Key Things to Know Before Getting Into the Insurance Business

Authors: Mark Nawrath, PMP, MBA, and Dean Ferdico
Today’s technology advancements have the potential to transform businesses across industries. Aging systems and increased demand for new and innovative products mean insurance is ripe for disruption, but new solutions are not always as easy to implement as they may seem. Insurance is both complex and highly regulated: a double hit for Insurtech or non-insurance companies looking to break into the space. That said, there are endless opportunities for your company to make major waves in the industry…if you take a careful approach.
Based on our decades of insurance consulting along with our experience helping numerous Insurtech startups over the last several years, here’s what you should know as you break into the insurance market.

The insurance industry is highly regulated

Many of today’s Insurtech companies emerge from the finance world, where modern technology has transformed everything from customer service to the nature of banking itself. While U.S. banking must comply with a single federal charter, insurance products are subject to disparate rules in 51 jurisdictions, multiplied by 20 to 30 lines of business that each has its own individual coverages. The number of details required for each product filing can be staggering and small errors have the potential to stall the filing on the path-to-market.
Partnering with a seasoned insurance technology consulting company with state filings experts enables you to achieve a clear roadmap of what to expect, potential pitfalls, and areas to consider before you get too far along in the product development process. Experienced partners will provide you with a clear understanding of the playing field and help you draft a realistic strategy for rolling out your product.

Add insurance executives to your team

State Departments of Insurance (DOIs) look favorably upon companies with proven histories in insurance. They have no time to teach inexperienced technology companies or non-insurance companies the ins and outs of creating a compliant filing. Bringing a seasoned insurance executive onto your team – and partnering with proven insurance consultants – helps sidestep avoidable regulatory pitfalls and adds instant credibility to your organization in the eyes of the regulators. The same also applies when raising capital. Venture capital firms feel more comfortable investing in firms with experienced in-house teams and insurance consulting experts onboard.

Primary insurers are skittish

Around eight years ago, many primary insurance companies started issuing paper to unproven Insurtech companies – a move that ultimately damaged their standing with state DOIs. Since then, primary insurers (as well as reinsurance companies) are more discerning about with whom they will do business. After all, their reputations and licenses are on the line. This is where working with a seasoned insurance technology consulting company with state filings experts pays off. Having insurance consultants on your team to thoroughly review and pressure-test your proof of concept will help you stand out to primary insurers and reinsurance carriers.

Insurance compliance is full of hurdles

Receiving approval from state DOIs and remaining compliant also means your policy, billings, and claims administration systems must all meet regulatory standards. These standards include everything from how your products are priced to how you advertise to consumers to how data must be reported. Some requirement documents are thousands of pages long, a difficult task to manage for teams short on insurance experience.
Whether you are implementing an Insurtech solution or offering ancillary insurance along with your primary service offerings, insurance product development is a tricky process. Even bureau-based products that lean heavily on Insurance Services Office (ISO) or National Council on Compensation Insurance (NCCI) content are extremely complicated to interpret and adopt in a compliant manner. Seasoned insurance consultants like the team at Perr&Knight know this content and the related regulatory requirements inside and out because we work with them daily.
We help new Insurtech and non-insurance companies understand how to consume the content to develop an insurance product, how to structure the content for systems development and testing, and how to implement a compliant operational process from the outset. Building compliant systems and communications from the ground up protect your company from speed to market issues or costly re-work while avoiding potential fines for your carrier partner.

Use professional “matchmakers”

Primary insurance companies and reinsurers have what Insurtech companies and non-insurance companies need: approved licenses from state DOIs and capacity. Insurtech/non-insurance businesses have what primary carriers are looking for: fresh ideas, technologies, and access to new markets. Both must vet one another, a daunting task if neither company can accurately verify the validity of the other party’s credentials.
Experienced insurance consultants like the team at Perr&Knight can provide an insurance-focused perspective to determine whether the partnership will be beneficial for both parties. Evaluations from unbiased insurance professionals can increase your confidence that your prospective partner can deliver.

The future is full of opportunity

Technology and consumer product development move with lightning speed. Insurance, on the other hand, is extremely sluggish. The merging of these complementary industries opens a plethora of opportunities for proactive companies, but success is never guaranteed. Re-framing your expectations, working with experts, and adopting a calculated approach to your new insurance offerings are the most effective ways to improve your position. Start exploring “what you know you don’t know” with seasoned insurance experts before you get too far down the road.

Considering launching a new insurance product? Talk to the team at Perr&Knight first.

The Time Is Now: The American Rescue Plan’s Impact on Supplemental Health Insurance

If your company hasn’t reviewed your supplemental health products lately, now is the time to refresh your portfolio. The Biden-Harris administration’s American Rescue Plan reduces healthcare costs and expands access to coverage for millions of Americans. The subsidies are technically temporary (in place for 2021-2022), but we anticipate these popular provisions may ultimately remain in place for the foreseeable future, regardless of administration.
The plan provides fresh assurance to individuals buying their or their family’s health insurance through a marketplace that they will receive a premium-reducing tax credit. As more buyers enter the health market, the need for supplemental products will expand. Marketplace-insured Americans may still be facing moderate to significant out-of-pocket costs that supplemental health insurance plans can help alleviate.

