Market Conduct & Consumer Affairs (EX3) Subcommittee

Date: 12/19/14
Conference Call
MARKET REGULATION AND CONSUMER AFFAIRS (D) COMMITTEE
Friday, December 19, 2014
12:00 p.m. ET
ROLL CALL
Stephen W. Robertson, Chair
Therese M. Goldsmith, Vice Chair
Jay Bradford
Chester A. McPherson
Sharon P. Clark
Mike Rothman
Bruce R. Ramge
Wayne Goodwin
Mark O. Rabauliman
Laura N. Cali
Susan L. Donegan
Michael D. Riley
Tom C. Hirsig
Indiana
Maryland
Arkansas
District of Columbia
Kentucky
Minnesota
Nebraska
North Carolina
N. Mariana Islands
Oregon
Vermont
West Virginia
Wyoming
AGENDA
1.
Consider Adoption of its Nov. 18 Minutes—Commissioner Stephen W. Robertson (IN)
Attachment A
2.
Consider Adoption of Health Reform Data Call and Definitions
—Commissioner Stephen W. Robertson (IN)
Attachment B
3.
Receive Update on 2014 Market Regulation Summit Action Items
—Commissioner Stephen W. Robertson (IN)
Attachment C
© 2014 National Association of Insurance Commissioners
Draft Pending Adoption
Attachment A
Draft: 11/26/14
Market Regulation and Consumer Affairs (D) Committee
Washington, District of Columbia
November 18, 2014
The Market Regulation and Consumer Affairs (D) Committee met in Washington, DC, Nov. 18, 2014. The following
Committee members participated: Stephen W. Robertson, Chair (IN); Therese M. Goldsmith, Vice Chair (MD); Jay Bradford
represented by Ashley Fisher (AR); Chester A. McPherson represented by Lee Backus (DC); Sharon P. Clark (KY); Mike
Rothman (MN); Wayne Goodwin represented by Tracy Biehn (NC); Bruce R. Ramge (NE); Laura N. Cali (OR); Susan L.
Donegan (VT); Michael D. Riley and Mark Hooker (WV); and Tom C. Hirsig (WY). Also participating were: Randy Adair
(KS); and Chuck Vanasdalan (NH).
1.
Adopted its Oct. 20 Minutes
Commissioner Rothman made a motion, seconded by Commissioner Clark, to adopt the Committee’s Oct. 20 minutes
(Attachment One). The motion was unanimously adopted.
2.
Adopted ACA Market Conduct Examination Standards
Director Ramge said since the Summer National Meeting, the Market Conduct Examination Standards (D) Working Group
has adopted: 1) health reform-related market conduct examination standards relating to prohibition of excessive waiting
periods; and 2) health reform-related market conduct examination standards relating to essential health benefits.
Director Ramge said the Working Group has been working since 2012 on drafting market conduct examination standards for
the immediate health reforms of the federal Affordable Care Act (ACA), as well as for the health reforms effective Jan. 1,
2014. He said that once the examination standards are adopted by the Executive (EX) Committee and Plenary, they will be
included in the Market Regulation Handbook. Director Ramge said that recognizing jurisdictions have varying policy
directions regarding the enforcement of the ACA, the examination standards developed by the Working Group are designed
to provide uniform guidance to insurance regulators in their oversight of regulated entity activity, as appropriate for their
consumers. Director Ramge made a motion, seconded by Commissioner Rothman, to adopt the examination standards related
to prohibition of excessive waiting periods (Attachment Two) and essential health benefits (Attachment Three). The motion
was unanimously adopted.
3.
Adopted Revised Core Competencies
Director Ramge said the Market Conduct Examination Standards (D) Working Group was asked by the Market Regulation
and Consumer Affairs (D) Committee, on its June 23 conference call, to perform a review of the core competencies regarding
state insurance department oversight of contract examiners, in response to one of the recommendations found in the
December 2013 Federal Insurance Office (FIO) report. He said that at the Fall National Meeting, the Working Group adopted
revisions concerning: 1) professional designations of both insurance department and contract examiner staff; 2) status reports
to insurance departments from contract examiners; 3) insurance department oversight of contract examiner activity; and 4)
contract examiner conduct, adherence to work plan and conflict of interest guidelines. Director Ramge made a motion,
seconded by Commissioner Goldsmith, to adopt the revised core competencies (Attachment Four). The motion was
unanimously adopted.
4.
Adopted the Health Reform Survey
Mr. Vanasdalan said the Market Analysis Procedures (D) Working Group had adopted a survey to be placed in the NAIC
Market Regulation Handbook, which could be used as a template by states, either individually or collaboratively, to perform
analysis or examination work. He said the survey essentially asks companies to certify if they have taken steps required to
implement the ACA. Director Rothman made a motion, seconded by Commissioner Clark, to adopt the health reform survey
(Attachment Five). The motion was unanimously adopted.
5.
Adopted the Health Reform Data Call
Mr. Vanasdalan said the Market Analysis Procedures (D) Working Group had also adopted a health reform data call, which
could be placed in the Market Regulation Handbook so it can be used as a template by states to perform analysis or
© 2014 National Association of Insurance Commissioners
1
Draft Pending Adoption
Attachment A
examination work on active carriers. He said that since he understood the ACA eliminated issues with closed blocks of
business, the data call would not collect data on closed blocks of business. He said that the Working Group, when adopting
the data elements for the data call, also agreed to request permission for an interim meeting to work with all interested parties
to develop definitions.
Director Ramge asked if a pilot program had been considered to test the data elements. Mr. Vanasdalan said the Working
Group had not discussed a pilot program since he believed this data call, like the other standard data requests in the Market
Regulation Handbook, is only to be used as a template by states. Mr. Vanasdalan said it might be possible to request data
from a small group of carriers to identify issues with the data elements.
