Bureau Monitoring

2022 Workers’ Compensation Financial Data Calls: What You Should Know

by Chris Curry

The 2022 reporting season is underway for workers’ compensation financial data calls to the National Council on Compensation Insurance (NCCI) and independent state workers’ compensation rating bureaus. This is a very busy season for reporting analysts and data quality staff who will need to aggregate, validate, and submit all the policy and claims financial detail for the year countrywide.

While there are very few changes in the calls and data capture this year, it remains important to keep tabs on updates from the bureaus. For instance:

  • The New Jersey rating bureau has issued a data call to collect COVID-19 pandemic data.
  • The California rating bureau is requiring the reporting of premium detail by month instead of year, starting with 1st Quarter, 2022.
  • Other rating bureaus have updated their front-end and back-end processes. For instance, NCCI updated its system interface slightly, and the NCCI template for uploading data into the financial call system has also been modified.

These are not significant changes but could affect your workflow and timing.

Companies should use the financial call reporting season as an opportunity to closely review their data collection, aggregation, and submission processes for weaknesses and to make updates accordingly.

Closer scrutiny

The rating bureaus have been implementing more edits and cross-reporting reconciliations in recent years and are therefore catching more data reporting inconsistencies. The risk of incomplete or incorrect data has always been an issue for carriers—deadlines are strict and penalties for late reporting can be substantial. With even greater scrutiny from the rating bureaus, carriers are under even more pressure to ensure accurate, on-time reporting.

Statistical and financial data analysis and reporting are non-revenue-generating tasks that can consume precious bandwidth. Timely, accurate reporting draws time and attention from staff whose focus is generally directed toward high-value tasks. As a result, many carriers opt to partner with reporting specialists like Perr&Knight. Delegating reporting to insurance data services experts alleviates the stress and seasonal time crunch of accurate data preparation and submission.

Common reporting problems

During decades of providing insurance data services for workers’ compensation carriers across the nation, we have seen companies run into issues that can complicate reporting and compromise accuracy. Here are some of the most common pitfalls companies experience:

  • Calculating designated statistical reporting (DSR) premium levels—specifically, applying rating modifications and loss-cost multipliers correctly—can be challenging. Different policy types, rating bureaus, and loss-cost adoptions can create different methods of calculation. Lack of experience with this calculation can result in incorrect DSR premium level reporting.
  • Difficulty understanding how deductible programs work. Some portions of deductible policies are not reported to the bureau. For example, large deductible policies and claims must be excluded from most calls, whereas small deductible policies are generally included.  Pay close attention to whether premiums and claims are reportable net of the deductible versus gross of the deductible when reporting. Plenty of carriers get tripped up here.
  • Issues related to comparisons between financial data and policy/claims data. Disconnects between unit statistical reporting (detailed audited premiums and claims reporting) and financial data calls will cause problems. Companies must uncover discrepancies and clear up edits in financial-to-statistical data reports before submission or risk penalties.

A head-start on accuracy

Working with experienced third-party support teams for reporting also ensures the cleanliness of data before submission to the rating bureaus. Before the Perr&Knight teams even submit data to bureaus, we aggregate all the required information and perform reconciliations to a company’s NAIC Annual Statement. If there is a difference, we work with our clients to resolve the error or create a detailed explanation for the bureau.

Offloading reporting to the experts at Perr&Knight protects against inaccuracy by ensuring all state-specific updates and requirements are taken into consideration. Our financial call reporting specialists make sure all the bases are covered.

The 2022 financial data calls show reporting is becoming more robust as it is further digitized. Data is under closer scrutiny and edits are stricter than ever. For many companies, working with a third-party insurance data services partner is the most efficient, cost-effective solution to ensure data accuracy and receive added support for this essential and resource-consuming task.

Offload this year’s NCCI data call to the reporting specialists at Perr&Knight. Contact us today to learn how we help.

A Smarter, More Efficient Way to Manage Adoption Filings

by Karen Barrett Daley

Tracking and managing changes to bureau material has long been a time-draining process for property casualty insurance company staff. When we released Bureau Monitor, a subscription service housed within our StateFilings.com system, our aim was to make our clients aware immediately if there were updates required for their bureau based products. By centralizing loss cost, rule and form circulars for all bureaus and lines of business in a single location and then generating automatic notifications explaining the impact on our clients, the system was able to relieve in-house compliance teams from managing the minutiae of circular tracking. It also provided a crucial first line of defense against compliance violations.
We’ve now taken this process one step further. By combining our useful bureau monitoring service with the filing capabilities built into StateFilings.com, we’re launching our newest service: Bureau Maintenance. It’s a single, automated solution for keeping your state filings current.

