Lumelight helps simplify the complex work behind employee benefits with expert-led solutions for ACA reporting, MHPAEA comparative analysis, Form 5500 filings, nondiscrimination testing, ERISA wrap documents, and dependent eligibility verification. Reduce administrative burden, manage risk, and strengthen plan integrity with specialized support in the areas that demand it most.
Dependent Eligibility Verification
Integrated with ADP Workforce Now® and ADP Workforce Now NextGen®
ADP® clients can now add Lumelight’s iVerifyPro dependent eligibility verification solutions along with their other HR and financial services directly through ADP Workforce Now, versus partnering with vendors separately. Staying true to our commitment to ease-of-use, all services and reports will now be billed and accessed through one ADP account, and employers can simplify operations and automate data through our API-based integration with ADP.
Downloads: Our DEV Solution | Case Study
It is important to consider various factors before hiring a third party for dependent eligibility verification. What matters most is selecting a third party that your organization trusts and is the best fit for your members.
We recommend also considering:
How long have they been in business?
Do they have the necessary privacy, security, and insurance policies?
Could other service offerings be considered a conflict of interest?
Do members have different methods for submitting the required information?
Is live help available for members who need assistance?
Is the verification process easy to follow and complete?
What is included in the price and what may cost extra?
A dependent eligibility verification audit is a process used by employers or plan sponsors to verify if the relationship between dependents and the employee or member aligns with the eligibility rules defined by the plan. For example, a valid birth certificate would confirm that a child is an eligible dependent of the member.
The dependent verification process ensures that only those who qualify as dependents – such as spouses, children, or others defined by the plan – receive benefits, thereby controlling costs and maintaining compliance with plan rules.
If a dependent audit participant needs help, they can reach a live Lumelight representative via our helpline, available Monday–Thursday, 7:30 am-6:00 pm CT, and Friday, 7:30 am-4:00 pm CT. Participants can also submit a request for assistance at any time through our member portal.
An ineligible dependent is someone who does not qualify for healthcare coverage based on the plan's eligibility rules. For example, an ex-spouse wouldn’t qualify as a dependent if the plan only covers a current legal spouse.
Lumelight offers two types of dependent eligibility verification.
Comprehensive Dependent Verification
A comprehensive dependent eligibility verification is a thorough, documentation-based verification of all enrolled dependents within an organization's health plan(s). Results leave the organization with an accurate list of dependents who did and did not meet the specific eligibility requirements.Ongoing Dependent Verification
Ongoing dependent verification regularly checks the eligibility of dependents added through life events, new hires, open enrollment, and mergers & acquisitions. Conducted monthly, bi-monthly, or quarterly, this process helps prevent future coverage of ineligible dependents.
Additionally, comprehensive and ongoing verifications can include a Working Spouse or Affidavit-Only verification.
If an ineligible dependent is found enrolled in a benefit plan, the dependent should be removed. Then you should conduct a comprehensive dependent eligibility verification audit of all enrolled members. This will ensure no additional ineligible dependents remain on the plan, helping to lower plan costs, fulfill ERISA requirements, and reduce the risk of tax consequences and stop-loss claim denials.
To help ensure that no ineligible dependents are enrolled in a benefit plan, a comprehensive dependent verification review of each dependent’s eligibility should be conducted. This process should then be performed on an ongoing basis for newly added dependents throughout the year and during open enrollment. This provides peace of mind knowing that only eligible dependents are enrolled.
The dependent eligibility verification best practice in the industry is a combined approach that includes a comprehensive audit followed by ongoing verification. Lumelight can help you select the ideal approach for your needs and those of your members.
Contact us for more information.
There’s no bad time to conduct a dependent eligibility audit with Lumelight. We will partner with you to find the timing that works best for your organization.
Yes, Lumelight has a standard process for verifying if a working spouse has other insurance options through their own employer. If they do, a spousal surcharge may be added to the member's premium, or the spouse may be excluded from the plan through a spousal carve-out policy.
Working spouse verification can be conducted as part of a comprehensive dependent eligibility audit, during ongoing verification, or on its own.
For optimal member experience, a dependent eligibility audit typically takes 12-16 weeks from kick-off to completion. This provides members with enough time to gather documents that they may not have readily available.
For the plan sponsor and/or the broker consultant, the time commitment averages less than an hour a week. This time is spent on setup, progress updates, and a wrap-up discussion with Lumelight experts for a presentation of the audit findings and guidance on the next steps.
Contact us and we can provide a detailed plan based on your needs.