Marty Mitchell (America’s Health Insurance Plans—AHIP) said that he supported an interim meeting or conference calls to
finalize definitions and ensure that the data elements could be provided by health insurance carriers. Commissioner
Robertson asked if it was acceptable to exclude closed blocks of business from the data call. Mr. Mitchell said excluding
information from the data call would not be an issue.
Timothy S. Jost (Virginia Organizing) said that since the ACA has been in effect for four years, and the U.S. Department of
Health and Human Services (HHS) had not yet collected any data, he believed they were clearly signaling to the state
regulators that HHS is deferring to state regulators for the collection of data for analysis and examinations. He said that while
he understood there were a few definitional issues to be worked out, he would like to see the data call finalized as soon as
possible.
Commissioner Goldsmith asked Mr. Mitchell if he had concerns about the definitions or the data elements themselves. Mr.,
Mitchell said he was concerned with both the data definitions and the data elements. He said that since the data elements
were requesting information by metal level, he was unsure if companies could provide the information as requested.
Commissioner Goldsmith said she was concerned about opening up both the data elements and definitions for continued
discussion.
Commissioner Robertson asked Mr. Mitchell if he had discussed the issue with his member carriers and wanted to know how
long it would take to do so. Mr. Mitchell said he was uncertain how long it would take. Commissioner Robertson said he was
concerned that nothing would be accomplished if the group continued to wait for answers from carriers.
Commissioner Rothman made a motion, seconded by Commissioner Cali, to adopt the data call framework subject to an
interim meeting in mid-December to finalize the data elements and definitions, as well to discuss a potential pilot project, and
then submit any changes to the Committee for adoption in December. The motion was unanimously adopted (Attachment
Six).
Andrea Routh (Missouri Health Advocacy Alliance) said there is a great deal of activity in the health insurance marketplace
and that the data call could currently be used by any state to collect data for analysis. She thanked the Committee for trying to
get the documents finalized by the end of the year.
6.
Adopted Market Information Systems Data Analysis Metrics
Mr. Hooker said the Market Information Systems (MIS) data analysis metrics had been developed to analyze the data
currently in the NAIC’s MIS to see what was entered and what training needs to occur to ensure better data quality. For this
analysis, the Market Information Systems (D) Task Force included Complaint, Exam, Market Analysis Reporting System,
Market Conduct Annual Statement and Regulatory Action data. For each of these systems, the Market Information Systems
(D) Task Force evaluated three aspects of data quality: completeness, timeliness and accuracy. The objective of this analysis
is to identify potential data quality issues. In some areas, a direct correlation cannot be drawn between the data and the
measure; therefore, the test is intended to measure reasonableness. In other areas, a threshold is recommended, again to
measure reasonableness. Some outliers may be accurate and acceptable. Commissioner Riley made a motion, seconded by
Commissioner Goldsmith, to adopt the MIS data analysis metrics. The motion was unanimously adopted (Attachment
Seven).
7.
Adopted a Compendium of Reports on the Pricing of Personal Automobile Insurance
Commissioner Hirsig said the Auto Study (C/D) Study Group adopted a “Summary of Consumer Groups’ Comments related
to the Availability and Affordability of Auto Insurance for Low Income Drivers.” Commissioner Hirsig said this summary
will be included in the “Compendium of Reports on the Pricing of Personal Automobile Insurance.” Commissioner Hirsig
© 2014 National Association of Insurance Commissioners
2
Draft Pending Adoption
Attachment A
made a motion, seconded by Commissioner Goldsmith, to adopt the “Summary of Consumer Groups’ Comments related to
the Availability and Affordability of Auto Insurance for Low Income Drivers.” The motion was unanimously adopted
[Drafting Note: joint minutes are attached to the Property and Casualty Insurance (C) Committee, Nov. 18, 2014, minutes].
8.
Adopted Task Force and Working Group Reports
Mr. Adair said the Antifraud (D) Task Force adopted its Sept. 17 and Aug. 17 minutes. He said the Task Force had received a
report on NAIC participation as a partner in the Healthcare Fraud Prevention Partnership and that the NAIC has remained a
full partner since 2011. He said the Task Force will continue to participate and provide information to the Committee on how
it can benefit from the participation. He said the Task Force also received a report on the Online Fraud Reporting System
(OFRS), as well as a report on the 2014 antifraud education programs. Mr. Adair said that due to the success of the 2013
Insurance Department Investigator Safety Guideline webinar, the Task Force had discussed offering an additional webinar on
Dec. 9. He said the Task Force will also be working on the creation of an industry insurance investigator safety guideline for
2015. He said the Task Force discussed the NAIC Antifraud Resources Report data updates for 2014. He said the Task Force
will be opening the report to update the type of data collected. He said the Task Force will solicit comments and suggestions
from its members, interested regulators and interested parties on the information published in the report. He said the Task
Force received reports from Coalition Against Insurance Fraud, National Insurance Crime Bureau (NICB) and National
Health Care Anti-Fraud Association (NHCAA) on matters of national interest to insurance fraud bureaus.
Commissioner Riley said the Market Information Systems (D) Task Force adopted its Aug. 16 minutes and adopted the
report of the Market Information Systems Research and Development (D) Working Group from its Oct. 30, Oct. 8 and Sept.
10 meetings. He said the report included direction given on several Uniform System Enhancement Request (USER) forms
and a review of criteria to analyze the MIS data. He said the Task Force adopted the report of the Regulatory Information
Retrieval System (D) Subgroup from its Oct. 28 meeting. He said the Task Force also adopted criteria to analyze the MIS
data and directed NAIC staff to generate the associated results.
Director Ramge said the Market Conduct Examination Standards (D) Working Group continues to work on ACA standards
and Chapter 14 regarding sampling for market conduct examinations. He said the Working Group had also adopted revisions
to core competencies related to insurance department staff professional designations and contract examiner professional
designations, state insurance department oversight of contract examiners, and conflict of interest (Attachment Eight).
