A successful risk management strategy requires a strong internal control environment. The risk control matrix (RCM) format emphasizes that strong and risk-oriented internal control environments are often optimized with automated/manual controls, depending on the situation.

An RCM provides an overview of different control objectives that organizations should take into consideration and the corresponding controls to safeguard the company against risks which may arise if not checked timely. Once customized to an organization, this document can help the user in assessing each control. The control assessment can then also be summarized to develop an action plan.

This document outlines risks and controls common to the “manage healthcare reimbursement accounts” aspect of the 3.5.7 Manage & Administer Benefits process in a risk control matrix (RCM) format.

Sample risks include:

• The HRA is not in compliance with Employee Retirement Income Security Act of 1974 (ERISA), the Internal Revenue Code (IRC)/Internal Revenue Service (IRS) provisions, Health Insurance Portability and Accountability Act of 1996 (HIPAA) or Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA)
• Non-discrimination testing is not performed, or the plan does not pass the test
• The HRA is not properly communicated to employees Ineligible employees are enrolled in an HRA
• The reimbursements provided to the employee are not eligible HRA reimbursements

This document can be used as a sample RCM and is not meant to be an exhaustive list of risks and controls. The KnowledgeLeader team will periodically update this RCM with new content. Organizations should select, update and modify the risks and controls included in this document to ensure that it reflects business operations.