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HomeMy WebLinkAboutCOMEBPT 2024 Management Letter - DRAFTApril 30, 2026 William Nary Chairperson City of Meridian Employee Benefits Plan Trust 33 E. Broadway Ave Meridian, ID 83642 ** via e-mail: cbarney@meridiancity.org ** Re: City of Meridian Employee Benefits Plan Trust Management Letter Financial Condition Examination as of December 31, 2024 Dear Mr. Nary: The Idaho Department of Insurance recognizes the City of Meridian Employee Benefits Plan Trust’s (the “Trust”) important role in providing a Self-Funded Health Care Plan to the citizens of Idaho. SCOPE OF EXAMINATION The primary objectives of the modified risk-focused examination were to reach specific and general conclusions about the financial condition under which the Trust operates, as well as the control environment during the examination period. To accomplish these objectives, the examination limited its focus on areas that were most likely at risk based on our analysis. As a result of our review and to assist management, we are submitting, for your consideration, additional examination comments which will not be included in the final report of examination. It should be understood that our comments deal exclusively with operational systems, procedures and controls and should not be regarded as reflecting on the integrity or capabilities of anyone in the Trust. It should further be recognized that our comments are restricted to suggested improvements and are not intended as a commentary on the various favorable aspects of the Trust’s operations. Our evaluation, comments, and suggestions regarding the Trust’s practices do not necessarily disclose all weaknesses. There may be some areas needing improvement that were not commented on herein. We outlined only those observations that were identified during our examination, covering the period from January 2, 2020, through December 31, 2024.  We appreciate management’s ongoing efforts to improve risk mitigation and ensure regulatory compliance. Although the findings and recommendations contained in this letter do not rise to a level of seriousness that requires their inclusion in the corresponding report of examination, we view them as legitimate considerations. We expect you to consider the cost/benefit effect of the recommendations and to implement them where appropriate. Implementation of these recommendations may improve the quality of the overall control environment and risk mitigation. If you have any questions or require additional information with respect to any of the matters discussed in the accompanying findings and recommendations, please do not hesitate to contact us. Please submit your written response, or written acknowledgment that the included Trust’s response is accurate, to our findings and recommendations in both the report of examination and management letter within twenty-eight (28) days. Included in your response should be an affirmation that our findings and recommendations, in addition to management’s responses, have been reviewed by the Board of Directors. Sincerely, Cecilee Houdek, CFE Examiner-in-Charge The INS Companies On behalf of Idaho Department of Insurance cc: Eric Fletcher, Bureau Chief/ Chief Examiner Idaho Department of Insurance James Anderson, Deputy Chief Examiner Idaho Department of Insurance Amber Re, Examiner Financial Analyst Supervisor Idaho Department of Insurance Anthony Green, Examiner Financial Analyst Idaho Department of Insurance FINDINGS AND RECOMMENDATIONS INTERNAL CONTROL BEST PRACTICES Issue: Governance and Oversight Practices FINDING: During review of meeting minutes, the examination identified several governance-related concerns, including: The Board does not formally review or approve the annual audit report or actuarial report in its meeting minutes, and the auditor and actuary do not regularly present their reports directly to the Board. Meeting minutes are not signed. Some meeting minutes contained inconsistencies between the document title, referenced dates within the content, and the actual meeting date. In the minutes dated August 17, 2022, a policyholder’s name and coverage details were disclosed.  This is a significant privacy concern, as Trustees should not have access to or disclose personally identifiable information (PII) of policyholders in public meetings or discussions. Officers of the Trust, Chair and Vice-Chair, are required by the Trust Agreement to be elected at the first regular meeting in November of each year; however, no evidence was noted in the meeting minutes to indicate that such elections occurred during that time. RECOMMENDATION: It is recommended that the Board strengthen its governance by: Formally reviewing and approving the annual audit and actuarial reports in Board meetings, with the auditor and actuary present to summarize any findings and answer questions. Ensure all meeting minutes are signed by the Chair or Secretary to affirm completeness and accuracy. Establish strict protocols to prevent the inclusion of PII in Board minutes or discussions to mitigate potential legal risks. Ensure compliance with the Trust Agreement by conducting officer elections at the first regular meeting in November each year, or amend the Trust Agreement to reflect current governance practices. TRUST RESPONSE: Following the annual audit, the Board will have the auditor provide a formal review of the audit and any findings to include the SOC’s for all TPAs on record.  This provides an opportunity for the Board to discuss, ask questions and ensure a full understanding of the audit. The Board will work to amend the COMEBPT By-Laws to include: Meeting minutes will be signed following the approval of the minutes during the Trust Meeting, affirming the completeness and accuracy of the record. The Trustees of the Board will not disclose any PII during meetings. Should an employee have a desire to address the Board regarding their situation, the Board will provide the following disclosure statement to the employee: Please be aware that any statements you make or information you disclose during the Board meeting will become part of the official public record. This includes both oral comments and any written materials you submit. Accordingly, you should avoid sharing confidential, private, or protected information during the meeting. If you have questions about what may be appropriate to disclose, Human Resources is available to provide guidance in advance of the meeting. Issue: Lack of Documentation of Key Processes FINDING: During review of process documentation and interview with management, the following were noted: There is no formal process in place to monitor Third-Party Administrators (TPAs). There is no defined process to report instances of internal fraud. There is no process to obtain and review annual System and Organization