Commissioner Hirsig said the Auto Insurance (C/D) Study Group adopted its Aug. 16 minutes and a revised version of the
Compendium of Reports on the Pricing of Personal Automobile Insurance. He said the Study Group also discussed comments
received on the draft data call template and a memorandum the Study Group sent to the Casualty Actuarial and Statistical (C)
Task Force asking the Task Force to study the issue of price optimization. He said the Study Group: 1) heard an update from
Maryland concerning a bulletin prohibiting the use of price optimization; 2) discussed the possibility of studying the issue of
rating tools, such as one from TransUnion/CARFAX, that use vehicle records to rate auto insurance policies; and 3) heard an
update from Oklahoma on its Temporary Motorist Liability Plan, which attempts to address the issue of uninsured motorists
in Oklahoma. Commissioner Hirsig said he would like a data call template adopted by the Study Group to be discussed on an
upcoming call for possible adoption [Drafting Note: joint minutes are attached to the Property and Casualty Insurance (C)
Committee, Nov. 18, 2014, minutes].
Mr. Vanasdalan said the Market Analysis Procedures (D) Working Group adopted its Oct. 29, Sept. 25 and Aug. 17 minutes,
and agreed to add health as the next line of business in the Market Conduct Annual Statement (MCAS) (Attachment Nine).
Commissioner Goldsmith said the Market Regulation Accreditation (D) Working Group had discussed a Market Regulation
Accreditation Goals, Objectives and Guiding Principles draft and the Working Group’s projected timeline (Attachment Ten).
Commissioner Robertson said the Market Actions (D) Working Group met Nov. 6, Oct. 7 and Sept. 2 in regulator-toregulator session pursuant to paragraph 3 (specific companies, entities or individuals) of the NAIC Policy Statement on
Open Meetings.
Commissioner Rothman made a motion, seconded by Commissioner Donegan, to adopt the reports from the Committee’s
task forces and working groups. The motion was unanimously adopted.
© 2014 National Association of Insurance Commissioners
3
Draft Pending Adoption
9.
Attachment A
Heard a Presentation on Amendments to Regulation P: Annual Privacy Notice Requirements Under the Federal GrammLeach-Bliley Act
Joseph Devlin (Consumer Financial Protection Bureau—CFPB) said that a new rule had been adopted regarding the nature of
annual privacy notice distributions. He said under the federal Gramm-Leach-Bliley Act, financial institutions are required to
provide privacy information to customers when a relationship is first established and then on an annual basis. However, he
said that since studies show that consumers often do not read the annual notices, they are not receiving the information they
need. He said that under certain conditions, financial institutions will now be able to post the privacy notice online and then
alert concerns with a Web address on other notices provided to the consumer. Consumers must also be given a phone number
for them to call if they want a hard copy of the notice. This method will not be allowed for financial institutions that
distribute customer information to other parties.
10. Heard a Report on Market Conduct Activities of the IAIS
Commissioner Donegan said the IAIS had developed issues papers and other documents to assist regulators worldwide in the
regulation of their insurance marketplace. She said that starting in 2015, the IAIS will require the Market Conduct Working
Group to interact with stakeholders: 1) when specific, technical input is required on an issue; 2) to solicit targeted feedback
on an issue or proposal; 3) to receive an explanation of practices and developments within the industry or certain regions or
jurisdictions; and 4) to engage with consumer groups or representatives and other stakeholders on relevant issues. She said
she would recommend a brief presentation to the Committee on all international activities at the 2015 Spring National
Meeting.
11. Heard a Report on Federal Activities
Tony Cotto (NAIC) said Commissioner Consedine will be testifying in front of the U.S. House Financial Services Committee
on international transparency issues.
12. Heard a Presentation on Weblining and Implications for Insurance Market Regulation
Birny Birnbaum (Center for Economic Justice—CEJ) said big data is defined as massive databases of information of
individual consumers; associated data mining and predictive analytics applied to those data; and scoring models produced
from those analytics. He said that originally, advisory organizations, like the Insurance Services Office (ISO), collected data
from many insurers to develop advisory loss costs. He said information was organized and gathered according to predefined
characteristics and used to evaluate those predefined risk classes. He said their activities were subject to regulatory oversight.
He said the use of insurance credit score was a watershed event because it was the first time a large non-insurance database
was data-mined to predict outcomes for insurance companies. Mr. Birnbaum said that using a database from consumer credit
information on 200 million consumers, Fair Isaac identified 500 data elements within consumer credit reports, added some
individual insurance outcome information to the data and associated insurance outcomes with consumer credit information to
identify 10 to 20 data elements most predictive of the insurance outcome to create “credit-based insurance scores.” He said
this dramatically increased the segmentation of consumers into risk classes and led insurers to review traditional insurance
classifications to develop more granularity. He said the new use of big data occurs when financial service firms, including
insurers, tap into a variety of non-insurance databases to steer and segment consumers with little or no transparency or
oversight. He said this occurs with the steering of consumers without the consumers’ knowledge and skirting protections
form consumers required by the federal Fair Credit Reporting Act (FCRA). Commissioner Robertson said Mr. Birnbaum
would have opportunities at future NAIC meetings to expand on the issue.
13. Discussed Other Matters
Commissioner Robertson said he would like the minutes to reflect his appreciation for the prior contributions of
Commissioner Hirsig, Ted Clark (KS), Jim Mumford (IA) and Craig Leonard (NAIC).
Having no further business, the Market Regulation and Consumer Affairs (D) Committee adjourned.
W:\National Meetings\2014\Fall\Cmte\D\11-Dmin.docx
© 2014 National Association of Insurance Commissioners
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Attachment B
HEALTH REFORM DATA CALL DEFINITIONS
Adopted by the Market Analysis Procedures (D) Working Group – December 11, 2014
© 2014 National Association of Insurance Commissioners
1
Attachment B
Line
#
Terms and Data
Elements
Health Insurance
Coverage
Exchange
(Marketplace)
Definition
Benefits consisting of medical care (provided directly, through insurance or
reimbursement, or otherwise and including items and services paid for as medical care)
under any hospital or medical service policy or certificate, hospital or medical service
plan contract, or health maintenance organization contract offered by a health
insurance issuer. This is not intended to include excepted benefits as defined in 42
U.S.C. § 300gg-91(c). This is also not intended to include closed blocks not subject to
Medical Loss Ratio (MLR) reporting under Centers for Medicare & Medicaid Services
(CMS) guidance nor is it intended to include self-funded plans.
