Common DOL Audit Triggers
| Trigger | Description | Risk Level |
|---|---|---|
| Participant complaint | Employee files a complaint with DOL about plan administration | High |
| Form 5500 anomaly | Unusual data in Form 5500 filing triggers review | Medium |
| Industry enforcement initiative | DOL targets specific industries or plan types | Medium |
| MHPAEA compliance | DOL's ongoing MHPAEA enforcement initiative | High |
| CAA transparency | Emerging focus on broker disclosure and price transparency | Medium |
| Random selection | DOL randomly selects plans for audit | Low |
MHPAEA Enforcement Initiative
MHPAEA compliance is a primary focus of current DOL health plan audits. The DOL's MHPAEA enforcement initiative targets plans that have not performed the required comparative analysis or that have significant parity disparities. Plans that receive a DOL MHPAEA audit request must produce the comparative analysis within 30 days.
Proactive Compliance
IQ Insight
Proactive compliance — maintaining current plan documents, performing required analyses, and documenting compliance efforts — reduces the risk of audit and improves audit outcomes. Plans that can demonstrate a good-faith compliance effort are treated more favorably in enforcement actions than those that cannot. The cost of proactive compliance is far less than the cost of an audit finding.