Yes, spousal-only verification can be conducted for spouses without including dependent children. Because divorces are often unreported, reviewing marital status annually keep records accurate.
It is best to verify the eligibility of all dependents as close as possible to the date they are added to the plan. We recommend starting with a comprehensive verification of all enrolled dependents to confirm current enrollment is accurate, followed by ongoing verification to verify any dependents added through new hires, qualifying life events, annual enrollment, or mergers and acquisitions.
Comprehensive verification should be considered every 2-3 years to look for relationship or eligibility changes that could lead to an ineligible dependent.
Spousal-only verifications should be conducted annually to verify that the relationship is still active and the surcharge or carve-out associated with the working spouse rule is applied correctly, if applicable.
Yes, Lumelight can accommodate an affidavit-only verification. An affidavit-only dependent verification relies on the member attesting that their dependents meet the plan’s eligibility requirements. This process does not require members to submit supporting documents like marriage certificates, birth certificates, or tax returns.
While an affidavit-only option is available, Lumelight strongly recommends collecting supporting documents as more substantial documentation of dependent eligibility and compliance with ERISA requirements.
Pricing for dependent verification depends on a few key factors—like the verification approach and number of households (members covering dependents). For an accurate estimate, the best next step is to request a custom quote from the Lumelight team.
Dependent eligibility verification is important because:
Rising costs. Healthcare benefits are the second largest line item for most organizations and costs continue to increase. Both self-insured and fully insured plans benefit from dependent verification, which helps to mitigate expenses by removing ineligible dependents.
Compliance. Completion of a dependent eligibility audit helps reduce regulatory compliance risk under Sarbanes-Oxley, ERISA, and Department of Labor (DOL) guidelines by ensuring only eligible dependents are enrolled in benefit plans. This process strengthens internal controls, supports accurate reporting, and demonstrates compliance and due diligence in plan administration. Failure to prioritize this effort could result in financial penalties, tax consequences, claims denials, and increased exposure to legal and regulatory scrutiny.
Suspected or known issues. Sometimes, an ineligible dependent is discovered through the normal course of business. A comprehensive dependent verification audit is the best way to ensure that no additional ineligible dependents are covered by the plan. What are the average results of a dependent eligibility verification audit?
On average, dependent eligibility verification audits find that 9.5%* of enrolled dependents are found to be ineligible for benefits coverage. Results vary based on industry, plan eligibility criteria, and prior verification efforts.
See sample audit findings here.
*Results from audits conducted by Lumelight (formerly BMI Audit Services) from January 2022 - December 2024.
On average, a dependent eligibility verification audit provides an impressive ROI of 2,573%*. With the average annual plan sponsor cost of $7,000 per dependent, the savings identified through an audit often vastly outweigh the cost of conducting one.
Use Lumelight’s calculator to see how much you may be spending on ineligible dependents.
*Results from dependent audits conducted by Lumelight (formerly BMI Audit Services) from January 2022 - December 2024.
Yes, dependent verification helps to reduce or prevent healthcare cost increases for plan sponsors, insurers, and members. Here’s how:
Dependent verification is a powerful way to manage and reduce healthcare costs while protecting the financial integrity of your benefits plan.
Organizations that benefit from a comprehensive dependent verification include healthcare plans that:
have never conducted a dependent eligibility audit
have not completed an audit within the last 2-3 years
utilize a spousal surcharge or carve-out
experience high turnover or company mergers & acquisitions
have made changes to their coverage or eligibility rules
Organizations that benefit from ongoing dependent verification include healthcare plans that:
do not have a plan to manage ongoing verification internally
have recently completed a comprehensive audit
experience high turnover or company mergers & acquisitions
Yes. Lumelight’s dependent eligibility verification audits help plan fiduciaries comply with ERISA’s fiduciary duties by supporting their obligations to follow the terms of the plan and act in the sole interest of plan participants. These audits also help employers comply with ERISA’s exclusive benefit rule by ensuring that only truly eligible participants are benefiting from plan assets.
The 4-step dependent eligibility audit process is fast, simple, and easy for members to complete.
Communication
Clear instructions are sent via email and mail to plan members on how to complete the verification process for each dependent they have enrolled.
Document submission
Members submit required documents through a secure web portal, fax, or mail.
Review and verification
Lumelight reviews documents to verify the dependent relationship and notifies members if any additional information is needed.
Results
Lumelight shares the verification results with the members and plan sponsor throughout the process.
Dependent eligibility verification typically requires standard documents that confirm a dependent’s relationship to the plan participant. Lumelight can support all relationship types permitted under a plan.
