[UCRDBR] HealthEquity – Health Savings Account Contribution Return Due to CIP Failure

[Departmental Benefits Representatives]

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October 13, 2020

To:          Department Benefits Representatives (DBRs)
From:      HR Benefits Office
Re:          Extension of UC Contribution for Benefits During Temporary Layoff
Due to the USA Patriot Act, all financial institutions including HealthEquity (HEQ), custodian of UC’s Health Savings Accounts, are required by federal regulations to implement a Customer Identification Process (CIP) to prevent financing of terrorist operations and money laundering. As a result, UC and HEQ have established a procedure and developed steps taken to ensure HEQ is able to verify a customer’s identity.

The following customer information is used to check the account holder’s identity and by HEQ to validate against their data system. The account holder passes the CIP process when certain combinations of the data below match. Employees who fail the CIP process are required to submit additional documentation before their accounts can be established.

·     First and Last Name

·     Residential Address

·     Date of Birth

·     Social Security Number

·     Home or Business Phone
There are various reasons why an account holder may fail the CIP process. The following are examples of possible scenarios that may prevent an individual from passing the CIP process:

·     Name matches the Office of Foreign Assets Control registry listing

·     Social Security Number (SSN) was issued prior to date of birth

·     SSN registered as deceased

·     Day, year or month of birth does not coincide with SSN

·     SSN does not coincide with name and address

CIP is performed for the account holder at the time of enrollment in the Health Savings Plan (HSP) or upon receipt of the first contribution from UC by HEQ. During the application process, HEQ may collect additional forms of identification from account holders. HEQ notifies the member up to three times by mail and/or phone. A sample of the HealthEquity Customer Identification Process Failure Notice<https://hr.ucr.edu/document/healthequity-customer-identification-process-failure-notice> is being included for your review.

The accepted forms of identification include:

·     Valid U.S. Driver's License, Valid U.S. Probationary Driver's License, Valid U.S. Learner’s Permit, or Valid U.S. State Non-Driver ID Card

·     Valid U.S. Passport or Valid U.S. Passport Card

·     Social Security Card or Social Security Letter

·     Individual Tax Identification Number Card or Individual Tax Identification Number Letter

·     U.S. Military ID

·     Alien Registration Receipt Card or Employment Authorization Card Form I-766

·     Permanent Resident Card or Temporary Resident Card

·     Green Card or Non-Resident Alien Card or Immigrant or Non-Immigrant Visa

·     Credit Card or Complete Credit Card Statement

·     Most Recent Property Tax Bill
Health Savings Account (HSA) contributions are held in a temporary account and are unavailable until the CIP has been successfully completed. In previous years, HEQ held on to these funds indefinitely (mirroring what Fidelity does with the retirement savings plan funds).

What has changed

This year, HEQ is now instructed to close out the account if the account holder is unable to supply the proper forms of identification within 60 days from receipt of initial contribution. If the CIP is not completed, HEQ will return the funds as follows:


·     All UC contributions to the HSA are returned to UCPath

·     Employee contributions designated for previous years are returned to the employee directly

·     Employee contributions for the current plan year are remitted to UCPath for its eventual return to the employee

If employees wish to establish another account, they will be required to resubmit a new application through the appropriate enrollment method and provide identification at that time.


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