Before requesting documents

• Confirm the governing eligibility definitions, age limits, disability provisions, and coverage-loss rules.
• Identify inconsistencies across the plan document, SPD, enrollment materials, carrier system, and HRIS.
• Define acceptable evidence and reasonable alternatives.
• Establish privacy, secure-upload, retention, appeal, and escalation procedures.
• Coordinate prospective termination, COBRA, rescission, and payroll-refund questions with counsel and vendors.

Audit workflow

1. Clean the census and remove obvious system duplicates.
2. Send a clear notice explaining the rule, required action, deadline, help channel, and consequences.
3. Track responses without exposing sensitive documents in ordinary email.
4. Review consistently and provide a meaningful correction or appeal path.
5. Send final determinations and apply coverage changes under plan terms and law.
6. Reconcile the carrier, COBRA administrator, HRIS, payroll, and employee communications.

Important boundaries

HIPAA special-enrollment, COBRA, ACA rescission restrictions, Section 125 election rules, collective bargaining agreements, and state insurance law can affect the result. Do not retroactively cancel coverage merely because an audit found a discrepancy.