Examples of a few common relationships with documents that could be requested are:
Spouses: Marriage certificate, tax return showing joint filing, or other proof of ongoing relationship
Children: Birth certificate, adoption papers, court order, or proof of guardianship
Other: Legal documents proving custody or financial dependency
Many organizations turn to a third party for dependent eligibility verification because managing an audit internally is time-consuming and resource intensive. Partnering with Lumelight helps streamline the process, maintain objectivity, and reduce potential friction by creating a clear separation between HR teams and plan members.
With Lumelight’s process, the plan sponsor and/or the broker consultant typically spend less than an hour a week on the project. Lumelight has robust tools and services to manage the entire eligibility verification process so that you don’t have to.
These include:
Experienced personnel dedicated to dependent eligibility verification
Personalized and effective member notifications
Fully managed distribution of communications
Online portal for member resources and document submissions
Member assistance via a live representative
Detailed review of submitted documents
Individual follow-up for members with incomplete documents
Online client portal with access to project status and member details
Wrap-up consultation with recommendations for next steps
ACA Employer Reporting
For plans with under 250 lives
The Affordable Care Act’s reporting rules change often — and the IRS no longer accepts “good faith” errors.
You’re expected to master hundreds of compliance details while managing everything else HR throws your way.
It’s a lot. And you shouldn’t have to do it alone. We manage every detail — from data collection to filing — with precision and care, ensuring your organization stays penalty-free.
Downloads: Our ACA Solution | Case Studies
For plan years beginning in 2026, employer-sponsored health coverage is considered affordable if the employee's required contribution for the lowest-cost self-only coverage option does not exceed 9.96% of the employee's household income.
Because employers generally do not know an employee's household income, the IRS allows employers to use one of three affordability safe harbors:
Federal Poverty Line (FPL) Safe Harbor
Rate of Pay Safe Harbor
Form W-2 Safe Harbor
Using one of these safe harbors helps employers determine affordability for ACA compliance and ACA employer reporting purposes.
ACA affordability is one of the key requirements of the ACA Employer Mandate.
If an Applicable Large Employer (ALE) offers coverage that is not affordable and a full-time employee receives a premium tax credit through a Health Insurance Marketplace, the employer may be subject to IRS penalties.
Monitoring affordability throughout the year helps employers reduce compliance risk and avoid unexpected assessments.
The IRS provides three ACA affordability safe harbor methods that employers can use to demonstrate affordability:
- Federal Poverty Line (FPL) Safe Harbor
Uses the federal poverty guidelines to establish a maximum employee contribution amount.- Rate of Pay Safe Harbor
Calculates affordability based on an employee's hourly rate or monthly salary.- Form W-2 Safe Harbor
Measures affordability using Box 1 wages reported on the employee's Form W-2.
Employers may use different safe harbors for different employee groups when applied consistently and in accordance with IRS rules.
ACA Employer Mandate penalties, also known as Employer Shared Responsibility Payments (ESRPs), may apply to Applicable Large Employers (ALEs) that:
Fail to offer minimum essential coverage to at least 95% of full-time employees and eligible dependents, or
Offer coverage that is unaffordable or does not provide minimum value.
The IRS adjusts ACA Employer Mandate penalty amounts annually.
For ACA purposes, a full-time employee is someone who works:
At least 30 hours per week, or
At least 130 hours per month
Employers use this definition when determining eligibility for health coverage and ACA reporting obligations.
A Full-Time Employee is an individual who averages at least 30 hours of service per week/130 hours per month.
A Full-Time Equivalent Employee (FTE) is a combination of employees who aren’t full-time, but who together are counted as full-time for purposes of determining their employer’s ALE status.
FTEs are not generally counted as full-time employees for the Employer Mandate’s offer of coverage requirements.
The ACA filing requirements depend on the employer's size and funding arrangement.
Applicable Large Employers (ALEs)
ALEs, regardless of their insurance type, must create:
Self-Insured Employers
Self-insured ALEs must comply with the requirements above and also generate Forms 1095-C for individuals who weren’t full-time, but who were enrolled in their self-insured coverage (COBRA participants, retirees, etc.)
Self-insured employers that are too small to qualify as an ALE must create:
Employers should ensure they are filing the correct ACA forms to remain compliant with IRS requirements.
Applicable Large Employers (ALEs) must distribute and file ACA reporting forms each year to comply with Affordable Care Act (ACA) requirements.
