If your health or dental plan is self-insured, then you know that there are some key differences in comparison to a fully insured plan. For public school districts in Wisconsin that self-insure their sponsored health or dental plans, there is one other emerging requirement.
Wisconsin Statute §120.14 and the Wisconsin Department of Public Instruction (DPI) state audit guidelines require that school district audits, on behalf of those that have established a self-insured health or dental plan, include specific information concerning the plan, as specified by the Wisconsin Office of the Commissioner of Insurance (OCI). The 2021 Wisconsin School District Audit Manual addresses these requirements, as specified by OCI. The DPI has worked with OCI to provide a self-insured insurance footnote disclosure template that includes the information required by OCI. This footnote includes detailed information regarding school districts’ self-insured plan, including when the plan was established, who is responsible for the administration, approval, processing and payment of claims, details regarding purchased stop-loss coverage, estimates of claims outstanding as of the recent fiscal year ends and, ultimately, an actuarial certification attesting to the adequacy of the reserves, rates, and overall financial soundness of the plan. This certification must be provided by an independent actuary who is a member of the Society of Actuaries (SOA) or the American Academy of Actuaries (AAA).
However, OCI has allowed school districts to avoid fulfilling this requirement if the plan administrator is unable to provide such certification for 2021 reporting and also now for 2022 reporting. It is a fluid situation in that it’s unknown when OCI will fully implement the requirement as written in the statute. Despite this, some school districts and auditors are still choosing to receive an actuarial certification to simply have a better understanding of their health or dental plan’s financial soundness and stability.
KBC has been in constant contact with OCI to understand the current status of their requirements. If you’re interested in receiving an actuarial certification or your auditor is recommending you obtain one, please do not hesitate to reach out to KBC with any questions.