The Affordable Care Act (ACA) creates new “American Health Benefit Exchanges” in
each state to assist individuals and small businesses in comparing and purchasing
qualified health insurance plans. An exchange may be a governmental agency or nonprofit entity that meets the applicable standards of the ACA and makes Qualified Health
Plans (QHPs) available on the marketplace to qualified individuals and/or qualified
employers. Unless otherwise identified, this term includes an Exchange serving the
individual market for qualified individuals and a Small Business Health Options Program
(SHOP) serving the small group market for qualified employers, regardless of whether
the Exchange is established and operated by a State (including a regional Exchange or
subsidiary Exchange) or by Health and Human Services (HHS). The individual Exchange
will determine who qualifies for subsidies and make subsidy payments to insurers on
behalf of individuals receiving them.
© 2014 National Association of Insurance Commissioners
Reference
42 U.S.C. § 300gg91 (c)
CCIIO Technical
Guidance (CCIIO
2013-0001)
Part 155.20-Exchange
Establishment
Standards and
Other Related
Standards under
the Affordable
Care Act
2
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#
Terms and Data
Elements
Definition
Reference
In Exchange
Health insurance coverage acquired through the Exchange (marketplace) as described
above.
Out of Exchange
Health insurance coverage acquired outside the Exchange (marketplace) as described
above.
Bronze
(Metal Level)
Health insurance coverage in the bronze level shall provide a level of coverage that is
designed to provide benefits that are actuarially equivalent to 60 percent of the full
42 U.S.C. § 18022
actuarial value (with allowable de minimus variations as described in 45 CFD 156.140(c)) (d)(1)(A)
of the benefits provided under the plan.
Silver
(Metal Level)
Health insurance coverage in the silver level shall provide a level of coverage that is
designed to provide benefits that are actuarially equivalent to 70 percent of the full
42 U.S.C. § 18022
actuarial value (with allowable de minimus variations as described in 45 CFD 156.140(c)) (d)(1)(B)
of the benefits provided under the plan.
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Terms and Data
Elements
Definition
Reference
Gold
(Metal Level)
Health insurance coverage in the gold level shall provide a level of coverage that is
designed to provide benefits that are actuarially equivalent to 80 percent of the full
42 U.S.C. § 18022
actuarial value (with allowable de minimus variations as described in 45 CFD 156.140(c)) (d)(1)(C)
of the benefits provided under the plan.
Platinum
(Metal Level)
Health insurance coverage in the platinum level shall provide a level of coverage that is
designed to provide benefits that are actuarially equivalent to 90 percent of the full
42 U.S.C. § 18022
actuarial value (with allowable de minimus variations as described in 45 CFD 156.140(c)) (d)(1)(D)
of the benefits provided under the plan.
Catastrophic
Health insurance coverage that does not provide a metal level of coverage.
Catastrophic coverage plans pay less than 60% of the total average cost of care and are
available only to people who are under 30 years of age before the beginning of the plan
year or who have received an exemption from the requirement to maintain minimum
essential coverage by reason of hardship or lack of affordability.
42 U.S.C. § 18022
(E)
Individual Health Health insurance coverage offered in the individual market, but does not include shortInsurance Coverage term limited duration insurance.
42 U.S.C. § 300gg91 (b) (5)
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Terms and Data
Elements
Definition
Reference
Grandfathered
Health insurance coverage that an individual was enrolled in prior to March 23, 2010
either through an individual health insurance coverage or group health insurance
coverage plan. Grandfathered plans are exempted from most changes required by the 29 CFR §
ACA. New employees may be added to group plans that are grandfathered, and new 2590.715-1251
family members may be added to all grandfathered plans. The plan may lose
grandfathered status if significant changes are made to the plan...
Multi-State
Health insurance coverage created by ACA operated under contract with The U.S.
Office of Personnel Management (OPM) and available in multiple states.
ACA 1334
Short-Term
Health insurance coverage provided pursuant to a contract with an issuer that has an
expiration date specified in the contract (taking into account any extensions that may
be elected by the policyholder without the issuer's consent) that is less than 12 months
after the original effective date of the contract.
45 CFR § 144.103
Small Group Health
Health insurance coverage offered in the small group market.
Insurance Coverage
© 2014 National Association of Insurance Commissioners
45 CFR § 144.103
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Attachment B
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#
Terms and Data
Elements
Definition
Reference
Student
Individual health insurance coverage that is provided pursuant to a written agreement
between an institution of higher education and a health insurance issuer, and provided
to students enrolled in that institution of higher education and their dependents, that
meets the following conditions: (1) Does not make health insurance coverage available
other than in connection with enrollment as a student (or as a dependent of a student)
in the institution of higher education. (2) Does not condition eligibility for the health
insurance coverage on any health status-related factor relating to a student (or a
dependent of a student). (3) Meets any additional requirement that may be imposed
under State law.
45 CFR § 147.145
Transitional Plan
Plans that are issued pursuant to the policy promulgated by the Centers for Medicare &
Medicaid Services (CMS) in a letter dated November 14, 2013 to the State Insurance
Commissioners. If permitted by applicable State authorities, health insurance issuers
may choose to continue certain coverage that would otherwise be cancelled or
modified to comply with the ACA, and affected individuals and small businesses may
choose to re-enroll in such coverage. CMS has further stated that, under the transitional
policy, non-grandfathered health insurance coverage in the individual or small group
market that is renewed for a policy year starting between January 1, 2014 and October
1, 2016 will not be considered to be out of compliance with certain market reforms if
certain specific conditions are met including the approval of state authorities.