Controls (SOC) reports from TPAs. RECOMMENDATION: It is recommended that the Trust strengthen its processes by: Creating a formal process to periodically review the transactions processed by TPAs to ensure information was reported accurately and within policy requirements. Establishing documented protocols of how internal fraud should be reported and the action items to be followed. Implement an annual procedure of obtaining TPA SOC reports from the TPA and performing a review of the results. Review any control failures and determine the impact to the Trust. TRUST RESPONSE: The Board will work to amend the COMEBPT By-Laws to include: Board is to review a random sample of transactions by each TPA biannually to ensure information is reported accurately and within policy requirements. Should a discrepancy be found, the Trust will conduct a full audit of the TPA. The Board will work to amend the COMEBPT By-Laws to include: Any concerns, violations, or fraud suspected by the Board should be reported through the Compliance & Ethics Help Line 844-797-9166 or online by going to MyComplianceReport.com. The line is staffed by Compliance Line, a third-party organization, which will document your concerns and send the report to Human Resources. You may remain anonymous, or you may choose to identify yourself. Regardless of your decision, your information will be documented and investigated. The toll-free number that you can call is 844-787-9166. Compliance Line does not trace or record calls and does not have caller identification. Once you have entered the site, you will click on "begin new report" (bottom left of page). You will be asked to provide an access I.D. The City's I.D. is COM. Compliance Line posters are posted on all general bulletin boards at all City Facilities and on the City’s Intranet. The Board will implement an annual procedure of obtaining TPA SOC reports from the TPA and performing a review of the results. Review any control failures and determine the impact to the Trust. COMPLIANCE Issue: Conflict of Interest Disclosure Practices FINDING: It was observed that the Trust does not have a formal process that requires Board of Trustees members to review and sign conflict-of-interest statements annually.  Statements appear to only be signed at the time of appointment. Additionally, one Trustee who joined the Board in 2022 did not sign a conflict-of-interest statement until September 2025.  The current practice may not sufficiently ensure ongoing compliance with Idaho Code § 41-4015, which prohibits pecuniary interests in plan management, and could create governance risks if future conflicts of interest arise and remain undisclosed. RECOMMENDATION: It is recommended that the Trust implement a policy requiring all Trustees to review and sign a conflict-of-interest statement annually and document their review within meeting minutes.  This would support compliance with Idaho Code and promote proactive identification of potential conflicts. TRUST RESPONSE: All Trustees of the Board will review and sign the Conflict of Interest at the first meeting in January each year. Issue: Uninsured Cash Balances not in Compliance with Idaho Code § 41-4009(1)(e) FINDING: During the review of the cash balances for the years under examination, it was noted that the Trust maintains cash balances in excess of FDIC limits. Idaho Code § 41-4009(1)(e) established that deposit account balances should not exceed the amount covered by applicable deposit insurance limits. Uninsured amounts are as follows: 2024 - $2,131,142 2023 - $2,700,437 2022 - $2,002,600 2021 - $1,319,650 2020 - $1,347,283 RECOMMENDATION: It is recommended that the Trust consult with its financial institution to explore various ways to mitigate this risk. TRUST RESPONSE: The Board will consult with First Interstate Bank on options for insuring funds. Issue: Lack of Actuarial Opinion FINDING: In our review of the Actuarial Report, it was noted that there was no evidence of an actuarial opinion by the actuary. Idaho Code requires that reserves must be certified by a qualified actuary annually. Legal sections are as follows: 41-4010(1)(a) – The Trust fund shall establish and maintain a reserve in an amount as certified by a qualified actuary as being necessary for payment of claims liability. It must be reasonably adjusted on a quarterly basis in an amount as determined by a qualified actuary. 41-4011(3) – Details the filing of an actuarial opinion as described in 41-4010, adding that it should be prepared in accordance with the actuarial standard of practice no. 28. IDAPA 18.04.05.026.03 details that reserves need to be certified annually by a qualified actuary. RECOMMENDATION: We recommend that the actuary provides the Trust with an actuarial opinion as required under the Idaho Code going forward. TRUST RESPONSE: ACTUARIAL - INTERNAL CONTROL BEST PRACTICES Issue: IBNR Margin Estimate FINDING: We noted that the Trust's IBNR Estimate/report is said to have included a 20% margin. However, upon review, we noticed that the 20% margin does not apply anywhere. The following margins were noted: Medical - 10% Prescription Drug - 9.3% Dental - 14.3% Vision - Nothing. However, the Company's IBNR report shows Vision IBNR with Margin applied as $4,497. This shows a discrepancy between the two amounts listed. It is important that the Trust ensures consistency between the various tables and illustrations provided in the Opinion. RECOMMENDATION: Based on this, we recommend that the Trust ensure consistency in its actuarial report by documenting the correct margin utilized in the IBNR process. TRUST RESPONSE: The Board met with our actuary to review the IBNR and Actuarial Opinion. It was determined by the actuary the 20% margin was not applied correctly and the IBNR and Opinion were updated. The Trust submitted a new Opinion and IBNR on April 9 to Mike Mayberry and the updates made were deemed acceptable. The Board will review the Opinion with our actuary to ensure consistency with all information provided. Issue: Lack of Claim Settlement Expense FINDING: The Trust does not include in its IBNR Estimate an Expense Reserve, or what is often called the “Administration Cost to Discharge the Reserve” or a Claim Settlement Expense. This is often assumed to be 1 to 2 months of medical administrative fees and is expressed as an additional percentage added to the Claim Reserve. RECOMMENDATION: We recommend adopting this in future estimates to cover administrative runoff fees. TRUST RESPONSE: The Board met with our actuary to review the IBNR and Opinion. The actuary was able to update the Opinion and IBNR to reflect Administration Costs. The Trust submitted a new Opinion and IBNR on April 9 to Mike Mayberry and the updates made were deemed acceptable. The Board will ensure the Administrative Costs estimates are listed on all IBNR/Opinions.