Start laying the groundwork

As the supplemental health product marketplace has expanded over the last decade, these products have faced increasing regulatory pushback. Meeting this evolving regulatory challenge requires doing your homework ahead of time. Conducting comprehensive competitive analyses, market surveys, and evaluating existing competitor pricing puts you in a stronger position to release Gap medical and other supplemental health products that match state department of insurance (DOI) requirements directly out of the gate.

Accelerate time-to-market by partnering with experts

There are no shortcuts when it comes to insurance product development, but working with experienced actuaries, product development experts, and state filing experts can help you make up for lost time. Their access to historical filings, knowledge of region-specific requirements, and particulars of each state’s DOI protect you from costly, time-consuming mistakes that are likely to delay approval. Additional support means shifting from a reactive to a proactive position.
At Perr&Knight, we have experience developing limited medical/hospital indemnity plans, gap medical coverage products, and critical illness products that are more relevant – and necessary – to today’s marketplace than ever. We can help you gauge the interest to see if augmenting your portfolio with these products is worth the investment.

Changes are likely here to stay

It’s tempting to “play it safe” and hold off on investing in insurance product development because you believe the ARP’s health insurance provisions will be undone in the event of an administration change. But if the past is any indicator, even politically fraught plans like the Affordable Care Act (ACA) have withstood a barrage of threats, remaining popular with the American people.
As the saying goes, the best defense is a good offense. Failure to begin in earnest means your company is already behind other carriers who have either recently refreshed their portfolios with updated gap medical or other supplemental health products, or those who have started the insurance product development process. The time to get started is now.
Read more: New Trends in Accident & Health Insurance.

Ready to reevaluate the role of supplemental health coverage in your portfolio? Our actuarial and state filings experts are here to help.

Supplemental A&H Group vs Blanket Filings: An Overview

Authors: James Vallee, FSA, MAAA and Susan Cornett, FLMI, AIRC, CFE
At Perr&Knight, our insurance consultants help many clients develop group and individual supplemental health products. We are often approached by insurance companies with confusion about what group policyholder types to use and where a client should use group vs. blanket. When an employer policyholder is not appropriate, insurance companies look to other group types such as associations, trusts, or discretionary groups.

UNDERSTANDING GROUP POLICYHOLDER TYPES

Many clients want to rely on the outdated practice that, by using association or trust filings, a situs state approval means automatic approvals in other states and rating can be more flexible. While that was once the case, it no longer holds true. As associations became more popular, regulators noted that many of the associations lacked a common purpose and thought that the associations were used primarily to circumvent form and rate requirements.
Associations, trusts and discretionary groups often have to be approved by state regulators before a policy can be issued or, in some circumstances, before policy solicitation. Single case filings for these groups are required more often. Approvals for discretionary groups are particularly difficult to gain when the policyholder/insured relationship is not clear.

GROUP VERSUS BLANKET POLICIES

Another area of confusion is how a blanket policy is different from a group policy. On the surface they appear similar; there is a master policyholder and groups of individuals are covered. However, blanket coverage is usually offered to institutions (e.g. schools or camps) that provide excess or secondary accident/medical coverage to individuals participating in activities under their purview. While a few states require blanket coverage to have underlying certificates (like group), the people covered under these policies are often not aware that they have coverage under a blanket program.

HOW TO CHOOSE BETWEEN GROUP AND BLANKET POLICIES

Depending on the needs of the insurance company, policyholder and the individuals to be insured, insurance companies can utilize either a group or blanket policyholder format. Many jurisdiction handle non-employer groups and blanket programs differently. Some states will provide greater latitude to blanket products than group products simply due to the types of groups that may be insured.
Selecting a group type can be confusing so let our insurance consultants guide you. Our accident & health product development consulting team has ample experience in helping companies find success with non-employer groups.

Contact Perr&Knight today to schedule a consultation.

A&H Insurance Advertising: Rules & Compliance Overview

Advertisements are an integral part of any A&H insurance marketing plan. Insurance companies must find ways to get and keep the attention of a prospective insured. Given that the average American sees more than 4,000 advertisements each day, insurance companies look for creative ways to attract prospective insureds. However, it’s not as simple as writing a clever ad. Insurance companies are subject to various levels of regulation and process requirements.

What is an advertisement?

An advertisement is any material that is published, printed, scripted, or displayed to a consumer. This includes, but is not limited to, postcards, electronic communications, billboards, radio or TV ads, and websites. It can also include sales talks and presentations for use by agents, brokers, producers, and solicitors.
Advertisement includes advertising material sent with a policy when the policy is delivered and material used in the solicitation of renewals and reinstatements. It also extends to the use of all media for communications to the general public, to the use of all media for communications to specific members of the general public, and to the use of all media for communications by agents, brokers, producers and solicitors. The definition of advertisement casts a wide net.

What rules apply?