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Line
#
Terms and Data
Elements
Definition
Reference
Policy
Administration
Rescission
A rescission is a cancellation or discontinuance of coverage that has retroactive effect.
(Does not include cancellations for non-payment.)
PA1
Earned Premium
Total premium earned from all policies written by the insurer during the specified
period.
PA2
Number of policies
issued
Number of policies (contracts) for health insurance coverage issued during the
specified period.
© 2014 National Association of Insurance Commissioners
29 CFR §
2590.715-2712 A
(2)
NAIC Model Act
36 - Individual
Market Health
Insurance
Coverage Model
Act
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#
Terms and Data
Elements
Definition
PA3
Applications
received by carrier
that did not result
in a policy
Number of applications (questionnaires and forms required by the insurer to determine
eligibility) which were received by the carrier during the period but which did not result
in a policy being issued.
PA4
Number of lives on
policies issued
Total number of persons covered under all the insurance contracts during the period.
Reasonable approximations are allowed when exact information is not administratively
available to the reporting entity.
PA5
Member months
for policies issued
Accident & Health
The sum of total number of lives insured on a pre-specified day of each month of the Policy Experience
reported year. Reasonable approximations are allowed when exact information is not Exhibit of the
administratively available to the reporting entity.
Financial Annual
Statement
PA6
Number of policy
terminations and
cancellations
initiated by the
consumer
Number of policies terminated at the insured's request.
© 2014 National Association of Insurance Commissioners
Reference
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#
Terms and Data
Elements
PA7
Number of policy
terminations and
cancellations due
to non-payment of
premium
Number of policies terminated because the insured never paid, or stopped paying, the
required premium for coverage.
PA8
Number of lives
impacted on
terminations and
cancellations
initiated by the
consumer
Total number of lives which were no longer covered as a result of policies terminated at
the insured's request. Reasonable approximations are allowed when exact information
is not administratively available to the reporting entity.
PA9
Number of lives
impacted on
policies terminated
and cancelled due
to non-payment
Total number of lives which were no longer covered as a result of policies terminated
because the insured never paid, or stopped paying, the required premium for coverage.
Reasonable approximations are allowed when exact information is not administratively
available to the reporting entity.
Definition
© 2014 National Association of Insurance Commissioners
Reference
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Attachment B
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PA10
Terms and Data
Elements
Number of
rescissions
Number of lives
PA11 impacted by
rescissions
Definition
Reference
Number of policies cancelled as a result of a rescission.
Total number of lives which were no longer covered as a result of rescissions.
Reasonable approximations are allowed when exact information is not administratively
available to the reporting entity.
Claims
Administration
CA1
Claim
For the purposes of this data call a claim means any individual line of service within a
bill for services.
Number of claims
received
Number of claims received by a carrier during the period requesting payment or
reimbursement based on the terms of the insurance policy. Note: For the purposes of
this data call a claim means any individual line of service.
© 2014 National Association of Insurance Commissioners
42 CFR § 447.45
(b)
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Terms and Data
Elements
Definition
CA2
Number of claims
submitted by innetwork providers
Number of claims received by a carrier asking for a payment or reimbursement by or on
behalf of an in-network health care provider (such as a hospital or doctor) that is
contracted to be part of the network for a carrier (such as a Health Maintenance
Organization (HMO) or Preferred Provider Organization (PPO)). The provider agrees to
the carriers' rules and fee schedules in order to be part of the network and usually
agrees not to balance bill patients for amounts beyond the agreed upon fee. Note: For
the purposes of this data call a claim means any individual line of service.
CA3
Number of claims
submitted by outof-network
Providers
Number of claims received by a carrier asking for a payment or reimbursement by or on
behalf of an out-of-network health care provider (such as a hospital or doctor) that is
not contracted to be part of a carrier's network (such as an HMO or PPO). Note: For the
purposes of this data call a claim means any individual line of service.
Number of claim
denials for innetwork claims
Number of claims received by a carrier asking for a payment or reimbursement by or on
behalf of an in-network health care provider (such as a hospital or doctor) that is
contracted to be part of the network for a carrier (such as an HMO or PPO) and were
subsequently denied by the carrier. Note: For the purposes of this data call a claim
means any individual line of service. Do not include claims that were pended for
additional information and subsequently paid.
CA4
CA5
Reference
Stratification of A grouping of number of days that it has taken to deny in-network claims. (0-15, 16-30,
days (tied to CA4) 31 to 45, 46 to 90, 91 to 180, 181 to 360, 360+).
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CA6
CA7
CA8
CA9
Terms and Data
Elements
Number of claims
denials for out-ofnetwork claims
Definition
Reference
Total number of claims received by a carrier asking for a payment or reimbursement by
or on behalf of an out-of-network health care provider (such as a hospital or doctor)
that is not contracted to be part of a carrier's network (such as an HMO or PPO) and
subsequently denied by the carrier. Note: For the purposes of this data call a claim
means any individual line of service. Do not include claims that were pended for
additional information and subsequently paid.
Stratification of A grouping of number of days that it has taken to deny out-of-network claims. (0-15,
days (tied to CA6) 16-30, 31 to 45, 46 to 90, 91 to 180, 181 to 360, 360+).
Number of paid
claims for innetwork services
Total number of claims received by a carrier asking for a payment or reimbursement by
or on behalf of an in-network health care provider (such as a hospital or doctor) that is
contracted to be part of the network for a carrier (such as an HMO or PPO) and were
subsequently paid by the carrier. Note: For the purposes of this data call a claim means
any individual line of service. Include claims that were pended for additional
information and subsequently paid.
Stratification of A grouping of number of days that it has taken to pay in-network claims. (0-15, 16-30,
days (tied to CA8) 31 to 45, 46 to 90, 91 to 180, 181 to 360, 360+).
