Filing a Complaint - As an Employer - Insurance News Magazine

So I am in an unusual situation. I run the HR for a smedium company and by that I mean I am HR, IT, Customer Service, AP, AR and a few other things. We are large enough to have about 30 enrolled members in the plan, not large enough to have one person dedicated to running our program and nothing else. It is a level funded plan with one of the major insurers in the US.

The Insurer termed us due to non-payment. Except we did pay, they misapplied the payments to future invoices. This happened because we had credit memos for the current month so when we we applied them against the current month and paid the balance. The insurer applied the CM to the next month's invoice which made the current invoice appear short paid.

Example we paid, using round numbers:

April Invoice $10,000 April Credit Memo ($5,000) April Payment $5,000 May Invoice $10,000 May Payment $10,000

How the insurer applied it:

April Invoice $10,000 April Payment $5,000 April Balance Due $5,000 May Invoice $10,000 April Credit Memo ($5,000) May Payment $10,000 June Balance Due $5,000

On top of all this, they sent the warning of termination notice to an address that we have told them multiple times not to use (mail disappears there all the time) and I know they have our correct address as they send our invoices there. Once I got a copy of the termination notice (which did not have pay by date it just said "must be paid by the end of your grace period") I called them up to explain the situation and they said not worry about it, they saw the payments and they would talk to billing about getting the CM moved to the right invoice.

2 days later they termed us. Over the next day I called multiple times trying to clear this up. Both my broker and the insurer's advocates could see what I was seeing, admitted that payments were incorrectly applied and were working on talking to someone above them to get us reinstated.

I chose to just pay what their system said I owed so we could get reinstated. I confirmed this amount with their client advocate on the phone and when I was transferred to their phone payment portal was given a different (larger) amount to pay. I paid that. They said we would be back online the next day. Called the next day to confirm we were good and they said that there was an additional balance owed. I decided just to pay it and argue with them later. When they transferred me to the phone payment portal this time it said I had no balance owed. They had me pay online even though my total balance showed a negative amount at this point.

It took 3 days to get us back online. I'm not worried about the money side of things, I'll get that all worked out. I am furious for my employees. For their privacy I wont go into what some of them had to endure those 3 days without coverage but it was a lot.

Who can I file a complaint with about this? I was thinking our state's corporate commission? Is there a federal department I can file a complaint with? Would a complaint even do anything? I feel like I'm in a David vs Goliath situation. Or I just got shook down by a loan shark.