Insurance advertisements are subject to federal, state, and in some cases, local statutes, regulations, and ordinances. At the federal level, insurance companies must review HIPAA marketing regulations and the CAN-SPAM Act.
The HIPAA regulation defines marketing materials as a communication about a product or service that encourages recipients of the communication to purchase or use the product or service. Applicability of the act depends on the recipient and the service or product in the communication.
CAN-SPAM sets the rules for commercial email, establishes requirements for commercial messages, and provides penalties for violations.
In addition to the federal requirements, most states have adopted some version of the NAIC’s Advertisements of Accident and Sickness Insurance Model Regulation. This regulation defines advertisements and sets forth requirements for content, control, and filing requirements. Most states require insurance companies to file Medicare Supplement and long-term care ads, but some states require that all advertisements be filed. At the local level, city and county ordinances control signage, such as those seen in traffic medians or attached to light poles.

Who controls advertisements?

Insurance companies have a duty to maintain control of their advertisements, whether those ads are created by a home office employee, a broker, or an independent agent. Insurance companies must have procedures in place to establish and maintain a system of control over the content, form, and method of dissemination of all of its advertisements.
According to our insurance support services experts, best practices include a formal advertising approval process, tracking, and record retention. States rely on insurance companies to self-monitor their advertising procedures and require a signed certification of compliance each year with the annual statement filing.
While A&H advertising requirements can be overwhelming, it’s also important to note that most states have adopted the same basic requirements with respect to content. It’s usually not necessary to create 51 versions of an ad, although there are almost always state variations.

Next steps

Whether the advertising campaign is one jurisdiction or fifty-one jurisdictions, insurance companies must understand requirements for content, filing, and distribution. Contact the insurance consultants at Perr&Knight to learn how we can provide insurance support services for advertising review and the development of processes and procedures to manage advertising.

Digital Transformation: Old Wine in New Bottles?

So much of what we find new and exciting requires what we too often write off as outmoded.
Today’s insurance technology initiatives are increasingly motivated by our latest term of art, digital transformation. We love to throw those words around as if they represent some magical incantation that, when invoked, will produce brilliant solutions that lift us to otherwise unattainable competitive positions, as masterworks of art that evoke feelings of awe eons after their original creation.
Of course, we’ve been “digitally transforming” for decades. Setting aside the nineteenth-century innovations of Charles Babbage for a moment, modern “digital” computing is easily traced at least as far back as 1945 with the introduction of ENIAC, “the first programmable, general-purpose electronic digital computer”.[1] The intervening years have seen a remarkable explosion of computing power. Famously, the Apollo Guidance Computer (AGC) used to put men on the moon in 1969, with its 2 MHz CPU speed, had roughly the same computing power as a twenty-five year-old Nintendo Entertainment System (1.8 MHz). An old iPhone 4 (2010), with its 800 MHz CPU speed, outgunned the $32 million Cray 2 supercomputer (1985) by a factor of three (244 MHz).[2] And today’s iPhone 12 (2.99 GHz) and Sony PlayStation 5 (3.5 GHz) make those computing milestones seem quaint.
The growth in computing power, and therefore the number of practical applications that can be handled by affordable computers, has been astonishing. Indeed, it has made the aspirations of computer scientists who only dreamed about artificial intelligence and virtual reality just a few decades ago – dreams because they would require rooms full of very expensive hardware – available to the masses in tiny packages for very modest sums.
So it follows that today when we hear about insurers wishing to undertake digital transformation initiatives, we understand that their desire is to leverage today’s massive computing power to gain a competitive advantage. Otherwise, we’re simply talking about modernization, which was all the rage way, way back in 2015. Today’s initiatives have the far more ambitious goal of producing novel solutions, in the sense that competitors haven’t yet discovered – let alone adopted – them, and so they’re in a very real sense disruptive.
But disruption comes out of tolerance for mistakes. Disruption comes from having the wherewithal to experiment and fail repeatedly. Disruption comes from having the courage to engage in radically candid conversations laced with dissent and debate. So disruption can only happen if the company culture permits it to happen – an idea antithetical to an insurance company’s traditional mission, which is to avoid undue risk.
This frosty bit of insight begs an entirely different approach to insurance company operations that goes well beyond technology. Famously linear thinkers, insurance professionals have historically worked to place a price x on some risk y in anticipation of a positive return z. We press this button and that happens. Of course, this approach has turned out to be of dubious value, evidenced by the prevalence of combined ratios that exceed the century mark. Instead, a confluence of factors in a variety of dimensions conspire to destroy our bottom lines, if not our innocence: Geopolitics. The environment. Social movements. Generational sensibilities. Competitive moves. Regulatory constraints. Human psychology. Solar flares?! And yes, the rapid pace of technological change. After all, how popular was cyber insurance – arguably influenced by each of those factors – in 1950?
Woke (forgive me, but the term seems to work in this context, too) insurers have accepted this. And so their efforts are directed toward aggregating not just traditional datasets that populate rating algorithms or underwriting rules, but those many ancillary bits of information that influence risk selection and loss potential in a far more informed (read: non-linear) way. They utilize Big Data. They leverage artificial intelligence. They employ dedicated predictive analytics units. They automate routine operational processes. They invest in new technology. And they adopt change management programs to support those initiatives. That’s a long list of expensive undertakings for a smaller insurer. But that’s the world in which they have to compete.
Middle-tier regionals with relatively modest means must contend with tiny upstarts with tens of millions in capital investment unburdened by years of legacy operations on one end, and multi-billion dollar behemoths spinning off autonomous innovation centers on the other, for their share of the hundreds of billions of premium dollars blown skyward by the shattering of preconceived notions.
And so we arrive at the intersection of culture and technology, of art and science, of hard skills and soft skills. In an industry famously fixated on risk avoidance and profit margins, this juncture becomes an especially challenging moment in time. Indeed, a quick review of recent literature on disruption in the insurance industry makes scant mention of the behavioral changes that must accompany any radical innovation, both within an organization among its constituents and outside among its customers and suppliers.
The impact on many well-established insurers? InsureTech startups are eating their lunch. That is, unless those veteran organizations were prescient (and well-capitalized) enough to develop their own skunkworks, separate and apart from their core organizations in order to permit the risk-tolerant cultures found in their more nimble adversaries. That’s fine if you’re a major player, one of the billion-dollar insurers who can afford separately funded venture arms, or an agile start-up with fifty million smackers to burn. But what of the middle tier, those thousands of regional insurers vying for market share in the face of old threats (mainstays) and new (InsureTechs)?
The obvious answer is they need to think a little differently. With no discretionary trove of millions to casually deploy, the focus must be on manifesting beneficial change. And beneficial change begins with vision, culture, and leadership – not bits and bytes. Old wine in new bottles, you might say.
I’m not suggesting plastering office walls with poster-sized admonitions to “embrace change,” nor am I suggesting that beneficial change is a thing that happens if you hire the right consultants. I am suggesting, however, that with all of the marvels of technology available in the twenty-first century, it’s still people who matter most. It’s still paying attention to what motivates – inspires – every individual responsible for the welfare of the organizations in which they toil that separates leaders from laggards. And most importantly, it’s regularly respecting and acknowledging their contributions to ensure they stay focused and motivated, long after the paint is dry on that beautifully executed automation project.
Of course, standard “tactical” practices for operational improvements and technology deployments involving proven toolsets for workflow analysis, business process design, and technical project management are essential for a successful digital transformation initiative. But no amount of funding will replace the unbridled enthusiasm of a group of colleagues setting out to effect change for the better. It’s that enthusiasm and commitment that drive organizations to prosperity; it is rarely prosperity – and never technology – that drives individuals to become enthused if they’re not adequately engaged and committed to the work they do.