© 2014 National Association of Insurance Commissioners
12
Attachment B
Line
#
Terms and Data
Elements
Number of paid
CA10 claims for out-ofnetwork services
CA11
Definition
Reference
Total number of claims received by a carrier asking for a payment or reimbursement by
or on behalf of an out-of-network health care provider (such as a hospital or doctor)
that is not contracted to be part of a carrier's network (such as an HMO or PPO) and
subsequently paid by the carrier. Note: For the purposes of this data call a claim means
any individual line of service. Include claims that were pended for additional
information and subsequently paid.
Stratification of A grouping of number of days that it has taken to pay out-of-network claims. (0-15, 16days (tied to CA10) 30, 31 to 45, 46 to 90, 91 to 180, 181 to 360, 360+).
CA12 Claims Paid
Total dollar value of payments by the carrier for benefits reflected in claimants’
Explanations of Benefits (EOBs) for the requested period.
© 2014 National Association of Insurance Commissioners
13
Attachment B
Line
#
Terms and Data
Elements
Definition
Reference
Total dollar value of co-payments reflected in claimants' EOBs for the requested period.
Insured/beneficiary
A co-payment is a fixed amount (for example, $15) paid by a covered life for a covered
CA13 co-payment
health care service, usually paid when the service is provided. The amount can vary by
responsibility
the type of covered health care service.
Insured
CA14 coinsurance
responsibility
Total dollar value of co-insurance applied on benefits reflected in claimants’ EOBs for
the requested period. Co-insurance is the percentage amount, if any, of a covered
benefit which the insured pays as share of the payment made against a claim.
Insured deductible
CA15
responsibility
Total dollar value of deductibles applied by the carrier for the requested period. A
deductible is the amount owed for health care services the plan covers before the
health insurance or plan begins to pay.
© 2014 National Association of Insurance Commissioners
14
Attachment B
Line
#
Terms and Data
Elements
Definition
Reference
A rescission, or a denial, reduction, termination of, or a failure to provide or make
payment (in whole or in part) for, a benefit, including any such denial, reduction,
termination, or failure to provide or make payment that is based on a determination of
a member’s, or eligible dependent’s, eligibility to participate in a plan, and including a
denial, reduction, termination of, or a failure to provide or make payment (in whole or
in part) for, a benefit resulting from the application of any utilization review, as well as a
failure to cover an item or service for which benefits are otherwise provided because it
is determined to be experimental or investigational or not medically necessary or
appropriate.
NAIC Model Act
76 - Uniform
Health Carrier
External Review
Model Act;
NAIC Model Act
72 - Health Carrier
Grievance
Procedure Model
Act, Section 3(A)
An independent review of an adverse determination or final adverse determination.
NAIC Model Act
76 - Uniform
Health Carrier
External Review
Model Act
Consumer
Requested Internal
Reviews
(Grievances)
Adverse
Determination
External Review
© 2014 National Association of Insurance Commissioners
15
Attachment B
Line
#
Terms and Data
Elements
Definition
Reference
External
(Independent)
Review
Organization
NAIC Model Act
76 - Uniform
An entity that conducts independent external review of adverse determinations or final
Health Carrier
adverse determination.
External Review
Model Act
Grievance
A written complaint, or oral complaint if the complaint involves an urgent care request,
submitted by or on behalf of a covered person regarding: (1) Availability, delivery or
quality of health care services, including a complaint regarding an adverse
determination made pursuant to utilization review; (2) Claims payment, handling or
reimbursement for health care services; or (3) Matters pertaining to the contractual
relationship between a covered person and a health carrier.
Grievance for NonAdverse
Determination
A grievance arising from any issue other than an adverse determination.
Internal Review
A process by which the insured may have an adverse determination reviewed by the
carrier with respect to a denial of an admission, availability of care, continued stay or
health care services for a covered person.
© 2014 National Association of Insurance Commissioners
NAIC Model Act
72 - Health Carrier
Grievance
Procedure Model
Act
NAIC Model Act
72 - Health Carrier
Grievance
Procedure Model
Act
NAIC Model Act
72 - Health Carrier
Grievance
Procedure Model
Act
16
Attachment B
Line
#
Terms and Data
Elements
Overturned
Decision
A reversal of a denial of an adverse determination by a health carrier or its designee
utilization review organization.
Upheld Decision
A denial of an adverse determination that has been found to be supported by a health
carrier or its designee utilization review organization.
Voluntary Review
Level
IR1
Definition
A level of review beyond the normal internal appeals process.
Reference
NAIC Model Act
72 - Health Carrier
Grievance
Procedure Model
Act - Section 9
Number of
customer requests
for internal reviews
of grievances
involving adverse
See definition of internal review above.
determinations (Do
not include
additional
voluntary levels of
reviews.)
© 2014 National Association of Insurance Commissioners
17
Attachment B
Line
#
IR2
IR3
Terms and Data
Elements
Definition
Reference
Number of adverse
determinations
upheld upon
request for internal
See definition of upheld decision above.
review (Do not
include additional
voluntary levels of
reviews.)
Number of final
adverse
determinations
overturned upon
request for
See definition of overturned decision above.
external review (Do
not include
additional
voluntary levels of
reviews.)
© 2014 National Association of Insurance Commissioners
18
Attachment B
Line
#
IR4
IR5
ER1
Terms and Data
Elements
Definition
Reference
Does the company
have an additional
voluntary level of
review for
See definition of voluntary review level above.
grievances? Y/N
(Applies to all plans
and all metal
levels)
Number of
customer requests
for internal reviews
See definition of grievance for non-adverse determination.
of grievances not
involving adverse
determinations
Number of
customer
requested appeals
on final adverse
See definition of external review above.
determinations to
an external review
organization
© 2014 National Association of Insurance Commissioners
19
Attachment B
Line
#
ER2
ER3
Terms and Data
Elements
Number of final
adverse
determinations
upheld upon
request for
external review
Number of final
adverse
determinations
overturned upon
request for
external review
Definition
Reference
See definition of upheld decision above.
See definition of overturned decision above.
