25. 03-24-14 EMP BEN ESTABLISH TWO ADMIN ACCTS UHG AGENDA SUPPORT.PDF
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Maricopa County Department of Employee Benefits and Health 301 West Jefferson, Suite 3200 TO: Administrative Bank Account Committee: Phoenix, AZ 85003-2143 Phone: 602 506-1771 Sandi Wilson, Deputy County Manager www.maricopa.gov Royce Flora, Chief Deputy Treasurer Shelby Scharbach, Assistant County Manager & CFO Charles "Hos" Hoskins, Treasurer FROM: Dave Hansen, Employee Benefits Finance Manager DATE: March 17, 2014 SUBJECT: Request to Establish two Administrative Bank Accounts This memo and application package is to request the establishment of two Administrative Bank Accounts (Accounts) for processing electronic payments to the new health care provider, United Healthcare Group, for two of the County's medical plans. The Accounts will be consistent and in compliance with the County's Establishing Administrative Bank Accounts Policy (A2504), legal, operating, reporting, and internal control requirements. The Accounts will be established at the County's servicing bank JP Morgan Chase branch located at 201 N Central Avenue — 21 st Fl., Phoenix, AZ 85004. Electronic access to the Accounts will be granted to the Employee Benefits Finance Department, Treasurer's Office and Department of Finance. The Department of Finance will work with Employee Benefits Finance Department to ensure proper cash handling procedures are used to manage the bank account. Please refer to the attached forms for additional Account information. Attachments c: Chris Bradley, Director — Department of Employee Benefits and Health Description of why and Administrative Bank Account is needed for servicing United Health Group Health Savings Account Contributions: Maricopa County's High Deductible Health Plan requires that Health Savings Account Bank Accounts be set up for each employee subscriber. An administrative bank account needs to be set up by Maricopa County to facilitate reverse ACH Transfers to Optum Bank for crediting Employee's Health Savings Bank Accounts at Optum Bank. There will be an initial funding to all employee accounts prior to 7/1/14 and funding every pay period thereafter. Optum Bank is a subsidiary of United Health Group. This Account will be owned by Maricopa County and is expected to have a $200,000 to $300,000 balance on average. This Bank Account will be funded via ACH transfers from Maricopa County. There are two alternative solutions, but both would require doing wire transfers from the Treasurer's Servicing Bank Account on the day of funding at a cost of $8.00 per transfer. Neither of these options is recommended by United Health Group. This request along with the other request is for two separate accounts which would be accessible by UHG. It would be possible to have the two functions 1) Claims Processing and 2) Health Savings Account funding flow through the same outside bank account. This is not recommended because Health Savings Account funding is highly predicable and thus requires lower excess balances than claims processing. The risk of not being able to fund employees H S A bank accounts when scheduled could potentially create many problems for employees. This would more likely occur if unpredictable claims were higher than anticipated. It is also not recommended to have two vendors with rights to pull funds from the same bank account. If questionable transactions hit the bank account, it would be more difficult to resolve if two vendors were involved. The cost of this bank account will be lost interest income which at a rate of 1% would be about $2,500 per year. Employees A S H Bank Accounts JPMorgan Employees H A S Bank Accounts Bank Optum accounts At accounts At 1,700 Online exceptions County. 7/1/2014 exceptions the accts. employee submitted for pulls A S the to effective to for 7/1/2014 Bank online Cigna H Cigna. back to Bank 6/30/2014 Morgan deposits money contributon money while employee within money Process JP transfers effective Optum for to funds revert Optum through at initiates at account transfers account funds client can allow UHG Accounts Cigna Manually Process Accounts Manually Bank transfer different Cigna to and the and Process to FTPd Finance - auto-debit's to and of only County; Savings file Savings Finance Administrative County balance. 