How Bureau Maintenance Works

Our team of filing experts monitor the circulars impacting loss costs, rules and forms released by the various rating bureaus, including the Insurance Services Office (“ISO”) and the National Council on Compensation Insurance (“NCCI”). We publish these circulars to Bureau Monitor, which then generates a notification if your company is required to file an update to your product based on your specific adoption profile. Using Perr&Knight’s StateFilings.com platform, our state filings experts will submit the change on your behalf, eliminating your risk of falling behind or slipping out of compliance. Using an online dashboard, you’ll be able to see in real-time which adoptions have been filed and which are pending submission.

Why automate your state filings?

As technology becomes faster, smarter and more secure, it makes sense to outsource to machines the tasks that require lower levels of human discernment. Standard bureau adoption filings are an excellent function for automation because the process requires the management of numerous minor but important details, instead of critical decision-making, which is better suited for people. This approach frees up time and attention for your teams to focus on more complex product compliance tasks. Bureau Maintenance is simply that—maintaining bureau-based products in real-time, rather than being forced to play major catch up down the road.
Read more: Expert tips to speed up state filing approvals.

Updates that matter to you

Because your Bureau Maintenance profile will be unique to your company, you’ll be alerted to only those filing requirements that apply to you. Based on the lines of business you follow, your adoption status, and programs in the states where you operate, you’ll know exactly which circulars need to be adopted via a state filing. This eliminates the need for manual scrutiny of each published circular by your staff.
Even for companies that don’t seem overwhelmed by filing updates, Bureau Maintenance can protect you from the risk of non-compliance. For example, affiliating with an auto-adopt or file-on-behalf status will likely minimize your number of filings. However, in cases of the states that prohibit auto-adoption, you are required to pay attention and submit your filings accordingly. Bureau Maintenance will ensure that nothing falls between the cracks.  On other hand, if you have the opposite bureau affiliation profile — i.e. you have adopted loss costs, rules or forms from a particular bureau at single point in time and don’t intend to make updates— you could still be on the hook for mandatory changes if the bureau adjusts its materials based on regulatory changes. Once again, Bureau Maintenance will make sure that you keep current and compliant.
Read more: How to streamline bureau monitoring.

Maximize your resources

We deliberately created a competitive pricing structure for Bureau Maintenance because this ancillary service is designed to work in conjunction with your in-house teams. As a result, offloading the time-consuming tasks to automated software will increase the efficiency of your human capital on the revenue-generating tasks that forward your business objectives and competitive advantage.
Bureau Maintenance takes away the final piece of worry regarding the management of bureau adoption state filings. By letting dedicated software pay non-stop attention to bureau updates that impact your filings, you reduce the risk of overloading your internal teams or slipping into non-compliance. In an era where more and more businesses are capitalizing on the advantages of improved technology, automating these simple tasks just makes sense.

Contact Perr&Knight today to learn more about how Bureau Maintenance can eliminate your state filings and bureau monitoring headaches.

Entering the Workers Compensation Line of Business: What You Need to Know

by Michelle Freitag

Workers Compensation (“WC”) filing activity is increasing as more and more insurance companies and InsurTech providers roll out WC products to round out their insurance product offerings. However, many of these companies possess only a limited understanding of the scope of what is involved in WC insurance product development. In the rush to market, they overlook important requirements that negatively impact the state filings process and stall their product’s release.
Before your company proceeds full steam ahead with your WC product, here are some important considerations to keep in mind.

Multiple rating bureaus and their products

Before an insurance company can begin writing WC they must affiliate with the appropriate rating bureau. The National Council on Compensation Insurance, Inc. (“NCCI”) is the designated statistical agent and rating bureau in 37 jurisdictions.  The remaining 14 jurisdictions have either licensed an independent state-specific rating bureau or provide workers compensation through a monopolistic state fund.  Companies will need to affiliate with the appropriate rating bureau before filing their product with a state.
Your team must be aware of the product offerings of the various bureaus in order to ensure you file everything you need. In most jurisdictions, the WC core product is already filed on your behalf and you are tasked with providing specific supplemental information. However, the amount of supplementation varies by state. It’s important to know exactly what information you’ll be responsible for submitting.  For example, schedule rating is allowed in Connecticut and is filed on the company’s behalf by NCCI in that state.  NCCI is also the rating bureau in Illinois and Illinois allows for schedule rating, but it’s not filed on the company’s behalf by NCCI.  So, if a Company wants to use schedule rating in Illinois, they must specifically file a schedule rating plan.