© 2014 National Association of Insurance Commissioners
20
Attachment B
B
C
3
Policy Administration
15
1 Earned premiums for Reporting Year
2 Number of policies issued
Number of Applications received by the carrier that
3
did not result in an issued policy
4 Number of lives on policies issued
5 Member months for policies issued
Number of policy terminations and cancellations
6
initiated by consumer
Number of policy terminations and cancellations due
7
to non-payment of premium.
Number of lives impacted on terminations and
8
cancellations initiated by the consumer
Number of lives impacted on policies terminated and
9
cancelled due to non-payment
10 Number of carrier initiated rescissions
Number of lives impacted by carrier initiated
11
rescissions
16
17
1 Number of claims received
7
8
9
10
11
12
13
14
18
19
20
21
22
23
24
25
26
27
28
E
F
G
For all Individual comprehensive major medical and
managed care (EHB compliant) policies - other than
multi-states policies
Health insurance coverage other than transitional,
grandfathered, multi-state, or student
2
4
5
6
D
H
I
J
K
L
M
N
O
P
Q
R
S
T
U
V
W
X
In Exchange (Note: there are two sections with the same questions. In Exchange would not include large group or student coverage. Out-of Exchange would not include Multi-State)
1
Claims Administration
2 Number of claims submitted by network providers
Number of claims submitted for by out of network
providers
4 Number of claim denials for in-network claims
Stratification by number of days -- 0-15, 16-30, 31 to
5
45, 46 to 90, 91 to 180, 181 to 360, 360+
3
6 Number of claim denials for out-of-network claims
Stratification by number of days -- 0-15, 16-30, 31 to
45, 46 to 90, 91 to 180, 181 to 360, 360+
8 Number of paid claims for in-network services
Stratification by number of days -- 0-15, 16-30, 31 to
9
45, 46 to 90, 91 to 180, 181 to 360, 360+
7
10 Number of paid claims for out-of-network services
11
Stratification by number of days -- 0-15, 16-30, 31 to
45, 46 to 90, 91 to 180, 181 to 360, 360+
12
Number of claims delayed due to untimely issuance of
policy
(Perhaps as an interrog: If more than 5% of your
claims are paid/denied past 90 days, please explain)
(c) 2014 National Association of Insurance Commissioners
Bronze
Silver
Gold
Platinum
For all Small Group Health Insurance Coveage
comprehensive major medical and managed care
(EHB compliant) policies - other than transitional,
grandfathered,or multi-state policies
Bronze
Silver
Gold
Platinum
Multi-State
(Individual)
Catastrophic
Bronze
Silver
Gold
Multi-State
(Small Group)
Platinum
Bronze
Silver
Gold
Platinum
Y
Z
Attachment B
B
C
3
29 12 Claims Paid Incurred Claims
30 13 Insured/beneficiary co-payment responsibility
31 14 Insured coinsurance responsibility
32 15 Insured deductible responsibility
33 Consumer Requested Internal Reviews
Number of customer requests for internal reviews of
grievances involving adverse benefit determinations
1
(Do not include additional voluntary levels of
34
reviews.)
36
Number of adverse benefit determinations upheld
2 upon request for internal review (Do not include
additional voluntary levels of reviews.)
Number of adverse benefit determinations
3 overturned upon request for internal review (Do not
include additional voluntary levels of reviews.)
Does the company have an additional voluntary level
of review for grievances?
Y/N
(Applies to all plans and all metal levels)
Number of customer requests for internal reviews of
5 grievances not involving adverse benefit
determinations
4
37
38
39
Consumer Requested External Reviews
40
Number of customer requested appeals on final
1 adverse benefit determinations to an external review
organization
2
Number of final adverse benefit determinations
upheld upon request for external review
3
Number of final adverse benefit determinations
overturned upon request for external review
41
42
43
E
F
G
For all Individual comprehensive major medical and
managed care (EHB compliant) policies - other than
multi-states policies
Health insurance coverage other than transitional,
grandfathered, multi-state, or student
2
35
D
H
I
J
K
L
M
N
O
P
Q
R
S
T
U
V
W
X
In Exchange (Note: there are two sections with the same questions. In Exchange would not include large group or student coverage. Out-of Exchange would not include Multi-State)
1
Total number of external reviews of final adverse
4 benefit determinations which either party appeals
after the external review decision
(c) 2014 National Association of Insurance Commissioners
Bronze
Silver
Gold
Platinum
For all Small Group Health Insurance Coveage
comprehensive major medical and managed care
(EHB compliant) policies - other than transitional,
grandfathered,or multi-state policies
Bronze
Silver
Gold
Platinum
Multi-State
(Individual)
Catastrophic
Bronze
Silver
Gold
Multi-State
(Small Group)
Platinum
Bronze
Silver
Gold
Platinum
Y
Z
Attachment B
B
C
Bronze
3
10
Policy Administration
1 Earned premiums for Reporting Year
2 Number of policies issued
Number of Applications received by the carrier that
3
did not result in an issued policy
4 Number of lives on policies issued
5 Member months for policies issued
Number of policy terminations and cancellations
6
initiated by consumer
7
11
12
13
14
15
8
9
Number of policy terminations and cancellations due
to non-payment of premium.