Employee Statement Deadline
Forms 1095-C must be furnished to employees by March 2 following the reporting year (or the next business day if March 2 falls on a weekend or holiday).
IRS Filing Deadlines
Employers must submit ACA reporting forms to the IRS by:
February 28 if filing on paper
March 31 if filing electronically
Because the IRS now requires nearly every employer to file electronically, the March 31 deadline applies to the vast majority of ACA filers. Employers can request an automatic 30-day extension to this deadline if need be.
Employers should monitor IRS guidance annually, as filing deadlines and reporting requirements may change. Lumelight helps employers stay on track with ACA reporting deadlines by automating data validation, form preparation, and electronic filing workflows.
Late, incomplete, or inaccurate ACA filings can result in significant IRS penalties.
Employers may be assessed penalties for:
Failing to file required ACA forms with the IRS
Failing to furnish employee statements on time
Filing forms with incorrect or incomplete information
Failing to file electronically when required
Lumelight's ACA Employer Reporting solution helps employers reduce compliance risk by identifying data issues early, streamlining ACA form preparation, and supporting accurate, on-time filing with the IRS.
Yes. Many employers choose to outsource ACA reporting to a specialized compliance and reporting partner to help:
Improve data accuracy
Reduce administrative burden
Meet IRS filing deadlines
Minimize compliance risk
Manage corrections and employee statements
Whether you are looking for ongoing ACA reporting services or support with a specific filing year, outsourcing ACA employer reporting can help improve accuracy, streamline compliance, and reduce reporting risk.
ACA reporting is a complex, data-intensive, and highly regulated compliance responsibility. Lumelight helps employers simplify this process by bringing together reporting expertise, filing support, and subject matter expertise. Our team of experts can help with tracking, unique company and plan designs, and general affordability issues to make reporting seamless.
With Lumelight, employers can streamline ACA reporting workflows, improve data quality, reduce compliance risk, and confidently meet annual IRS reporting requirements.
ACA reporting refers to the annual reporting requirements established under the Affordable Care Act (ACA). Employers, insurers, and other coverage providers must report information about health coverage offered to employees and covered individuals using IRS Forms 1094 and 1095.
Applicable Large Employers (ALEs) use Forms 1094-C and 1095-C to report offers of coverage and demonstrate compliance with the ACA Employer Mandate.
Accurate ACA reporting helps employers avoid penalties and satisfy IRS requirements.
An Applicable Large Employer (ALE) is an employer that averaged at least 50 full-time employees, including full-time equivalent employees (FTEs), during the previous calendar year.
ALE status determines whether an employer is subject to:
ACA Employer Shared Responsibility (Employer Mandate) rules
IRS Forms 1094-C and 1095-C furnishing and filing obligations
Yes. Although the federal individual mandate penalty was reduced to $0, the ACA Employer Mandate remains fully in effect. Applicable Large Employers (ALEs) must continue offering affordable, minimum-value health coverage to eligible full-time employees and their dependents or risk employer shared responsibility penalties.
Employers subject to the mandate must also continue meeting ACA reporting requirements, including filing Forms 1094-C and 1095-C with the IRS each year.
Mental Health Parity
Group health plans and carriers are required to have a detailed written analysis, with plan-specific information on hand if regulators were to ask, to meet the requirements of the Mental Health Parity and Addiction Equity Act (MHPAEA).
Lumelight helps you meet these requirements through expert-led Mental Health Parity Analyses that turn a complex obligation into a manageable, in-depth report – so you can improve compliance and be audit ready.
Two solultions for Mental Health Parity support
Mental Health Parity Comprehensive Analysis
Comprehensive, audit-ready comparative analyses reports, expert-backed recommendations and a fully white glove service model
Mental Health Parity Assessment
A cost efficient snapshot of where their plan stands in compliance with the MHPAEA regulations
Downloads: Our MHP Solutions
If requested by a federal or state agency, the NQTL comparative analysis must be provided within 10 days. If requested by an ERISA plan participant, it must be provided within 30 days.
No. In May 2025, the Departments of Labor (DOL), Health and Human Services (HHS), and the Treasury announced a temporary non-enforcement period for the 2024 MHPAEA final rule while the rule is reconsidered as part of an ongoing lawsuit related to ONLY the 2024 Final Rules. That non-enforcement period lasts until a final court decision is issued and for 18 months afterward.
Yes. The pre-2024 MHPAEA framework remains in effect, including the 2013 final rule, related guidance and FAQs, and the written comparative analysis requirement for NQTLs added by the Consolidated Appropriations Act of 2021. The temporary non-enforcement period does not eliminate MHPAEA compliance, nor the testing obligations set in CAA21.