6/30/2014 Current Benefits Contributions Bank commingling deposited, Maricopa - Health Reserve Owned OKH0039a Health Account** A S H Account Chase Optum Benefits County Maricopa are from $300,000 through to Cigna Maricopa County Account 397011434081 Cigna to Maricopa County Sweep (New) Morgan Maricopa from avoid to monies transfers to Contributions Accounts **New P J a cash name once Bank. $200,000 HSAs Deposits Deposits from Morgan. of as ACH Optum a of Savings JP transfers County's Account receive at have to funding Accounts County's Week Health County's Week contributions at Account ACH Maricopa (New). to Account expected a Once of a Once A S maintained hold in Reserve Account County Bank is Cigna Savings Maricopa Funded Maricopa Funded H the account Bank Account to maintained the of Sweep Maricopa Employee's and Current Health pay Funding pay pull will Cigna Servicing disbursements Cigna by but control A S by to County of to Fr'? - to UHG a Treasurer's for Reserve controlled Cigna full have H controlled money Maricopa the Cash Group Cash that from County by not County by of Funding of County Health of County is Contributions County Account and up owned does Maricopa and up transfer owned Comparison - Movement Treasurer's Servicing Bank Account Movement Treasurer's Servicing Bank Account difference Bank Cigna/Maricopa set is County - set ACH is CIGNA Maricopa United Maricopa Main A S Maricopa Central Account Account The UHG Account reverse Account H Maricopa County Title: Establishing Number: A2504 Internal Policy Administrative Bank Issue Date: May 2000 Accounts Policy Category: Finance Initiating Department: Revision No: 2 Department of Finance Revision Date: June 20, 2012 Attachment A REQUEST FOR ADMINISTRATIVE BANK ACCOUNT Department Name Employee Benefits Low Org # 3950 Date 3/19/2014 Account Contact Name Dave Hansen Phone Number 506-2828 Description of why an Administrative Bank Account is needed: A new bank account is required for the funding process of the High Deductible Health Plan (H S A). Our cut tent bank account for ttils process Is owned by Cigna not by the County. Cigna will no longer administer the H S A medical plan effective July 1, 2014. Type of Administrative Bank Account being requested (based on the definitions in Section II.A) and reason the account type is needed: Third-Party Administrative Processing Account — to facilitate the process of funding Employees' H S A accounts Name of Maricopa County/Special District Employees to be authorized signers (minimum of 2 required): Chris Bradley and Dave Hansen Name of Maricopa County/Special District Employee to act as Custodian: Lisa Tso Type of Account Requested: Anticipated Account Activity: Checking Account x Number of Deposits per Month 4 Savings Account Average Monthly Deposit $ 480,000. Investment Account Number of Withdrawals/Checks per Month 8 Interest Bearing (Y/N) Average Monthly Withdrawals/Checks $ 480,000. Explanation of Source of Funds (e.g., fines, fees, charges for services, bonds, restitution/wards/inmates/probationers monies held in trust, etc.): Employee and Employer Health Savings Account Contributions held in Trust Fund. 8 Maricopa County Title: Establishing Number: A2504 Internal Policy Administrative Bank Issue Date: May 2000 Accounts Policy Category: Finance Initiating Department: Revision No: 2 • _Department of Finance Revision Date: June 20, 2012 , For Department of Finance Use Only Financial reporting of deposits & investments held in Administrative Bank Account Fund classification: Special Revenue[ ] Debt Service[ ] Capital Project[ ] Enterprisel ] Internal Service[ ] Agency[ ] Advantage Fund Number (N/A for Agency Funds) Balance Sheet Account 0006/0013 (N/A for Agency Funds) See attached Memo for additional information. REQUIRED APPROVALS Depart ant or 0 a App val Appointing Authority Approval Date Completed by County Manager (or signees) , /2451/ County Manager Approval Date 3 Completed County Treasur T / . / County Treasurer Approv '71,4-1. - Date Completed by Clerk of the Board of Supervisors/Board of Directors Date of Board of Supervisors/Directors Approval Agenda # 9 Description of why and Administrative Bank Account is needed for servicing United Health Group Claims payments: Employee Benefit's Contract with United Health Group (UHG) requires the County to pay UHG the same day that the PPO and HDHP (High Deductible Health Plan) medical claims processed by UHG clear the UHG claim processing bank account. Failure to comply gives UHG the option of terminating the benefits administration contract. The first and preferred funding process for claims paid would involve the UHG claim processing bank account pulling funds from the UHG Direct Deposit Account in Maricopa's name, which would then pull funds from Maricopa County's Administrative Bank account. These transactions would be facilitated via reverse ACH. There would be no Imprest bank account required, however the Employee Benefits staff would need to insure that enough funds were maintained in the administrative bank account based on expected future activity. An alternative process is available which would not require