Document ID: OPS-SOP-011 | Version: 1.0 | Date: March 2026 | Owner: Operations | Status: Draft — Pending Leadership Review
OPS-SOP-011 — New Employer Group Onboarding
End-to-end process for bringing a new employer group onto the Unity self-funded health plan under the Unity Care Member Plan Master Trust.
Why this exists: Each new employer group is a separate ERISA plan with its own compliance obligations. Onboarding is not just a sales handoff — it requires legal setup, TPA enrollment, captive cell creation, compliance documentation, and member communication. This SOP ensures nothing is missed and every group goes live clean.
1. Onboarding Phases Overview
| # |
Phase |
Key Outputs |
Target Timeline |
| 1 |
Qualification & Risk Screening |
Gradient AI SAIL score, go/no-go decision |
Week 1 |
| 2 |
Plan Design & Rate Development |
Davies actuarial rate, plan design finalized |
Weeks 2–3 |
| 3 |
Legal & Trust Setup |
Adoption Agreement, CIF executed, protected cell created |
Weeks 3–5 |
| 4 |
TPA / PBM Enrollment |
Allied group setup, Employee Navigator feed, ProAct group added |
Weeks 4–6 |
| 5 |
Compliance Documentation |
SPD, SBC, participant notices distributed |
Week 6 (before go-live) |
| 6 |
Funding & Finance Setup |
Trust contribution amount set, first premium collected, GL codes assigned |
Week 6 |
| 7 |
Go-Live |
Group active in Allied, ProAct, Employee Navigator; members enrolled |
Plan effective date |
Timing: Cleanest go-live is January 1 (avoids deductible credit complexity). Mid-year starts are possible but require explicit handling of deductible transitions with the stop-loss carrier — confirm with SRS/HLRA before committing to a mid-year effective date.
2. Phase 1 — Qualification & Risk Screening
Step 1.1 — Collect Group Data
Sales collects census data: headcount by plan tier, age/gender distribution, state(s) of operation, current carrier and plan type, renewal date, EIN.
Owner: Sales
Due: Before Davies engagement
Step 1.2 — Gradient AI Risk Screen
Upload census to Gradient AI for SAIL score and predicted claims profile. Review top 5 high-cost drug flags and chronic condition distribution. SAIL score > 1.3 triggers mandatory Davies actuarial review before quoting.
Owner: Operations
BAA with Gradient AI must be on file before upload
Step 1.3 — Go/No-Go Decision
Operations reviews Gradient output. Groups with SAIL > 1.5 or active high-cost claimants above $100K predicted require Primary Approver (Dr. Greg) sign-off before proceeding. Document decision in Asana task.
Owner: Operations + Dr. Greg (if threshold exceeded)
3. Phase 2 — Plan Design & Rate Development
Step 2.1 — Engage Davies Group
Submit group census and Gradient AI report to Davies for actuarial rate development. Specify: plan tier(s) desired, network (PHCS for multi-state, Epic for Michigan), DPC integration (yes/no), HSA-qualified HDHP (yes/no). Davies SLA: [TBD] business days.
Owner: Operations
Step 2.2 — Plan Design Finalization
Operations reviews Davies rate output. Confirms plan design with employer group HR contact. Documents selected plan(s), contribution strategy (employer vs. employee split), and waiting period.
Owner: Operations + Employer HR
Step 2.3 — Rate Sign-Off
Operations Director approves final rate. For groups over 50 lives or with significant claims history: Primary Approver (Dr. Greg) reviews actuarial summary before proceeding.
Owner: Operations Director
4. Phase 3 — Legal & Trust Setup
Step 3.1 — Adoption Agreement
ERISA Legal Counsel (Dickinson Wright) prepares Adoption Agreement for the new employer plan under the Unity Care Member Plan Master Trust. Employer's authorized signer executes. Each employer is its own Plan Administrator under ERISA.
Owner: ERISA Legal Counsel + Employer
Must be executed before go-live
Step 3.2 — CIF Execution (ProAct)
Complete ProAct Client Information Form for the new group. Contact: Dolores Hynes (dolores.hynes@proactrx.com). Compliance reviews CIF before execution. Signed CIF enables PBM benefits for the group.
Owner: Operations + Compliance
Step 3.3 — Protected Cell Setup (Captive)
SRS (Melissa Hancock) coordinates creation of a protected cell under Unity Care Solutions – TN, LLC for the new employer group. Each employer gets one cell. Captive Counsel (Tony Greer / Kevin Doherty, Dickinson Wright) confirms structure.
Owner: SRS Captive Management + Captive Counsel
5. Phase 4 — TPA / PBM Enrollment
Step 4.1 — Allied Group Setup
Submit group enrollment to Kim James (kjames@alliedbenefit.com). Required: plan design summary, effective date, employer EIN, employee census, contribution amounts. Allied assigns group plan number. Confirm Employee Navigator feed scope (existing trust-level feed vs. new setup — pending Kim James clarification).