Contact Perr&Knight to support your digital transformation initiative with experienced project managers, business analysts, and process improvement experts well-versed in the ‘people part’ of transformation, who can assist with the requirements management, process redesign, and change management capabilities that are essential for any such project.

[1] Swaine, M. ENIAC. (n.d.). Britannica. Retrieved January 25, 2021 from https://www.britannica.com/technology/ENIAC
[2] Routley, N. (2017, November 4). Visualizing the trillion-fold increase in computing power. Visual Capitalist. https://www.visualcapitalist.com/visualizing-trillion-fold-increase-computing-power/.

Large Risk Rating Options for Workers’ Compensation: What You Should Know

The market for workers’ compensation insurance has undergone a shift as large employers with more bargaining power recognize they can achieve a better financial position by obtaining coverage that more closely aligns the total cost with their unique risk factors. State Departments of Insurance (DOI) have approved a number of sophisticated loss-sensitive options for workers’ compensation insurance, further prompting insurance companies to develop programs like these in order to remain competitive.
Below we have provided an overview of large risk rating workers’ compensation products and how Perr&Knight can help you develop competitive plans with the best chance of approval.

Large Deductible Plans


Large deductible workers’ compensation plans provide the same coverage as guaranteed or fixed cost plans, but with higher deductibles, possibly leading to reduced costs for insureds. Deductibles for these plans generally start at $25,000 to $100,000 per occurrence and are ideal for large employers seeking to self-insure a portion of their workers’ compensation losses.
Given the insurer is typically required to pay claims as they occur and seek reimbursement from the policyholder for claims below the deductible amount, insurers will often require the insured to provide collateral to secure the claims in this layer. Some jurisdictions may require insurance carriers to hold collateral, and insurers often need to analyze each risk individually to determine the amount of collateral to collect. This is an instance where turning to experienced actuarial consultants is invaluable. Our expert teams can assist in determining how much collateral to hold, either by performing actuarial loss projections based on historical loss runs prior to the onset of the policy or performing a collateral evaluation over time to ascertain how losses and collateral needs have developed for a particular policyholder.
Our actuarial consultants can help you develop your large deductible program, provide guidance on the various premium threshold requirements and permissible deductible levels by jurisdiction, as well as meet other state-specific requirements when filing large deductible workers’ compensation programs.