an administrative bank account but an Imprest bank account would be maintained by UHG. This process would involve wiring money from the Treasurer's Servicing Bank Account to the UHG demand deposit account on a weekly basis based upon a calculated lmprest amount based on 7 days claims payments. The imprest amount is estimated to be $1,500,000 to $1,800,000. This is not desirable because it would essentially transfer a large amount of cash on a prepayment basis to UHG. The transfer could be done ACH with a 48 hour turnaround time. This request along with the other request is for two separate accounts which would be accessible by UHG. It would be possible to have the two functions 1) Claims Processing and 2) Health Savings Account funding flow through the same outside bank account. This is not recommended because Health Savings Account funding is highly predicable and thus requires lower excess balances than claims processing. The risk of not being able to fund employees H S A bank accounts when scheduled could potentially create many problems for employees. This would more likely occur if unpredictable claims were higher than anticipated. It is also not recommended to have two vendors with rights to pull funds from the same bank account. If questionable transactions hit the bank account, it would be more difficult to resolve if two vendors were involved. The first alternative above would involve maintaining an average of $400,000 in a Maricopa County administrative bank account. At an interest rate of 1% per year, this would cost the County $4,000 in interest annually. Furthermore, this would require the County to allow UHG to open a UHG Direct Deposit Account (i.e., a separate bank account) controlled by UHG, but in Maricopa County's name and EIN, to avoid commingling of different client funds within UHG. The second alternative of wiring money from the Treasurer's Servicing Bank Account to an UHG Imprest account would involve turning approximately $1,650,000 over to UHG in advance of claims being paid. At an interest rate of 1% per year, this would cost the County $16,500 in loss of interest annually. Current Process for all Medical Claims. Process and Accounts will remain the same for the HMO Plan CIGNA -Funding of Claims Process using Maricopa County's Imprest Account Movement of Cash to pay Maricopa County Self-Insured Medical Claims to Cigna Accounts (Cigna maintains control of our cash with this process) Maricopa Account A Cigna Account in County's name Maricopa County Maricopa County Cigna Cigna Medical Treasurer's Benefits Catalyst Maricopa County Providers Servicing Imprest Sweep Bank Account Benefit Plan Bank Bank (Medical) Agent Bank Account Account Account #475732626 #601849573 Chase#982585648 (Med-California) #475732960 Funded Once a Daily Sweeps by Daily Sweeps by Normally Week 2:00:00 PM EST 2:00:00 PM EST Weekly Maricopa County Treasurer's Servicing Bank Account Central Bank Account for disbursements Maricopa County Benefits Imprest Sweep Bank Account Imprest to approximately $2,600,000, Owned by the County, but allows Cigna the rights to sweep the account for payment of Claims However, effective 7/1/2014 the Imprest amount will drop to approximately $1,300,000 as it will cover only HMO claims Cigna Catalyst Bank Account (Medical) #475732626. #47573296 (Subject to Qualified Public Depository guidelines for municipal accounts) Account set up and controlled by Cigna to receive either Wire Transfers or sweeps of cash from Maricopa County to reimburse paid claims This account is not a stand alone account but rather a sub-account of Cigna's catalyst omnibus account. Accounts are maintained in clients' names (Maricopa County) in order to not comingle claims paying funds. Cigna Maricopa County Benefit Plan Agent Bank Account #601849573 Account set up and controlled by Cigna to pay Maricopa Medical claims and to receive sweeps from "Catalyst Bank Account" FY14 New Process-United Health Group (UHG) -Funding of Claims Process using Maricopa County's Imprest Account Movement of Cash to pay Maricopa County Self-Insured Medical Claims to United Health Care (Maricopa County retains control of our cash with this process) Maricopa Account UHG Account in County's name **New Account** **New Account** Maricopa County RA C.•.