B-115338, MAR. 21, 1960

B-115338, MAR. 21, 1960

TO HONORABLE ROGER JONES, CHAIRMAN, UNITED STATES CIVIL SERVICE COMMISSION:

THE LETTER DATED MARCH 18, 1960, FROM THE EXECUTIVE DIRECTOR OF THE COMMISSION, REQUESTED GENERAL ACCOUNTING OFFICE APPROVAL OF A HEALTH BENEFITS REGISTRATION FORM. THIS FORM IS CLASSIFIED AS A STANDARD ACCOUNTING FORM BECAUSE IT IS TO BE USED BY ALL FEDERAL AGENCIES AND WILL SERVE AS A WRITTEN DOCUMENT FROM AN EMPLOYEE TO AUTHORIZE, CHANGE, OR TERMINATE PAYROLL DEDUCTIONS FOR A HEALTH BENEFITS PLAN.

WE HAVE ON SEVERAL OCCASIONS DURING THE PAST THREE WEEKS, AFTER SOME INFORMATION ON THE PLAN WAS INFORMALLY MADE AVAILABLE TO OUR STAFF, EXPRESSED TO OFFICIALS IN THE BUREAU OF RETIREMENT AND INSURANCE OUR RESERVATIONS REGARDING SOME OF THE PROCEDURES BEING DEVELOPED FOR THE HEALTH BENEFITS PROGRAM. WE EXPRESSED CONCERN THAT ADMINISTRATIVE COSTS MAY BE INCREASED UNNECESSARILY BY THE NEEDLESS PROCESSING OF PAPER AND THE DUPLICATIVE RECORDS AND FILES THAT WILL BE MAINTAINED UNDER THE PROPOSED PROCEDURES AS WE UNDERSTAND THEM.

WE HAVE PREVIOUSLY EXPRESSED INFORMALLY OUR CONCERN REGARDING THE FOLLOWING MATTERS:

1. WE DO NOT BELIEVE THAT THREE COPIES OF THE REGISTRATION FORM ARE NECESSARY. WE HAVE MADE MANY INQUIRIES AND HAVE FOUND NO DEMONSTRABLE REASON WHY THE PERSONNEL OFFICE OR THE SO-CALLED ,EMPLOYING OFFICE" SHOULD HAVE A COPY. IF THIS COPY IS ELIMINATED, THERE WILL BE A SAVING OF (A) PRINTING AND PAPER COST FOR THE INITIAL PRINTING OF 4,250,000 SETS OF THE FORM, AND (B) THE LARGER RELATED LABOR COSTS OF FILING SUCH REGISTRATION FORMS IN PERSONNEL FOLDERS.

2. THERE IS DOUBTFUL NEED FOR ALL CARRIERS TO HAVE A COPY OF THE REGISTRATION FORM. FROM THEIR COPY OF THIS FORM, WE UNDERSTAND, THE CARRIERS WILL SET UP "IN FORCE" FILES ON ABOUT 2,000,000 EMPLOYEES. THE GOVERNMENT WILL ALSO HAVE AN "IN FORCE" FILE IN THE FORM OF THE INDIVIDUAL'S PAY RECORD ON WHICH PAYROLL DEDUCTIONS WILL BE SHOWN. THE PAYROLL RECORD MUST BE MAINTAINED, BUT THE COMPANION RECORD TO BE KEPT BY THE CARRIER IS DUPLICATIVE AND WE BELIEVE IS NOT NECESSARY TO MOST CIRCUMSTANCES UNDER THE NEW PROGRAM. WE BELIEVE THAT THE EMPLOYER AGENCY CAN PERFORM THE ACTION OF CHECKING "INSURED STATUS" AS THE CLAIMS ARE PROCESSED. BY ELIMINATING THE CARRIERS' FILES AND RECORDS REGARDING "IN FORCE" INFORMATION, IT WILL BE UNNECESSARY TO PRINT AND PROCESS THE INITIAL CARRIERS' COPY OF 4,250,000 SETS OF FORMS AND THE DUPLICATIVE RECORD KEEPING EXPENSE IN THE CARRIERS' OFFICES CAN BE ELIMINATED. SUCH CARRIER EXPENSE WOULD, AS YOU KNOW, BE BORNE BY THE GOVERNMENT AND THE EMPLOYEE.

3. IF THE CONCEPT IN PARAGRAPH 2 IS ADOPTED, THEN THE PROBLEM OF RECONCILING RECORDS KEPT WITHIN THE GOVERNMENT WITH THOSE KEPT BY THE CARRIERS WILL BE ENTIRELY ELIMINATED.

4. IF THE CONCEPT IN PARAGRAPH 2 IS ADOPTED, THEN ONLY THE ORIGINAL OF THE REGISTRATION FORM IS NEEDED, THE EXPENSE OF TWO SETS OF CARBON FOR 4,250,000 SETS OF FORMS IN THE INITIAL PRINTING IS ELIMINATED, THE EXPENSE OF THE CARRIERS IS REDUCED, AND THE FILING COSTS IN THE GOVERNMENT PERSONNEL OFFICES IS ELIMINATED.

5. IF THE CARRIER IS NOT FURNISHED THE REGISTRATION FORM, THEN STANDARD IDENTIFICATION CARDS CAN BE PREPARED AND ISSUED IN THE FEDERAL AGENCIES AND THE EMPLOYEES WILL RECEIVE PROMPT EVIDENCE OF THEIR ENROLLMENT. SUCH CARDS SHOULD IDENTIFY THE PLAN AND PAYROLL OFFICE INVOLVED.

6. AS STATED TO YOUR OFFICIALS, WE BELIEVE THE REGISTRATION FORM COULD BE SIMPLIFIED AND A PUNCH CARD USED (WITHOUT COPIES). SUCH CARD WOULD FACILITATE PROCESSING IN THE PAYROLL UNITS THAT NOW USE PUNCH CARDS. HOWEVER, COMMISSION OFFICIALS INDICATED THAT THIS SUGGESTION WOULD NOT BE FEASIBLE AT THIS TIME.

IT IS RECOGNIZED THAT THE COMMISSION IS UNDER DURESS TO ACCOMPLISH NUMEROUS ACTIONS ON A TIMELY BASIS SO THE HEALTH PROGRAM WILL BE ASSURED OF STARTING IMMEDIATELY AFTER JUNE 30, 1960. WE BELIEVE THAT THE RECOMMENDATIONS MADE IN THIS LETTER CAN BE IMPLEMENTED VERY QUICKLY, AND WITHOUT CAUSING ANY DELAY.

HOWEVER, IN ORDER THAT YOU MAY HAVE FULL DISCRETION IN THE MATTER OF DECIDING WHETHER TO ACCEPT THE PROPOSALS OFFERED IN THIS LETTER, WE HAVE APPROVED THE FORM AS SUBMITTED.

THE HEALTH BENEFITS REGISTRATION FORM HAS BEEN ASSIGNED STANDARD FORM NO. 2809, AND IT WILL BE RECOGNIZED IN THE GENERAL ACCOUNTING OFFICE MANUAL IN 6 GAO 5000. PLEASE SEND US FOUR COPIES OF THE REVISED FORM WHEN IT IS PRINTED.