During the non-enforcement period, employers do not have to comply with the new fiduciary certification requirement, certain new definitions, the meaningful benefits requirement, or the requirement to collect relevant data which would have more specifically defined the timing of plan specific data. Nothing in the 2024 Final Rule affected the requirements for parity, testing of NQTLs and QTLs, or definitions established through regulation or department guidance prior to 2024.
If a plan is found to be non-compliant with MHPAEA, the employer may need to take corrective action, such as reprocessing claims or refunding participants where applicable. Non-compliant plans may also face penalties of up to $100 per day per affected individual, and separate ERISA penalties may apply if required disclosures or analyses are not provided on time. Penalties from regulatory audits may be accumulated in addition to monetary penalties established in a private right of action by a plan participant in court.
Employers should continue reviewing plan design and administration for parity compliance, work with carriers, TPAs, PBMs, and other service providers, and keep NQTL & QTL comparative analyses current and defensible. The pause is not a reason to step back from compliance readiness.
MHPAEA is a federal law that was passed in 2008 requiring group health plans offering mental health or substance use disorder benefits to provide those benefits in parity with medical and surgical benefits. This historic act continued the goal and evolution of the Mental Health Parity Act of 1996.
In practice, health plans must provide their mental health and substance use disorder benefits on substantially the same terms to be compliant - meaning plans cannot apply more restrictive barriers to coverage or treatment limitations to mental health and substance use disorder benefits than their medical/surgical counterparts.
MHPAEA applies broadly to group health plans and was amended to include individual health insurance coverage following the Affordable Care Act (ACA). MHPAEA does not apply directly to small group health plans but does indirectly have requirements related to Essential Health Benefits as part of the ACA amendments. Non-federal government plans had a longstanding exception for MHPAEA compliance that was sunset in the Consolidated Appropriations Act 2023, and these plans are now required to follow the same guidance.
No. MHPAEA does not require a health plan to offer mental health or substance use disorder benefits. But if a plan does offer those benefits, they must comply with parity and testing requirements.
There are two distinct types of limitations discussed when considering if a plan is in parity:
Quantitative treatment limitations (QTLs) are the number-based limitations such as visit limits or cost-sharing requirements.
Non-quantitative treatment limitations (NQTLs) are focused on how plans administer benefits in practice such as limitations related to prior authorization, provider network adequacy, and medical necessity standards.
The Consolidated Appropriations Act (CAA21) was built on the parity requirements of MHPAEA and created testing requirements related to non-quantitative treatment limitations (NQTLs). Prior to this additional testing requirement, plans only had testing parameters for QTLs, which largely missed the scope related to the MHPAEA requirements.
An NQTL comparative analysis is the written documentation a plan sponsor must maintain to show that NQTLs applicable to mental health and substance use disorder benefits comply with parity requirements. The analysis should demonstrate parity not only as written, but also in operation. This will involve plan specific data for testing.
No. The NQTL comparative analysis does not need to be submitted annually. But it does need to be current, kept on file, and ready to provide if requested by a federal or state agency or by plan participants under applicable timelines.
Nondiscrimination Testing
Protect the tax-advataged status of your plan
We handle the testing process end to end, from data gathering and eligibility determinations to reporting, remediation and secure documentation. We help employers stay compliant, save time and avoid costly surprises.
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Lumelight SIR is our featured SaaS analytics solution purpose-built for self-insured employers and advisors.
Experience a responsive, high-touch relationship that sets a new standard in benefits consulting.
End-to-end ACA Employer Reporting handled by experts who’ve never missed a filing — so you can focus on your people, not the paperwork.
iVerifyPro makes verification effortless for employers and employees alike, bringing accuracy, transparency and ease to every interaction.
Recent litigation has put employer governance practices under a brighter spotlight. Check-the-box fiduciary compliance is no longer enough. Today’s standards demand clear documentation, stronger oversight, and defensible decisions.
Lumelight’s Mental Health Parity Analysis is designed to produce comprehensive comparative analyses – we like to call it our parity book report!
Why Lumelight
Lumelight is an integrated workplace administration and compliance company. We support brokers and TPAs who help employers navigate complex areas like benefits design, compliance, and administration.
We’re not here to maintain the status quo – we’re here to transform an industry. Whether you’re a regulatory specialist, data analyst or client advisor, your role drives confidence and mitigates risk for organizations nationwide.
We handle the complexities of benefits compliance and administration, empowering you to focus on what you do best.