You Inherited Your Company's Health Benefits Plan. But Did You Inherit Its Problems Too?

A Practical 90-Day Health Benefits Review Checklist for HR Leaders

A new HR leadership role arrives with onboarding, payroll, policies, and compliance already in motion, and somewhere in that handoff, you inherit the company's health benefits program.

You may receive a benefits summary, a broker's contact information, and a folder containing enrollment materials. You may also be told that everything is running smoothly.

But how do you know?

When was the plan last reviewed? And who is responsible when something goes wrong?

A health benefits program can appear well organized while important questions remain unanswered.

For a new HR Director, the first 90 days are an opportunity to identify what is working, what needs attention, and which responsibilities may have been overlooked.

Here is where to begin.

1. Start With the Calendar: What Deadlines Did You Inherit?

Before evaluating coverage options or employee satisfaction, establish the benefits calendar.

Your company's health benefits program operates according to several timelines, and they may not all align with the calendar year.

Start by confirming the plan year, insurance policy renewal date, and next open enrollment period.

Then identify when the employer must make decisions about renewal terms, contributions, and employee communications.

Do not assume that a January 1 plan year means every administrative deadline falls in December.

Review agreements with your insurance broker, carrier, third-party administrator, and other benefits service providers.

Some agreements contain notice periods, renewal provisions, or termination requirements that deserve attention well before the insurance renewal date.

Also identify the deadlines associated with new-hire enrollment, qualifying life events, required notices, and applicable government reporting.

The first warning sign is not necessarily a missed deadline. It may be that nobody can tell you who owns the deadline.

A reliable benefits calendar should identify both the responsible party and the date by which each action must be completed.

2. Locate the Documents That Define Your Benefits Program

A benefits presentation is different from a legally required plan document.

One of the most important early responsibilities for an HR leader is establishing which documents govern the program and where the current versions are maintained.

For an ERISA-covered health plan, the written plan document establishes the plan's governing terms, while the Summary Plan Description (SPD) communicates important information to participants.

The SPD should explain matters such as eligibility, benefits, and how the plan operates.

The Summary of Benefits and Coverage (SBC) serves a different purpose. It provides a standardized explanation of covered benefits, cost-sharing provisions, and coverage limitations.

If the employer allows employees to pay eligible premiums through a Section 125 cafeteria plan, locate the written cafeteria plan document as well.

Confirm that the documents reflect the program currently being administered, including applicable amendments.

A new HR Director should also determine who is responsible for maintaining these documents and distributing them when required.

The broker, carrier, or outside administrator may assist with documentation. However, assistance from a service provider does not automatically transfer the employer's legal responsibilities.

A practical question to ask: If an employee requested the governing benefits documents tomorrow, could your organization identify and provide the appropriate materials?

If the answer is uncertain, document control deserves attention.

3. Identify Which Compliance Obligations Actually Apply

Not every employer faces the same health benefits compliance requirements.

Company size, plan structure, funding arrangements, employee locations, and other factors can determine which federal and state obligations apply.

A new HR Director should verify applicability before assuming that a particular filing, notice, or continuation coverage requirement is either mandatory or unnecessary.

COBRA: Does Federal Continuation Coverage Apply?

Federal COBRA generally applies to private-sector group health plans maintained by employers with at least 20 employees on more than 50% of their typical business days during the previous calendar year.

Part-time employees count proportionally when determining whether the threshold is met.

Covered plans must follow applicable continuation coverage requirements when qualifying events occur.

Employers below the federal threshold should also examine applicable state continuation coverage laws, which may impose additional requirements depending on the jurisdiction and insurance arrangement.

HR should identify who handles qualifying event notifications, elections, deadlines, and recordkeeping.

ACA Reporting: Is Your Company an Applicable Large Employer?

Under the Affordable Care Act, an Applicable Large Employer (ALE) generally has an average of at least 50 full-time employees, including full-time equivalent employees, during the preceding calendar year.

Special rules, including those for related employers and certain seasonal workforces, can affect the determination.

ALE members generally have reporting responsibilities involving Forms 1094-C and 1095-C.

These reporting obligations should be reviewed separately from the employer shared responsibility provisions, which determine whether a payment may apply based on the coverage the employer offers.

A company that has grown significantly should verify its ALE status rather than relying on last year's assumptions.

Form 5500: Is an Annual Filing Required?

Form 5500 reporting requirements depend on the type, size, and funding structure of the employee benefit plan.

Certain welfare benefit plans with fewer than 100 participants at the beginning of the plan year may qualify for an exemption when applicable funding and other conditions are satisfied.

However, not every small plan qualifies for an exemption, and larger plans are not necessarily subject to identical reporting requirements.

HR should confirm whether a filing is required, who prepares it, and who is responsible for reviewing and submitting it.

Required Employee Notices

Health plans may be subject to multiple federal and state disclosure requirements.

Depending on the arrangement and circumstances, these can include ERISA disclosures, COBRA notices, and HIPAA special enrollment notices.

Two additional notices deserve particular attention:

Medicare Part D Creditable Coverage Disclosure. Entities providing prescription drug coverage generally must notify Medicare-eligible individuals covered under the arrangement whether that coverage is creditable. Where applicable, the annual notice must be provided before October 15, along with notices required in other specified circumstances.

CHIP Premium Assistance Notice. Employers maintaining group health plans in states offering Medicaid or CHIP premium assistance for group coverage must provide the applicable Employer CHIP Notice annually. The notice informs employees about potential premium assistance opportunities in their state of residence.