-),^*I7/ UHG UHG Medical Treasurer's Demand Deposit common zero Providers Servicing IIII Api Bank Account balance check Bank (DDA) writing Account Account Account At Bankof America 1)ACH Wire used by Benefits Staff to fund this Weekly 3) 2 AM ACH sweeps to cover cleared checks Daily 2)Daily Reverse sweeps to cover 2 am nightly sweeps to zero balance account Maricopa County Treasurer's Servicing Bank Account Central Bank Account for disbursements Maricopa County Benefits Sweep Bank Account "Pro Forma" Imprest to about $1,500,000, Owned by the County, but allows Uh6 the rights to sweep the account for payment of Claims UHG/ Demand Deposit Account (Subject to Qualified Public Depository guidelines for municipal accounts) Account set up and controlled by UHG to receive reverse ACH sweeps of cash from Maricopa County to reimburse paid claims Account is owned by UHG but maintained in Maricopa County's name and EIN to avoid commingling of different client funds within UHG. The County does not have full control of this account as once monies are deposited, only UHG can revert back to the County. Account is similar to Cigna's Catalyst Bank Account. UHG common zero balance check writing Bank Account Account set up and controlled by UHG to pay Maricopa Medical claims and to receive sweeps from UHG DDA. Alternatives 1) Daily sweeps from Maricopa's Administrative Bank Account to UHG DDA. This method keeps the maximum amount of cash in Maricopa's Possession. There would be essentially a one day's worth of claims in this account on a daily basis which are cleared to zero with the 2 AM ACH sweep. This process is depicted above. 2) Weekly sweeps from Maricopa Administrative Bank Account to UHG DDA. This would require a 6 day imprest amount in the UHG Account to be topped off weekly. This is essentially what we are doing now and is probably the worst choice for Maricopa as an administrative bank account is still required and the vendor is in control of a large amount of cash. 3) Direct Funding into UHG Account from Treasurer's Servicing Account. Would require 7 day imprest balance of approximately $1,500,000-$1,800,000to account for 48 hour ACH lag. Maricopa would receive a request for Funding on Monday morning to be ACH'ed on Wednesday, thus causing a larger imprest amount. Recommendation The recommended option is option #1 above as it provides UHG with the smallest amount of free cash. The disadvantage of options 2) and 3) is that an imprest cash amount is maintained with UHG, but the advantage of this option is that UHG Is OK with that account going periodically into a deficit position (due to the nature of an imprest system.) Claim Patterns Spikes in daily claims activity will be caused by 1) Pharmacy claims clearing twice a month; 2) Large claims; 3) Large providers within alphabet Grouping as claims are paid daily using the first letter of the alphabet to group payments. Maricopa County Title: Establishing Number: A2504 Internal Policy Administrative Bank Issue Date: May 2000 Accounts Policy Category: Finance Initiating Department: Revision No: 2 Department of Finance Revision Date: June 20, 2012 Attachment A REQUEST FOR ADMINISTRATIVE BANK ACCOUNT Department Name Employee Benefits Low Org # 3950 Date 3/19/2014 Account Contact Name Dave Hansen Phone Number 506-2828 Description of why an Administrative Bank Account is needed: A .,,, new ,. bank „ account is requested , , due . to , , United ,.,.,. HealthCare , being added for . the County's PPO and HDHP ivieuiLdi plans. We would ince like LU dVOIU LINU miler ern. vend ors horn cu..Lessing the same ti dnik du..uunit to proccss daily sweeps to pay Medical claims. Type of Administrative Bank Account being requested (based on the definitions in Section II.A) and reason the account type is needed: Third-Party Administrative Processing Account —this bank account will be used to facilitate the processing of ddily sweeps to the U nited HedlUiLdie deuldild deposit du..oupl Name of Maricopa County/Special District Employees to be authorized signers (minimum of 2 required): Chris Bradley and Dave Hansen Name of Maricopa County/Special District Employee to act as Custodian: Lisa Tso Type of Account Requested: Anticipated Account Activity: Checking Account x Number of Deposits per Month 4 Savings Account Average Monthly Deposit $ 4,500,000. Investment Account Number of Withdrawals/Checks per Month 22 Interest Bearing (YIN) Average Monthly Withdrawals/Checks $ 4,500,000. Explanation of Source of Funds (e.g., fines, fees, charges for services, bonds, restitution/wards/inmates/probationers monies held in trust, etc.): Employee and Employer premiums held in Trust Fund. 8 _ _ Maricopa County Title: Establishing Number: A2504 Internal Policy Administrative Bank Issue Date: May 2000 Accounts Policy Category: Finance Initiating Department: Revision No: 2 • Department of Finance Revision Date: June 20, 2012 For Department of Finance Use Only Financial reporting of deposits & investments held in Administrative Bank Account Fund classification: Special Revenue[ ] Debt Service[ I Capital Project[ ] Enterprise[ ] Internal Service[ ] Agency[ ] Advantage Fund Number (N/A for Agency Funds) Balance Sheet Account 0006/0013 (N/A for Agency Funds) See attached Memo for additional information. REQUIRED APPROVALS Appointing Authority Approval Date County Manager Approval Date 3/20/ty Compl 6d,y County Treasuyer County Treasurer Approval Date 3'2° "( Completed by Clerk of the Board of Supervisors/Board of Directors Date of Board of Supervisors/Directors Approval Agenda # 9 12146 EXHIBIT B Section 7— Process For Providing Funds For Benefits 7.1 Providing Funds for Benefits. The Plan is Self-Funded. County is solely responsible for providing funds for payment for all Plan benefits payable to Participants, Network Providers, or non-Network Providers. 