Retrospective Rating Programs

Retrospective (also called “retro”) rating plans determine the final workers’ compensation premium by evaluating actual losses incurred during the policy period. Employers pay a certain premium upfront, but at set intervals after the policy expires, insurance companies evaluate actual losses versus what was originally expected. This can result in a premium refund to the insured if losses are better than expected and additional premium due if losses are worse than expected. These sophisticated plans can be helpful in controlling the final cost of an organization’s workers’ compensation program.
Because of their complexity, it is imperative to set retro programs up correctly from the outset. Perr&Knight’s actuarial consultants can assist in determining proper rating factors (expected loss ratios, the types of excess factors to file, other rating elements to file in various states, etc.), as well as determining if the state DOI will allow exceptions to bureau filed plans.

Large-Risk Alternative Rating Option (LRARO)

A provision commonly contained in retrospective rating plans, LRARO can be layered on top of other programs, enabling employers with a yearly estimated workers’ compensation premium exceeding a certain threshold to negotiate premiums with their insurance provider. With this rule on file, insurers can negotiate the rating factors and premium components involved in determining the final premium for their workers’ compensation coverage.
This option is permitted in most states, but filing requirements vary by jurisdiction. For example, some states have premium eligibility requirements which must be met before the insurance company may use this rating option.
We have deep experience in developing loss sensitive rating programs and filing LRARO rules to achieve exceptional rating flexibility. Our actuarial consultants understand important jurisdictional filing differences and can help you file this provision correctly.

Partner with Actuarial Experts

Sophisticated large risk rating programs add more complexity to an already complicated process. Our actuarial teams are profoundly experienced in the full scope of loss sensitive programs and can help with designing large risk workers’ compensation products including developing rating plans, defining rules, helping with endorsements, and ultimately managing state filings.
For insurance companies already offering loss sensitive workers’ compensation products, we can conduct reviews to determine if it is possible to enhance your product offerings, or conduct detailed competitive evaluations to make sure your program is in line with the market.

Thinking of making changes to your workers’ compensation products? Our expert actuarial consultants can help.

You Better Watch Out, You Better Not Cry, State Filing Requirement Changes Are Already Here!

Authors: Neresa Torres, Jessica Witvoet, API, AIS, AINS, AIT, and Diane Karis,AINS, CPCU
At Perr&Knight, we submit thousands of product filings (rate, rule and form) a year to the various state Departments of Insurance (“DOIs”) – and 2020 has been no exception. In fact, in addition to our normal annual volume of insurance product filings, COVID-19 has increased the number of state filings for pandemic-related submissions.
Throughout the course of this year, we have noticed a few trends in how states’ DOIs are reviewing product filings. Since we handle a high volume of submissions across all jurisdictions and all lines of business, we are able to quickly identify variations from previous years.
Here’s what we have discovered. 

States are getting pickier about the rules

Though states have always clearly articulated their filing guidelines, in preceding years DOIs were more likely to excuse minor deviations and process those filings anyway. DOIs in the past may have been inclined to give some leeway. This year, however, many states are opting to exercise their right to issue an objection or reject a filing outright if every detail is not spot on. Small errors that may have been “no big deal” in the past are now grounds for review or disapproval.
For example, Idaho is now closely scrutinizing the status of the filing in the domicile state. In the past, a “pending” entry or concurrent submission of domicile state was acceptable. Now, it is required that the program being filed is approved by the domiciliary state prior to submitting the filing in Idaho. Unless there is a reasonable explanation as to why, the filing will be rejected or subject to a 7-day turnaround for correction. If the information is not included at all, the filing is often disapproved without any opportunity for correction. Kansas has become more finicky, too, requiring each rule filing to have an accompanying form, or an objection will be issued. Other states have implemented guidance tools and checklists to ensure compliance with changing rules and requirements. For example, Massachusetts has created a four-part instruction guide to cover what is required for a filing to be considered acceptable.
The point is: don’t rely on DOIs being as forgiving as they have been in previous years. Make sure all your filing details are correct and complete.

Objections, rejections, and time-to-approval are increasing

Insurers are not the only ones experiencing administrative delays due to the pandemic. Many state DOIs shifted to remote working scenarios as well, and this has impacted their ability to issue speedy approvals. In California, for example, commercial, homeowners’, and other personal policies are taking longer to receive approval than in years past. The number of “pending” approvals has also increased.
Closer scrutiny by state DOIs is resulting in a higher number of rejections for minor issues. On the bright side, turnaround times for re-submitting are also faster. In many instances, we have seen DOIs allow re-submission within 7 to 10 days.
If your filing is rejected, correct the problem immediately and resubmit right away. Sophisticated software solutions like Perr&Knight’s StateFilings.com can help your teams keep a closer eye on filing status.

Other events impacting 2020

In addition to the disruptions caused by the pandemic, social unrest, and an election year, insurers are facing other challenges, such as recertification of the Terrorism Risk Insurance Act (TRIA), which requires all companies to update their language. Travel insurance products are also changing quickly as travel restrictions are lifted and added on a rolling basis worldwide.
This year’s regulatory requirements compel insurers to take a closer look at forms to make sure each meets the DOI’s current standards, which may have been updated recently.

