The administrator of a group health insurance plan reports the following:
1) An employee has informed us that his divorce has been finalized. At his request, we have changed him to individual coverage.
2) An employee was terminated effective September 1, 2012. We sent notice of his right to elect continuation coverage on September 7, 2012. The employee failed to make payment by October 7, 2012, so his coverage under the health plan was ended.
3) A new employee signed up for health insurance last month. He was treated for prostate cancer two years ago, so we told him that we would not cover any costs related to this condition for his first two years on the job.
4) We are charging employees who have family histories of serious health problems more for their premiums. It's only fair that potentially heavy users of medical care pay more for their health insurance.
5) Due to the high costs associated with child birth, we will require that employees pay an extra $200 deductible before any child birth expenses are covered.
6) To resolve disputes over health insurance claims expeditiously, we are now requiring that any disputed claims be appealed within 30 days of the denial. We will maintain continuity and expedite the handling of appeals by having the same individuals decide both initial determinations and appeals.
What, if any, legal problems do you see with how this health insurance plan is being administered? What should the plan administrator be doing differently?