Sample Audit

See what a Verq audit actually looks like.

Below are four findings from a real plan-document analysis, anonymized to “ACME.” Verq read the Summary Plan Description provision against provision — each finding cites the exact plan language in conflict, the claim that will expose it, its severity, and the question the plan sponsor needs to answer. The full report reads the entire document the same way.

Four Findings, As Delivered

Cost-sharing conflicts in one HDHP plan.

All four are High-severity contradictions in how deductibles, out-of-pocket maximums, and HDHP qualification are defined — places where the same claim can be paid or denied depending on which provision an adjudicator applies.

C-06Deductible design (embedded vs. aggregate)
High
AppearsOut-of-Pocket Expenses p.16 ('A Deductible applies to each Covered Person up to a family Deductible limit')
ConflictsSchedule p.4 note ('the FULL Family Deductible Amount Must Be Met Before The Plan Will Begin Paying')

The narrative describes an embedded per-person deductible with a family cap; the Schedule note describes a non-embedded aggregate family deductible. For a family of 4 on this HDHP, one member with $4,000 of claims either has met their deductible (narrative) or has not (schedule).

Example claimFirst large claim of the year for one member of a family-tier enrollment - the payable amount differs by thousands of dollars depending on which reading applies.
Question · suggested fixState one design. The schedule note (aggregate) matches typical family HDHP design; conform the narrative in the OOP section.
C-07Out-of-pocket maximum (individual vs. family aggregate)
High
AppearsOOP section p.16 ('the most the Covered Person pays each year')
ConflictsSchedule p.4 note ('Full Family Out-Of-Pocket Maximum Amount Must Be Met Before The Plan Will Begin Paying Covered Expenses In Full')

The narrative frames the OOPM as an individual protection; the Schedule requires the full family OOPM ($10,000 Tier 1 / $12,000 Tier 2) to be met before anything pays at 100%. With no embedded individual OOPM stated, a single family member could pay $10,000-$12,000 - above the ACA embedded self-only OOPM limit (~$9,200 for 2025) - a compliance exposure as well as an internal conflict.

Example claimOne catastrophically ill member of a family enrollment accumulating past $9,200 with the Plan still applying coinsurance.
Question · suggested fixAdd an embedded individual OOPM equal to or below the ACA self-only limit and reconcile the two provisions.
C-09Bariatric surgery cost share vs. HDHP structure
High
AppearsSchedule p.9: 'Bariatric Surgery - All Other Services: Paid By Plan 80%' (no deductible language); 'Informational Seminar: Paid By Plan After Deductible 100%'
ConflictsQHDHP declaration p.4 + IRS HDHP rules (only preventive care may be paid pre-deductible)

The 'All Other Services' bariatric row omits 'After Deductible,' implying first-dollar 80% coverage of surgery - which would disqualify the plan as an HSA-eligible HDHP. Meanwhile the low-cost informational seminar is paid 100% only AFTER deductible. The two rows read as if their deductible treatments were swapped.

Example claimBariatric surgical claim early in the plan year before deductible is met; also affects every enrollee's HSA eligibility if administered as written.
Question · suggested fixConfirm intended design (almost certainly: seminar deductible-waived, surgery after deductible) and correct the schedule.
C-10Foreign travel immunizations vs. HDHP qualification
High
AppearsSchedule p.10 & p.12: Foreign Travel Immunizations 'Paid By Plan After Deductible 100% (Deductible Waived)' Tiers 1-2
ConflictsQHDHP declaration p.4; Preventive/Routine Care glossary definition p.108 (QHDHP preventive = IRC 223(c)(2)(C))

Travel immunizations are not ACA/IRS-preventive. Paying them at 100% with the deductible waived under a purported Qualified HDHP contradicts the plan's own QHDHP definition and threatens every participant's HSA eligibility. (The 'After Deductible ... (Deductible Waived)' phrasing is also self-contradictory - see C-16.)

Example claimYellow fever/typhoid vaccine claim before deductible met; downstream: IRS challenge to HSA contributions for all enrollees.
Question · suggested fixEither apply the deductible to travel immunizations or obtain tax counsel sign-off; fix the row.
How Findings Are Prioritized

Every finding carries a severity.

Severity reflects risk — how often a claim hits the provision, the dollars and member impact at stake, and how defensible the outcome is — not which category the finding falls in. A silence can be High; a contradiction can be Low.

High
Fix at or before renewal. A claim that recurs on this plan will hit this provision, and the wrong answer is costly, clearly incorrect, or hard to defend on appeal — the kind that drives overpayments, reversed denials, or a stop-loss carrier declining reimbursement.
Medium
Put on this year’s amendment roadmap. A real conflict, but narrower — it affects a subset of claims, the dollars are moderate, or the plan’s intent is clear enough to administer today. Defensible for now, exposed over time.
Low
Roll into the next routine amendment. Technically wrong or unaddressed, but the triggering claim is rare and low-dollar. Worth cleaning up to keep the document tight; not worth holding a renewal over.
Take It With You

Download the full sample audit.

The complete 28-page report — all 75 findings across contradictions, ambiguities, and silences, with the same citations, example claims, and severity key. Built to be forwarded: bring it to your next client or stewardship meeting.

Full sample audit — cover
Download the full sample (PDF)

Real analysis, anonymized to “ACME” · 28 pages · 75 findings

Your Clients’ Plans

Want this run against a plan you advise?

Send us one plan document — client, prospect, or a public one — and we’ll run the full audit with you and walk through the findings live.

Talk to the founders — 20 minutes