Keeping track of the trends

2020 has been a year of surprise rejections for some insurance companies. It makes sense: companies only submitting a few filings per year – or who haven’t updated their product in recent years – lack the macro perspective to spot trends in DOI behavior.
When a rejection is received, it is important to determine as quickly as possible if the rejection is a unique occurrence or due to a change in a procedural requirement by the DOI. When submitting new filings, comparing against historical filings is no longer enough. Instead, it will be important to keep close track of current trends, as well as to look deeper into the DOI’s reasoning. This insight will help you avoid costly, time-consuming errors moving forward.
Internally, the Perr&Knight state filings department takes note of every rejection/objection we encounter and evaluates it to discover if it is part of a larger directional shift for that DOI, or simply a one-off. When we have questions about a particular DOI action, we contact the reviewer immediately and obtain a more thorough explanation. Because we handle such a high volume of nationwide filings, we remain in regular communication with every state DOI. These strong relationships enable us to obtain clarification on department actions that guide future filings on behalf of our clients.

Work with an experienced partner

Staying compliant today presents more of a challenge than it has in years past. Because the landscape is shifting quickly (as quickly as the insurance industry can shift), insurers are at higher risk of receiving rejections – especially those who submit a relatively low number of filings per year.
This is where working with an external insurance filings support partner can deliver a dramatic difference. Experienced state filings teams manage filings day-in and day-out. Their level of intimate knowledge of each transmittal requirement, variations between states, and regulatory expectations for each line of business can mean the difference between a smooth approvals process or being sent back to square one.
As 2020 draws to a close, the winds of change continue to shift. We expect more deviations from the status quo in the coming year. We’ll keep our clients posted on what we discover and how they can stay ahead of the game.

Questions about how to improve the efficiency of your rate filings? Our state filings experts can help.

Insurers Need to Plan for the Future of Workers’ Compensation Data Reporting

The world of workers’ compensation statistical data reporting is constantly evolving. Rating bureaus are continually updating regulatory requirements and increasing the number of reportable data elements.  The past few years have seen multiple rating bureaus roll out brand new data collection and reporting tools, introduce a new Indemnity data call, and increase the number of relational validations between Unit Statistical data and Financial Call data. The need for developing and maintaining adaptable reporting solutions has never been more important than it is today.

Expansion of Reporting and Testing Requirements

A substantial effort has been made by state independent rating bureaus to establish their own internal Policy and Unit Statistical Reporting applications. Historically, paper submissions were an option for Proof of Coverage Reporting. This is no longer the case. Electronic submission uploads or manual data entry are now required by all bureaus. For smaller insurers, manual data entry may be an option, but due to the amount of human intervention, is subject to a sizeable degree of error. Automated electronic data submissions are key to reducing costs associated with error resolution and manual entry.
For a carrier to be approved for electronic reporting by a rating bureau for all required reports, a thorough testing process is required. For WCPOLS, this involves comparing converted text files in bureau formats to hard copy policies to validate the accuracy and completeness of the data reported. DCI, Medical Data Calls, and Indemnity Data Calls all require stringent data validation checks and reconciliation to Unit Statistical Reports. State independent bureaus are increasing the complexity of their required test cases to account for multiple complex policy scenarios. This can be seen most recently with California’s Star systems and Pennsylvania’s expansion of testing requirements. The accuracy of data capture is essential for insurers to avoid fines and remediation.
On top of increased testing requirements, we are seeing the rating bureaus expand data requirements.  The National Council on Compensation Insurance (“NCCI”) and several state independent bureaus implemented the new Indemnity Data Call on 9/30/2020 to collect detailed claims data on indemnity losses. Financial data call relational data validations are expanding on an annual basis and comparisons to other reporting requirements such as Unit Statistical are becoming more prevalent. Data sources need to not only pass initial data validations but must also meet actuarial reasonability standards with increased accuracy. This is especially true for regulator-level premium calculations related to financial calls.

The Importance of Automated Error Correction

Reporting of workers’ compensation statistical data allows very little, if any, room for error. As data elements continue to expand and edit packages become more robust, data scrubbing and error correction will become more time consuming. Companies will be required to spend more money on resources to either improve data capture or invest more in additional resources and people to resolve data quality errors. Alternatively, working with an experienced reporting vendors’ data validation packages will make the reporting process more streamlined, allowing companies to identify data quality errors and make corrections in groups, rather than searching out errors one at a time. Implementation of automated bulk updates will result in a significant number of hours saved on an annual basis.

Single Source Solutions

Over the last few years, rating bureaus have expanded their systems to allow for direct reporting and error correction to be completed through internal web-based applications. In addition, NCCI has expanded their system to allow for the reporting of multiple state independent bureaus. This has improved the overall reporting process by reducing the number of websites utilized for data reporting, but there is still room for improvement. While the Compensation Data Exchange allows for the loading and reporting for both Policy and Unit Statistical data for all states, the application still does not capture all edits for all bureaus.  In the future, insurance companies will be looking for a single platform where data for all bureaus can be loaded, validated, and corrected. Carriers will seek a more simplistic solution – one that limits their employee’s effort and number of clicks required to search multiple websites to ensure they comply with Policy and Unit Statistical reporting requirements.