Owner: Operations
Submit 6 weeks before effective date minimum
Step 4.2 — Employee Navigator Eligibility Load
Confirm employer HR has access to Employee Navigator to manage eligibility. ADP is source of truth — verify ADP auto-feed to Employee Navigator is configured for the new group. Correct any eligibility discrepancies before go-live.
Owner: Operations + Employer HR
Step 4.3 — ProAct Group Enrollment
Confirm Dolores Hynes (ProAct) has added new group to PBM platform following CIF execution. Verify pharmacy benefit cards are ready for member distribution. Confirm Epic Health Pharmacy (NPI 1417665878 / NCPDP 2391580) is in ProAct network for DPC groups.
Owner: Operations
Step 4.4 — COBRA Setup (Varipro)
Notify Varipro of new employer group. Varipro triggered automatically via ADP for COBRA-qualifying events. Confirm group is in Varipro's system before first termination event.
Owner: Employer HR + Operations
6. Phase 5 — Compliance Documentation
Step 5.1 — SPD Production
ERISA Legal Counsel prepares Summary Plan Description (SPD) specific to the new employer group. SPD must reflect: correct plan name, employer as Plan Administrator, trust funding language, plan year, applicable benefits. SPD must be distributed to all eligible employees within 90 days of plan effective date.
Owner: ERISA Legal Counsel + Operations
Distribute within 90 days of plan effective date
Step 5.2 — SBC Production
Allied produces Summary of Benefits and Coverage (SBC) for each plan offered. Compliance reviews SBC against SPD for consistency. Distribute SBC to employees before enrollment (at least 60 days before plan effective date for new hires).
Owner: Allied (production) + Compliance (review)
Step 5.3 — Required Notices Package
Distribute all required participant notices:
- HIPAA Privacy Notice
- Medicare Part D Creditable Coverage Notice
- COBRA General Notice (Varipro distributes)
- CHIP Notice
- WHCRA Notice (mastectomy-related)
- Newborns Act Notice
- Exchange/Marketplace Notice
- NSA Patient Protection Notice
- MHPAEA Disclosure Notice
Owner: Employer HR + Operations
All notices distributed before or at plan effective date
7. Phase 6 — Funding & Finance Setup
Step 6.1 — Monthly Contribution Amount
Operations confirms employer's monthly trust contribution amount (based on Davies rate + stop-loss + admin fees). Documents in GL: Company = applicable entity, Branch = applicable location, GL 4xxx (premium income), Sub Account per employer group.
Owner: Operations + Finance
Step 6.2 — First Premium Collection
Collect first premium from employer before or on effective date. Employer submits to trust by first week of the month. Operations confirms trust bank account receipt before Allied escrow is funded.
Owner: Operations
Step 6.3 — Vendor Record Setup
If employer group's designated contacts differ from existing vendor list, create new vendor record in Acumatica per OPS-SOP-009 (Vendor Onboarding).
Owner: Finance
8. Phase 7 — Go-Live Checklist
| Item |
Confirmed By |
Status |
| Adoption Agreement executed | ERISA Legal | [ ] |
| CIF executed (ProAct) | Operations | [ ] |
| Allied group number assigned | Allied / Operations | [ ] |
| Employee Navigator eligibility loaded | Employer HR | [ ] |
| ProAct group active — pharmacy cards ready | ProAct | [ ] |
| Varipro notified | Operations | [ ] |
| Protected cell created (SRS) | SRS | [ ] |
| SPD distributed (or distribution plan confirmed) | Compliance | [ ] |
| SBC distributed | Compliance | [ ] |
| Required notices distributed | Employer HR | [ ] |
| First premium collected and in trust | Finance | [ ] |
| Allied escrow funded | Operations | [ ] |
| GL codes assigned in Acumatica | Finance | [ ] |
| BAAs confirmed for all PHI-touching vendors | Compliance | [ ] |
Go-Live Authorization: Operations Director must sign off on completed go-live checklist before the employer group's first claims can be processed. Any open items must be documented with a written remediation plan.
9. Post-Go-Live (30-Day Review)
30-Day Checkpoint
Operations conducts 30-day review: confirm Allied claims processing active, ProAct pharmacy claims active, Employee Navigator eligibility current, no enrollment discrepancies. Any issues escalated immediately to relevant vendor contact with documented follow-up.
Owner: Operations
Version History: v1.0 — March 2026 (initial draft). TBD items: Davies SLA timing, Employee Navigator trust-level feed confirmation (pending Kim James response), specific dollar thresholds for go/no-go SAIL triggers.
OPS-SOP-011 | Unity Care Solutions, LLC — Internal / Confidential
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