7.2 Bank Account. Contractor, on County's behalf, will open and maintain a Bank Account at the Bank to provide Contractor the means to access County's funds for the sole purpose of payment of Plan benefits, Plan expenses (such as state surcharges or assessments) and, when authorized by County, service fees. The Bank Account will be a part of the network of accounts that have been established at the Bank for Contractor's self-funded customers. The funds in the Bank Account are County's and will not be comingled with any other customer funds. 7.3 Balance In Account. County will maintain a minimum balance in the Bank Account in an amount equal to not less than I day of expected Bank Account activity. Contractor will establish this amount based on expected Plan benefit payments, with appropriate adjustments for anticipated non-daily activity (e.g., prescription drug benefits and service fee payments) as determined by Contractor. Contractor will determine if circumstances warrant increasing this minimum balance, and will notify County if and when the required balance or the amount identified above changes. The required minimum balance is based on County's financial condition as assessed by Contractor. In the event Contractor determines, based on reasonable information and belief, that County's financial condition has deteriorated or County continues to fail to comply with the material financial obligations specified in this Agreement, Contractor may revise the required balance subject to providing five (5) days written notice to County. 7.4 Issuing and Providing Funds for Checks and Non-Draft Payments. The checks and/or non-draft payments Contractor writes and issues to pay Plan benefits under this Agreement will be written and/or issued from one or more common accounts that are a part of the network of accounts maintained at the Bank for Contractor's self- funded customers. When the checks for Plan benefits are presented to the Bank, the Bank will notify Contractor and Contractor will direct the Bank to either reject the checks or to withdraw funds from the Bank Account to fund the checks that are cashed. 7.5 Transfers of Funds. Funds will also be withdrawn from the Bank Account when a transfer of funds Contractor made to pay Plan benefits is completed, such as when an electronic funds transfer has been made to a health care provider to pay benefits under the Plan. Contractor will direct the Bank to withdraw funds from the Bank Account to fund the non-draft payments as they are issued. 7.6 Calls for Funds. The withdrawals for Plan benefits and service fees are paid for by the balance County maintains in the Bank Account. This balance will be drawn down each banking day to satisfy the previous day's liability. County will authorize Contractor to initiate wire transfers from County's designated benefit funding bank account to the Bank Account for the amount needed to pay claims processed and fees that are due. Every I business day(s), Contractor will notify County of the amount due and Contractor will immediately, via wire, initiate transfers from County's designated funding bank account to the Bank Account in an amount necessary to pay Plan benefits. 7.7 Underfunding. If County does not provide the amounts sufficient to maintain the required minimum balance in the Bank Account, or to cover Bank Account withdrawals: (1) County must immediately correct the deficiency and provide prompt notice to Contractor. (2) If Contractor learns of the funding deficiency, Contractor will notify County within one business day so County can correct the deficiency. (3) Contractor may stop issuing checks and non-draft payments and suspend any of its other services under this Agreement for the period of time County does not provide the required funding. (4) If County does not correct the funding deficiency within five business days of Contractor's notice to County, Contractor may terminate this Agreement as otherwise set forth in the Contract, such termination to be effective the first day such claims funding deficiency began. County will pay interest on the amount of underfunding at the standard rate that Contractor charges to its self-funded customers for underfunding of bank accounts. 