Creating a countrywide product is complicated

Many insurance companies think that they can develop a product that meets the requirements for a handful of states, then simply expand coverage to include other states. When it comes to WC, state filings just aren’t that simple. With so many state nuances that require careful navigation, it’s virtually impossible to create a countrywide product that will satisfy every jurisdiction.
Some jurisdictions have required mandatory offerings (ex. risk control services and small deductibles) that may or may not need to be filed with the state. Some states don’t allow schedule rating for WC. Others require drug-free workplace program credits. Mistakenly thinking you can use the same product features everywhere will slow down your state filings process.
Bringing a product to market is never as easy as it seems, particularly when it comes to WC. Unforeseen delays and close regulatory scrutiny are simply par for the course. Perr&Knight has assisted numerous clients in getting their WC products to market. We are knowledgeable about each state’s requirements, limitations and restrictions. For more information about how we can help you achieve successful and streamlined Workers’ Compensation insurance product development, contact our offices today.

Expert Tips to Speed Up State Filings Approvals

by Perr&Knight

by Courtney Hughes, JD, CPCU, Manager, Regulatory Compliance
There are many reasons to try to expedite your state filings approvals. Whether you are changing rates, launching a new product, or updating a product to meet your customer’s needs, speed is critical in today’s immensely competitive insurance market.
Obtaining approvals quickly is a huge competitive advantage. Bureau filings, in particular, can be especially difficult to keep up with, because new circulars and info come out every day. For ISO, AAIS or other bureau-based products, staying on top of the frequently-changing requirements gives you a significant edge over companies that are lagging behind.  For independent products, it’s all about getting your new product or coverage to market before your competitors.
Speedy approvals can help lighten your workload by ending that process sooner, allowing you to focus your attention on the next big project. Here is a list of useful tips that can help you avoid the stumbling blocks that slow down state filings approvals.

Get prepared before submitting.

Thoroughly research the filing requirements for the states in which you plan to file well in advance of your target filing date. Understanding and complying with these requirements up front avoids the issue of states coming back to you requesting that you correct avoidable procedural issues, such as providing the wrong edition of a required transmittal document. Issues like this can delay your approval by weeks.
You can obtain current information from state department of insurance (DOI) websites, SERFF or your insurance consulting services partner. For bureau adoption filings, make sure you have collected and organized all the information from the circulars before you begin so you can provide the states with all necessary pieces of information, like the ircular number, bureau filing number and state filing number.

Submit compliant, complete, and consistent material,

Reviewers can’t approve filings that are not in compliance with their state laws. Every time they kick your filing back with questions, it slows down the time to approval. Make sure that your product development staff and actuaries, or your insurance consulting services partner, confirm that the forms, rates, and rules you plan to submit are in line with state requirements. Not all objections or issues can be prevented, but where possible, anticipate the state’s requirements for your product and try to answer any expected questions in the explanatory memorandum you submit with your filing.
Completed material also goes a long way in speeding up approvals. For example, some states require a form usage rule in your manual for each form submitted. By providing the form usage rules in your manual at submission, you avoid the objection coming in and having to scramble to create the form usage rules and get internal stakeholder approval before the deadline.
Finally, consistency is important because it makes your filing easier to review so it is more likely to be approved quickly. After the forms, rates, rules, and supporting documentation have been developed, take some time to review them carefully. Make sure, for example, that your program name is consistent between the documents, or that your explanatory memo is not referring to a form you decided not to file.

Submit your objection responses ASAP, but always before the due date.

DOIs like to speed up their workflows too, so give them everything they need to close the filing as soon as it becomes available. If you received an objection with a due date in a week, submitting your response by that deadline is good, but submitting it within two days is even better. And always be sure to respond to the state by the due date they set. If you know you will not be able to respond by that due date, contact the DOI analyst and request an extension. If you miss a due date, there’s a good chance your filing will be disapproved or rejected, putting you back to square one.

Have a plan for objection responses and status checks.

Staying on top of filings once they have been submitted is challenging because there are lots of moving pieces to manage. You need to keep track of DOI questions and their due dates and ensure that you are consulting the right internal teams for answers. You will also want to keep track of when filings have been submitted so you know when it is time to check in with the DOI to see how their review is progressing. Before you submit, you should have a plan in place for how you will keep all of the outstanding filings organized. 

Use tracking software designed for insurance.

When you have a clear insurance software tracking system in place instead of a hodgepodge of spreadsheets, databases, SharePoint, and/or emails, you can easily keep track of DOI questions and due dates. The more seamlessly you can manage the questions the reviewer throws at you, the sooner you can get the ball back into their court.

Avoid double work.

Review your internal systems to make sure they’re not slowing you down. If you use an ad hoc tracking process, you are likely doubling up on data entry, entering the information once in SERFF and again in your company’s tracking system. This can cause delays in your ability to respond to reviewer questions or use the time of valuable internal resources who could be focused on the next project. Evaluate your company’s state filings process, looking for areas you can streamline. Working with an outside insurance consulting partner can help reveal inefficiencies that you might overlook.
There are never any guarantees with state filings approvals. But preparation, planning, and organization can mean the difference between a product that is launched on time, and one that gets lost in a maze of questions and confusion.