Summary

As reporting requirements expand and data validations become more robust, staying current on reporting changes is a must in the digitization of data compliance. Being prepared for changes in statistical data reporting is the only true way to avoid countless hours of additional work staying compliant. Perr&Knight continuously works on anticipating trends in data reporting and regulatory compliance. Additionally, Perr&Knight continues to develop new data collection, data validation and error correction applications. Utilizing Perr&Knight will expedite data reporting processes, improve error resolution procedures and offer rapid data comparisons, allowing our clients to focus more of their time on profitability rather than compliance issues.

Stop worrying about missed deadlines and steep fines. Save time, save money and eliminate the hassle of accurate, on-time statistical reporting. Use Perr&Knight’s cutting-edge Statistical Reporting Solution to keep control of all of your statistical reporting needs.

Pet Health Insurance: Eight Key Ways to Enhance Profitability

With foreign body ingestion, poisoning, and cancer, along with being hit by car, ligament ruptures, and other accidents and illnesses, pet owners need to be prepared for the large unexpected veterinary bills that occur in treating their pet for these events. Pets are considered family members by many of us and require a significant amount of healthcare over the pet’s life, especially as the pet gets older and illnesses are more likely. In recent years, pet health insurance has been gaining in popularity and provides a way for pet owners to better manage the healthcare expenses of their pets.
For providers of pet health insurance, there are a number of ways to help enhance the likelihood of being profitable in the pet health insurance space while providing a valuable product to the pet owner.

Here are the key items that should be at the top of the list for successful programs: 

  1. Consider the impact and correlation between pet age / breed / size: While most pet health insurance writers want to focus on very young pets that will on average have better claims experience, the average age of the book of business will eventually increase as the company renews policies and the renewal of these aging pets will eventually outweigh the newer younger pets. Pet age factors are key in helping to achieve a better rate for the risk, but the risk associated with pet age is highly correlated with breed and size of dog. The table below shows an example of how pet health insurance writers are helping to maximize the correlation between these rating variables.

  1. Don’t rely on age at inception alone: Age at inception is a concept similar to whole life insurance, where your premiums do not increase as your age increases. While this may work for life insurance, it generally results in inadequate rates for pet health insurance as the average age of the book increases. Without another rating variable to compensate for the lost premium as the pet ages, the use of age at inception becomes more problematic as time goes on.
  2. Include automatic trend adjustments: Since the annual frequency and severity trend in pet claims is significant (typically ranging from 8% to 15%), a number of Departments of Insurance (“DOIs”) permit a rating factor that includes automatic trend adjustments. This allows premiums to increase over time without filing a rate increase with the state DOI. It is best to take advantage of this rating factor as it can significantly help with maintaining the profitability of the program in the states where this is allowed.

Following are a couple of examples of approved automatic trend adjustments:

  • Example 1: Due to this being health insurance for dogs and cats, loss costs will be susceptible to veterinary medical trends which we estimate to be compounding at a rate of up to 9% per year. A trend factor of up to (1+0.09)^(x/12), where x is the number of months since the effective date of this filing, may be applied to this base loss cost to account for the aforementioned inflationary effects.” 
  • Example 2: This factor is based on an expected annualized trend of 10.0% to account for the increasing cost of veterinary medical care. The formula for calculating the factor is (1+0.10)^(m/12) where m = the number of months since the base rate went into effect, and the factor in the first month of the proposed effective period equals 1.000 (i.e. m=0).
  1. Take advantage of ranges and flexibilities: Because pet health insurance is a property and casualty product and typically is filed under personal inland marine (only a handful of states are different), the DOIs in many states allow an insurance company to file subjective and experience-based rating variables for group policies, such as ranges of debits of credits, a schedule rating plan and/or an experience rating plan. It is best practice to add these where permitted to enhance rating flexibility.
  2. Don’t forget about forms: It is important to ensure your policy form has standard waiting periods and exclusions for pre-existing conditions, etc. to make sure you are not covering unexpected past injuries or illnesses. 
  1. Keep in mind that there are difficult states when it comes to profitability: Unfortunately, the biggest pet health insurance states when it comes to premium volume are also the most difficult ones to make money, such as California, Florida, New York, and Washington. These four states can sometimes make up to 50% of a nationwide book of business and the necessary rate changes to maintain profitability are often difficult to obtain with long approval timelines. While it may be enticing to write in these states due to the high growth potential, be careful as it is rare to be profitable in these states and very difficult to non-renew the business if things go south.
  2. Don’t set and forget: Pet health insurance rates need to be managed over time. A key to maintaining profitability is to take the necessary rate changes to at least achieve the target loss and expense ratio. Too often companies wait a few years before reviewing rates. This makes it very difficult to realize the rate level needed to achieve and maintain profitability.
  3. Monitor, monitor, monitor: It is important to not only understand the profitability of your book of business from an overall standpoint, but also whether your class plan rating variables are appropriately pricing the risk. Whether rating variables (such as state, deductible, coinsurance, pet age, breed, et.) are reviewed individually or with the use of predictive modeling, these analyses should be performed at least once a year to understand where the program is profitable and where rate increases are necessary to improve or maintain that profitability.