Some notices are associated with initial enrollment, others with specific events, annual periods, or changes to coverage.

The goal is to establish which notices apply to the company's arrangement, when they are due, and how distribution is documented.

4. Is the Health Benefits Program Actually Working for Employees?

Once the administrative foundation is understood, the next question is whether the benefits program meets employees' needs.

A company can maintain current documents, meet its reporting obligations, and still have a health benefits program that employees find difficult to use.

Consider an employer that offers health insurance but regularly hears concerns about provider networks, prescription costs, or unexpected out-of-pocket expenses.

These concerns may have several explanations, but they are worth examining.

Start by reviewing participation and waiver information.

How many eligible employees enroll? How many decline coverage? Are there patterns that warrant further investigation?

A waiver does not necessarily mean an employee is dissatisfied. Some employees may have coverage through a spouse, another qualifying source, or a different arrangement.

Next, examine the concerns employees actually raise.

Are employees having difficulty finding in-network physicians? Are deductibles or cost-sharing requirements creating financial pressure? Are employees confused about eligibility, enrollment, or coverage terms?

Ask your broker and carrier what aggregate information they can appropriately provide.

Depending on the plan and available reporting arrangements, this may include enrollment trends, utilization summaries, or other aggregated indicators.

Small fully insured groups may have limited access to detailed claims information, particularly where privacy restrictions or carrier reporting practices limit disclosure.

Employers should not expect unrestricted access to individual medical information.

Confidential employee feedback, aggregate enrollment data, and discussions with the benefits advisor can still help identify issues worth investigating.

The goal is to determine whether the organization has enough information to evaluate how well the program serves its workforce.

5. Review the Relationship With Your Benefits Broker

A benefits broker can play an important role beyond presenting insurance quotes.

But the services available to an employer depend on the relationship, contractual arrangements, and scope of engagement.

A new HR Director should understand what the broker has agreed to provide and how those services are delivered.

Does the broker assist with enrollment communications and employee education?

Who helps resolve coverage questions or escalates issues to the insurance carrier?

Does the broker provide renewal analysis, explain alternative plan designs, or assist with identifying potential compliance concerns?

What happens when an employee has a coverage issue that cannot be resolved through the carrier's ordinary service channels?

Review the existing service agreement and clarify expectations directly.

Some responsibilities may belong to the employer, while others may be supported by the broker, carrier, legal counsel, payroll provider, or third-party administrator.

The important point is to identify the boundaries before a problem occurs.

A productive broker relationship should give HR leadership clarity about available services, escalation procedures, and who is accountable for each administrative task.

6. Your First 90 Days: Health Benefits Review Checklist

A structured review starts with visibility into the existing arrangement and a list of areas that need follow-up.

Use the following checklist as a starting point.

Days 1–30: Establish Control

☐  Confirm the current plan year, policy renewal date, and open enrollment calendar.

☐  Identify all carriers, brokers, administrators, and other benefits service providers.

☐  Locate current plan documents, SPDs, SBCs, amendments, and applicable Section 125 documentation.

☐  Review existing service agreements, renewal provisions, and termination notice requirements.

☐  Determine who maintains enrollment records, employee notices, and benefits documentation.

☐  Identify upcoming compliance deadlines and assign responsible parties.

Days 31–60: Evaluate Compliance and Operations

☐  Confirm whether federal COBRA and applicable state continuation coverage requirements apply.

☐  Verify ALE status and applicable ACA reporting responsibilities.

☐  Determine whether Form 5500 filing is required or an exemption applies.

☐  Review required employee notices and available distribution records.

☐  Examine onboarding, qualifying life event, and termination procedures.

☐  Confirm how enrollment discrepancies, coverage questions, and premium payment issues are escalated.

☐  Review the broker's scope of services and administrative responsibilities.

Days 61–90: Evaluate Employee Experience and Prioritize Improvements

☐  Review eligible employee counts, participation, and waiver information.

☐  Identify recurring employee questions and coverage-related complaints.

☐  Request available aggregate enrollment or utilization information from the broker or carrier.

☐  Evaluate whether employees understand their coverage options and cost-sharing responsibilities.

☐  Identify operational gaps, unresolved documentation issues, and opportunities to improve employee communication.

☐  Establish an action plan with responsible parties, priorities, and target completion dates.

☐  Schedule the next benefits review before the applicable renewal decision deadlines.

By the end of 90 days, the HR leader should have a clearer understanding of the company's existing benefits obligations, operational processes, and employee experience.

The outcome may be a decision to maintain the current program while improving administration and communication.

Or it may reveal issues that warrant a more substantial review.

Either result is useful when supported by reliable information.

7. What If the Review Reveals That the Current Program No Longer Fits?

An inherited benefits program should not be changed simply because a new HR Director has arrived.

But the review may reveal that the company's workforce, administrative resources, or coverage needs have changed significantly since the existing arrangement was established.

In that situation, employers can evaluate different approaches to providing health benefits, including traditional group health plans and, where appropriate, a CHOICE Arrangement (ICHRA). Each model has distinct design, administration, and compliance considerations. For a broader comparison, see Lirvion’s ICHRA vs. Traditional Group Health Plans page: https://www.lirvion.com/guides/ichra-vs-group-health

Any transition should be evaluated against the employer's circumstances, applicable requirements, and realistic implementation timeline.

The Bottom Line

Taking over a health benefits program means inheriting deadlines, documents, legal obligations, vendor relationships, and employee expectations.

Some of those responsibilities are already well managed; others may never have been clearly assigned.

The first 90 days are the time to find out which is which.