of a recent (within 90 days of application) bank statement or
bill that includes both partner’s names received at the same address.
¾
¾
Domestic Partner (DP)
A person of the same sex with whom you have entered
into a domestic partnership as defined under Chapter
246, P.L. 2003, the Domestic Partnership Act. The
domestic partner of any State employee, State retiree,
or any eligible employee or retiree of a SHBP/SEHBP
participating local public entity, who adopts a
resolution to provide Chapter 246 health benefits, is
eligible for coverage.
¾
¾
¾
Children
Refers to your unmarried children under age 23 who:
¾ Live with you in a regular parent-child
relationship;
¾ Are away at school; or
¾ Are divorced children living at home provided that
they are dependent upon you for support and
maintenance
If you are a single parent, divorced, or legally
separated, your children who do not live with you are
eligible if you are legally required to support those
children. Stepchildren, foster children, legally adopted
children, and children in a guardian-ward relationship
are also eligible provided they live with you, are under
the age of 23 and are substantially dependent upon
you for support and maintenance.
¾
¾
¾
Photocopy of the New Jersey Certificate of Domestic Partnership
dated prior to February 19, 2007 or a valid certification from another
State of foreign jurisdiction that recognizes same-sex domestic
partners and
A copy of the top half of the front page of the employee’s most recently
filed NJ tax return that includes your partner (you may black out all
financial information and all but the last 4 digits of your social security
number) or
A copy of a recent (within 90 days of application) bank statement or
bill that includes both partner’s names received at the same address.
Natural Child – Photocopy of birth certificate showing employee’s
name.
Step Child – Photocopy of birth certificate showing employee’s
spouse/partner’s name; and a copy of marriage/partnership certificate
showing the employee and parent’s name
Legal Guardian, Adoption, Grandchild(ren), or Foster Child(ren)
– Photocopy of Affidavits of Dependency, Final Court Order with
presiding judge’s signature and seal, or Adoption Final Decree with
presiding judge’s signature and seal.
May 2009
Revised Documentation Chart - May 2009
Required Documentation for SHBP/SEHBP Dependent Eligibility Verification Audit (DEVA)
Dependents
Dependent Children
with Disabilities
Continued Coverage
for Over Age Children
Eligibility Definition
If a covered child is not capable of self-support when he
or she reaches age 23 due to mental illness or incapacity,
or a physical disability, the child may be eligible for a
continuance of coverage. Coverage for children with
disabilities may continue only while (1) you are covered
through the SHBP/SEHBP, and (2) the child continues to
be disabled, and (3) the child is unmarried or does not
enter into a civil union or domestic partnership, and (4) the
child remains substantially dependent on you for support
and maintenance. You will be contacted periodically to
verify that the child remains eligible for continued
coverage.
Certain dependent children may be eligible for continued
coverage under the provisions of Chapter 375, P.L. 2005.
This includes a child by blood or law who:
¾ is under the age of 31;
¾ is unmarried or not a partner in a civil union or
domestic partnership;
¾ has no dependent(s) of his or her own;
¾ is a resident of New Jersey or is a student at an
accredited public or private institution of higher
education, with at least 15 credit hours; and
¾ is not provided coverage as a subscriber,
insured, enrollee, or covered person under a
group or individual health benefits plan, group
health plan, church plan, or health benefits plan,
or entitled to benefits under Medicare.
Documentation Required
¾
¾
¾
¾
¾
¾
¾
¾
Documentation as noted for the “Child” dependent type
A copy of the top half of the front page of the employee’s most recently
filed federal tax return that includes this child (you may black out all
financial information and all but the last 4 digits of your social security
number)
If a Social Security disability award has been awarded, or is currently
pending, please include this information in the documentation
submitted
Please note that this audit is only verifying the child’s eligibility as a
dependent. Your health carrier determines the disability status of
the child.
Documentation as noted for the “Child” dependent type
A copy of the top half of the front page of the employee’s most
recently filed federal tax return that includes this child (you may black
out all financial information and all but the last 4 digits of your social
security number) or
If the overage child is not listed on the employee’s tax return, a copy
of the top half of the child’s most recently filed tax return is required
(you may black out all financial information and all but the last 4 digits
of your social security number) and
If the child resides out of the State of New Jersey, documentation of
full time student status must be received.
If you need to obtain copies of the necessary documentation listed above, you may contact the office of the Town Clerk
in the city of birth, marriage, etc., or visit these Web sites: www.vitalrec.com or www.studentclearinghouse.org
Residents of New Jersey also have the option of obtaining records from the State Bureau of Vital Statistics and Registration Web site:
www.state.nj.us/health/vital/index.shtml
May 2009