12146 EXHIBIT B 7.8 Stop Payments on Outstanding Checks. At County's expense, Contractor may place stop payments on checks if Contractor determines that County has insufficient funds in its designated benefits funding bank account to honor such checks. Contractor will send a search letter to the payee on all checks that have not been cashed within six (6) months. Contractor will automatically stop payment on all checks that have not been cashed within twelve (12) months and provide County with reports County needs for the purposes of performing escheat. County is solely responsible for determining to file and/or filing unclaimed property once notified, or for making unclaimed payee payments directly. 7.9 Funding After Termination. When the Contract terminates, the funding method for Plan benefits will remain in place for the length of the run-out period. After the run-out period has ended, that funding method will cease and County will deposit and maintain in the Bank Account enough funds to cover all checks for Plan benefits that have been issued but not cashed. This balance will remain in the Bank Account for a limited period of time to fund the outstanding checks. This period will be reasonable, as determined by Contractor. Contractor will stop payment on all checks that remain uncashed at the end of this period and County will request in writing to close the Bank Account and recover any funds remaining in it. Contractor will provide bank statements and Bank Account reconciliation reports, including reports County needs for the purposes of performing escheat. Section 8 — Services Begin and End 8.1 Services Begin and End. Contractor will begin providing County services under the Contract and this Agreement on the Services Effective Date. These services apply only to claims for Plan benefits that are incurred on or after the Services Effective Date. Contractor's services under this Agreement stops on the date the Contract or this Agreement terminates, regardless of the date that claims are incurred. However, Contractor may agree to continue providing certain run-out claims administration services beyond the termination date, as provided in Exhibit B-1 to this Agreement. Section 9 — Records, Information, Audits 9.1 Records. Contractor will keep records relating to the services it provides under this Agreement for six (6) years or as long as Contractor is required to do so by law, whichever is latest. 9.2 Access to Information. If County needs information in Contractor's possession for purposes other than an audit, but in order to administer the Plan, Contractor will provide County access to that information, if it is legally permissible, the information relates to Contractor's services under this Agreement, and County gives Contractor reasonable advance notice and an explanation of the need for such information. County represents that it has reasonable procedures in place for handling PHI, as required by law. County will only use or disclose PHI to administer the Plan, to perform under this Agreement or as otherwise permitted under this Agreement or required by law. Contractor will provide information only while this Agreement is in effect and for a period of six (6) months after the Agreement terminates, unless County demonstrates that the information is required by law or for Plan administration purposes. Contractor also will provide reasonable access to information to an entity providing Plan administrative services to County, such as a consultant or vendor, if County requests it. Before Contractor provides PHI to that entity, the parties must sign a mutually agreed-upon confidentiality agreement and adhere to all obligations under Exhibit C (the HIPAA Business Associate Agreement) to the Contract, and the parties must agree as to what information is minimally necessary to accomplish the Plan administrative service. 9.3 Audits. During the term of the Agreement, and at any time within six (6) months following its termination, County or a mutually agreeable entity may audit Contractor once each calendar year to determine whether Contractor is fulfilling the terms of this Agreement. Prior to the commencement of this audit, Contractor must receive a signed, mutually agreeable confidentiality agreement. Without limiting the foregoing, with respect to audits regarding the payment of Rebates by pharmaceutical manufacturers, the audit must be conducted solely by a mutually agreeable public accounting firm that maintains a separate and stand-alone audit department and is not providing support in conjunction with any litigation pending against Contractor or its affiliates.