If you have questions about strategies to speed your company’s state filings approvals, our team of insurance experts can help.

Streamline Bureau Monitoring and Stay on Top of Compliance

by Courtney Hughes

Keeping up with bureau changes is a critical aspect of compliance for every insurance company. Depending on the states and lines of business your company writes, your organization might need to track form, rule, and loss cost changes from just a handful–or more than two dozen–rating and advisory organizations per month. Some bureaus, such as Insurance Services Office (ISO), post twenty or more circulars per day. Other bureaus post updates only once every few months. For the frequently-posting bureaus, simply managing the onslaught of updates can pose a challenge. For the less-frequently-posting bureaus, there is a higher risk of forgetting to check the bureau’s site and take action based on their updates.
Adding to the challenge is the process of determining what form, rule or loss cost changes you can implement without filings and which you need to file to be able to use. That depends on three things: whether a state allows the bureau to file on behalf of companies, whether your company has given filing authority to the bureau, and the filing law in that state for that line of business. Even if the new or changed bureau material is filed on behalf of your company, you need to ensure the changes are made in your policy writing and rating systems by the effective date.
No matter the number of bureaus the company tracks, insurance companies face the same challenge: avoiding a breach of compliance by keeping up with bureau changes, including systems changes and the state filings needed to adopt or non-adopt based on state filing law.
As providers of insurance consulting services for companies in all lines of business and in all fifty states, we have seen first-hand how companies fall behind and the chaos it causes when their in-house regulatory compliance services cannot meet their company’s needs.
Here are some helpful insights that can assist your company in wrangling administrative work so you can focus on managing your business.

The challenge of maintaining ever-changing information

The sheer amount of time it takes to mine the bureau sites to compile and analyze relevant information can quickly overwhelm in-house regulatory compliance departments. After gathering information from the bureau sites, compliance staff may need to discuss whether the company would like to utilize the bureau’s changes with key stakeholders. Based on that discussion, they outline the necessary steps for filing to adopt or non-adopt, and request the needed system changes. To track these steps, many insurance carriers rely on ad hoc systems of spreadsheets and emails, thereby risking the accuracy of their information and creating the potential for forgotten or delayed state filings.

Lighten the load with a dedicated bureau monitoring service

To save time, maintain accuracy and streamline the bureau-based state filings process, we recommend outsourcing bureau monitoring and state filings to companies that provide insurance consulting services. These insurance experts monitor bureau changes, can recommend a detailed course of action depending on your company’s lines of business and the states in which you operate, and complete the necessary state filings.
Automating much of the minutiae of monitoring and tracking bureau circulars can relieve your regulatory compliance department of massive amounts of administrative work, freeing them up to focus on big-picture problem-solving.

Use specialized bureau monitoring services developed by insurance experts

Perr&Knight developed Bureau Monitor, a subscription service housed within our StateFilings.com system, specifically to streamline this process. Our compliance analysts review, track and organize circulars for all bureaus and lines of business and put them in one central repository. We keep your account up to date with relevant bureau information and the system keeps you informed in clear, concise terms as to which updates apply to you and what your company needs to do to use the update, including whether your company needs to make any state filings.

Reduce administrative work for faster decision-making and gain time to focus on what matters

Regulatory Compliance departments are often kept busy with compliance issues and filings to make desired changes to your company’s unique products or features. Streamlining the bureau update process enables your compliance department to focus on what matters most to your company while keeping the company in compliance and up to date with key industry changes.  
Being able to see status and recommendations for all circulars at a glance significantly improves your efficiency when trying to keep up with the furious pace of insurance bureaus, especially those that require multiple filings per month. If a filing is required to use a bureau update, systems like Bureau Monitor lighten the load because the information your filings staff needs (like the bureau filing number and effective date plus a link to the circular on the bureau’s website) is all in one place. Your compliance staff can also use automated bureau monitoring systems to know which bureau updates will require changes to policy writing and rating systems and indicate the necessary filing has been submitted or approved.
Internal compliance departments can get quickly overwhelmed by the onslaught of changes from frequently updated bureaus, or might simply forget to update material and systems based on updates from the bureaus that post circulars infrequently. Whether you choose to maintain a homegrown system or use an automated bureau monitoring service that augments your team, the most important thing is to maintain a clear, documented process that ensures that no deadlines are missed and all stakeholders have access to the information they need.
If you would like to discuss Bureau Monitor, StateFilings.com or any of the regulatory compliance services or expert insurance consulting services offered by Perr&Knight, call us at (888) 201-5123 ext. 3 and we’ll gladly provide a solution that works best for your business.