Pet health insurance is a fast-growing market with significant growth potential, but there are also a lot of ways to lose money in the process and companies can get themselves into a hole that is sometimes very difficult to dig out of.
About Perr&Knight
Perr&Knight is a leading provider of both actuarial consulting and pet insurance product development services to companies providing pet health insurance. Our consultants have assisted a number of pet health insurers with developing and maintaining a profitable pet health insurance product.

Please contact us with any assistance that is needed with your pet insurance product development.

How to Avoid Common Mistakes Carriers Make When Implementing New Systems

Carriers who have not been through complete development and implementation of a new system tend to underestimate the time, attention, and project management expertise it takes to smoothly roll out a system that works seamlessly with the other systems already in place. During our decades of providing project management and insurance technology consulting, we find that there are no universal “best practices.” However, there are good practices that everyone should try to follow.
Here are some of the most common mistakes we see and our suggestions for better alternatives.

MISTAKE: Thinking that your in-house staff has the bandwidth to properly oversee your new system rollout.

WHY IT’S A PROBLEM: In-house teams already have full slates and might overlook crucial details that can compromise the project.
BETTER ALTERNATIVE: Partner with insurance experts who can bring a fresh perspective. They will evaluate the details of your system roll-out to spot hiccups before you begin. They can also create achievable timelines and budgets, helping all parties stay on track to meet these expectations.
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MISTAKE: Relying on an inexperienced project manager.

WHY IT’S A PROBLEM: Project management is about more than just watching the schedule and staying organized. Successful project management requires scope management, HR management, and experience in risk, quality and procurement management.
BETTER ALTERNATIVE: Since there are many moving pieces and many specialized disciplines to take into consideration, it’s wise to trust an experienced project manager who has the insurance technology consulting expertise required to successfully implement new systems specifically for insurance companies.
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MISTAKE: Drafting an ambiguous or incomplete scope of work before beginning the project.

WHY IT’S A PROBLEM: Poor planning reveals surprises that must ultimately be sorted out down the line. These can delay deployments and cause budgets to balloon.
BETTER ALTERNATIVE: Carefully define your scope of work before engaging vendors. Make sure that all stakeholders understand what’s in and what’s out of scope before awarding a contract, and encourage them to draw to your attention any gaps or points of confusion.
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MISTAKE: Adopting an ad hoc or informal approach to planning.

WHY IT’S A PROBLEM: Scattered planning results in reacting to problems as they arise, not charting a proactive course of action.
BETTER ALTERNATIVE: Ask your insurance technology consulting expert to give you a realistic picture of what to expect while you draft your scope of work. Make sure you account for all aspects of your current systems that need to be updated before integrating with your new systems.
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MISTAKE: Doing things the way they’ve always been done.

WHY IT’S A PROBLEM: A “business as usual” approach can cause you to overlook important details or blind you to new practices, which can result in the marketplace leaving you behind.
BETTER ALTERNATIVE: To remain both efficient and competitive, insurance companies must maintain the flexibility to adapt to new situations. Simply relying on project management practices that have worked in the past can cause you to miss out on opportunities for greater efficiency or profitability.
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MISTAKE: Jumping to a solution before properly assessing the issue.

WHY IT’S A PROBLEM: Rushed decision making leads to costly oversights that can stall a project or force a complete re-evaluation down the line.
BETTER ALTERNATIVE: Undertake a proper discovery period to correctly assess your project needs and evaluate the costs and benefits associated with project decisions.  Create a game plan that makes sense and make sure everyone is on the same page before you start the project.
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MISTAKE: Hastily selecting a vendor.

WHY IT’S A PROBLEM: Partnering with the wrong vendor can cost you time and money. You might end up deep in a project and be forced to throw good money after a bad vendor experience in an effort to get your project back on track.
BETTER ALTERNATIVE: Take the time to properly vet your vendors. Ask them specific questions about their experience in the particular lines of business you are planning to write. Look for areas where they push back. You don’t need a team of yes-men. You need experienced professionals who tell you the truth, no matter what.
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MISTAKE: Remaining with the same vendor.

WHY IT’S A PROBLEM: Legacy partners can also get mired in their own systems and might not stay current with technology changes or industry advancements, causing you to lose out on important opportunities.
BETTER ALTERNATIVE: Ask your current vendor to bid alongside new vendors. If you have a personal relationship with your current vendor, request an unbiased third party from your team to handle the interviews and compare proposals. Take their assessment into strong consideration when deciding if your current vendor measures up or if you should partner with someone new.
There are as many ways to implement a new system as there are individual insurance companies. Use these guiding principles to help you make more thoughtful decisions as you develop new ways of serving your clients.
Need more guidance? Call Perr&Knight at (888)201-5123 Ext. 3 to discuss how we can help your implementation proceed more smoothly.