Case Study

Challenge: The U.S. Department of Labor Employee Benefits Security Administration (EBSA) wanted statistical and analytical expertise to support legal investigations into employer-sponsored benefits.

EBSA protects the pension, health, and other benefits of over 150 million Americans across more than 6 million private-sector employee benefit plans. EBSA ensures beneficiaries’ protection by investigating plans and enforcing compliance with all regulations and obligations. The broad scope of this task necessitates balance: it requires the agency to maximize its resources by scrutinizing as many plans as possible without losing the integrity of each investigation’s breadth and depth. Moreover, each investigation must maintain a high level of statistical rigor to ensure that plan beneficiaries are sufficiently looked after.

Solution: Since 2014, the Summit team has been instrumental in supporting the Office of Enforcement at EBSA. Summit currently partners with the Division of Economic Research and Analysis (DERA), and our team’s expertise is felt across an array of enforcement initiatives.

Given that a large portion of EBSA’s efforts are focused around access to healthcare, Summit deployed a team of health claims data experts to support and teach EBSA staff about the nuances of these data as well as how they can be analyzed to deliver actionable results. We help EBSA investigators disentangle the details from health data and extract the insights needed to detect violations in areas such as emergency room visits, preventive services (e.g., COVID vaccines), and access to mental health services. The Summit team hosts impromptu consultations with investigators and legal experts from EBSA as well as maintains a help desk for regular access. For particularly complex investigations, Summit completes the data analysis ourselves and presents the results to investigators and legal counsel.

In addition to our specialized knowledge in healthcare data, Summit also provides broader statistical support. This support may come in the form of statistical sampling for a selection of employer-sponsored plans that need review or hypothesis testing to compare outcomes across different types of plan beneficiaries. Each option helps EBSA ensure parity among plan participants without overexerting itself and stretching resources too thin.

Certain types of health and financial data analyses are routinely conducted for EBSA investigations. For these efforts, Summit designs and maintains a series of tools and applications that EBSA investigators can access to automatically generate results, saving the agency precious time and resources. Summit has previously developed tools to investigate such topics as timeliness of claims processing, maximum out-of-pocket accruals, and parity for mental health services according to the Mental Health Parity and Addiction Equity Act. We work with DERA staff to identify and develop new tools each year.

Summit recognizes that these efforts are only sustainable so long as EBSA staff are well trained on the concepts and approaches required to complete investigations. Therefore, Summit hosts a series of training sessions each year geared toward the building blocks of healthcare, financial, and statistical analyses. These sessions support new investigators learning these ideas for the first time as well as seasoned experts who must adapt to the ever-changing landscape of employer-sponsored benefit plans. Hosted several times throughout the year, Summit’s trainings vary from one-on-one sessions to broader presentations attended by hundreds of investigators.

Result: Due to the continued support from the Summit team, EBSA has been able to expand its reach and protect employer-sponsored plan beneficiaries. These investigations often result in beneficiaries’ compensation for past wrongdoing, mitigation of persistent or ongoing issues, and prevention of future violations from the plans or providers.

Our expertise, tools, and training sessions touch all aspects of EBSA’s work. From scoping and planning investigations to analyzing data to helping find a just resolution with legal counsel, we support EBSA every step of the way. As the landscape for healthcare and retirement benefits continues to change, Summit will help EBSA adapt and protect the benefits for which employees are entitled.