Number of lives impacted on terminations and
cancellations initiated by the consumer
Number of lives impacted on policies terminated and
cancelled due to non-payment
10 Number of carrier initiated rescissions
11
Number of lives impacted by carrier initiated
rescissions
Claims Administration
16
17
1 Number of claims received
18
2 Number of claims submitted by network providers
19
20
21
22
23
24
25
26
27
F
G
H
For all Individual comprehensive major medical and
managed care (EHB compliant) policies - other than
multi-states policies
Health insurance coverage other than transitional,
grandfathered, multi-state, or student
2
7
8
9
E
I
J
K
L
M
N
O
P
Q
R
S
T
U
V
W
X
Y
Z
AA
AB
AC
AD
Out of Exchange (Note: there are two sections with the same questions. In Exchange does not include large group or student coverage. Out-of Exchange does not include Multi-State)
1
4
5
6
D
Number of claims submitted for by out of network
providers
4 Number of claim denials for in-network claims
3
5
Stratification by number of days -- 0-15, 16-30, 31 to
45, 46 to 90, 91 to 180, 181 to 360, 360+
6 Number of claim denials for out-of-network claims
7
Stratification by number of days -- 0-15, 16-30, 31 to
45, 46 to 90, 91 to 180, 181 to 360, 360+
8 Number of paid claims for in-network services
9
Stratification by number of days -- 0-15, 16-30, 31 to
45, 46 to 90, 91 to 180, 181 to 360, 360+
10 Number of paid claims for out-of-network services
11
Stratification by number of days -- 0-15, 16-30, 31 to
45, 46 to 90, 91 to 180, 181 to 360, 360+
12
Number of claims delayed due to untimely issuance
of policy
(Perhaps as an interrog: If more than 5% of your
claims are paid/denied past 90 days, please explain)
28
29 12 Claims Paid Incurred Claims
(c) 2014 National Association of Insurance Commissioners
Silver
Gold
Platinum
For all Small Group Health Insurance Coveage
comprehensive major medical and managed care
(EHB compliant) policies - other than transitional,
grandfathered,or multi-state policies
Bronze
Silver
Gold
Platinum
Grandfathered
Large Group
Small Group
Catastrophic
Individual
For all Large Group comprehensive
major medical and managed care
(Minimum Essential Coverage)
policies
For Student
Coverage
Transitional Plans
Large Group
Small Group
Mini-Med
Individual
Large Group
Small Group
Short Term
Individual
Attachment B
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Q
R
S
T
U
V
W
X
Y
Z
AA
AB
AC
AD
Out of Exchange (Note: there are two sections with the same questions. In Exchange does not include large group or student coverage. Out-of Exchange does not include Multi-State)
1
For all Individual comprehensive major medical and
managed care (EHB compliant) policies - other than
multi-states policies
Health insurance coverage other than transitional,
grandfathered, multi-state, or student
2
3
30 13 Insured/beneficiary co-payment responsibility
31
32
14 Insured coinsurance responsibility
15 Insured deductible responsibility
Consumer Requested Internal Reviews
(Grievances)
33
1
34
35
36
Number of customer requests for internal reviews of
grievances involving adverse benefit determinations
(Do not include additional voluntary levels of
reviews.)
Number of adverse benefit determinations upheld
2 upon request for internal review (Do not include
additional voluntary levels of reviews.)
Number of adverse benefit determinations
3 overturned upon request for internal review (Do
not include additional voluntary levels of reviews.)
38
Does the company have an additional voluntary level
of review for grievances?
Y/N
(Applies to all plans and all metal levels)
Number of customer requests for internal reviews of
5
grievances not involving adverse benefit
39
Consumer Requested External
Reviews
40
Number of customer requested appeals on final
1 adverse benefit determinations to an external review
organization
4
37
2
Number of final adverse benefit determinations
upheld upon request for external review
3
Number of final adverse benefit determinations
overturned upon request for external review
41
42
43
Total number of external reviews of final adverse
4 benefit determinations which either party appeals
after the external review decision
(c) 2014 National Association of Insurance Commissioners
Bronze
Silver
Gold
Platinum
For all Small Group Health Insurance Coveage
comprehensive major medical and managed care
(EHB compliant) policies - other than transitional,
grandfathered,or multi-state policies
Bronze
Silver
Gold
Platinum
Grandfathered
Large Group
Small Group
Catastrophic
Individual
For all Large Group comprehensive
major medical and managed care
(Minimum Essential Coverage)
policies
For Student
Coverage
Mini-Med
Transitional Plans
Large Group
Small Group
Individual
Large Group
Small Group
Short Term
Individual
Attachment C
Market Regulation and Consumer Affairs (D) Committee
Action Items of the 2014 Market Regulation Summit
Progress Status – Dec. 17, 2014
Shaded Areas are Complete
Market Regulation and Consumer Affairs (D) Committee
1.
2.
3.
4.
5.
6.
7.
8.
Action Items and Deadlines for Completion
Action Items
7-31 8-31 9-30 10-31
In response to Federal Insurance Office
(FIO) recommendations, provide FIO
X
information regarding how states use the
Handbook and how it is updated.
(Addressed in draft memo to Government
Relations Leadership Council)
In response to FIO recommendations,
provide FIO detail on how states share
information with each other: NAIC
X
systems, NAIC bulletin boards, PICS
notifications, informal conversations at
meetings, review of publicly available
resources, etc.
(Addressed in draft memo to Government
Relations Leadership Council)
In response to FIO recommendations,
develop specific minimum qualifications
for contractors.
In response to FIO recommendations,
review and update core competency
addressing contract examiners.
In response to FIO recommendations,
recognize the evolution of states’ market
X
conduct examiners to market conduct
specialists.
(Addressed in draft memo to Government
Relations Leadership Council)
In response to FIO recommendations,
ensure contractors are required to provide
status reports to state insurance regulators,
and send a state employee to visit
contractors on site at examination.
(Addressed in draft memo to Government
Relations Leadership Council)
In response to FIO recommendations,
develop a list of contractors for
X
registration at the NAIC similar to what is
done for financial contract examiners.
Continue the NAIC partnership with the
X
National Conference of Insurance
Legislators (NCOIL).
© 2014 National Association of Insurance Commissioners
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X
X
X
Attachment C
9. Focus on creating a uniform process and
state accountability to the process as a
starting point for market regulation
accreditation.
10. Obtain state statutes that reference the use
of the Market Regulation Handbook.
X
X
Market Information Systems (D) Task Force
Action Items and Deadlines for Completion
Action Items
7-31 8-31 9-30 10-31
11-30
1. Ensure completion of Market Information
Systems (D) Task Force action plan.
2. Develop a system/database that better
shares information on actions other than
examinations.
3. Analyze the data currently in the NAIC
Market Information Systems to see what
was entered and what training needs to
occur to ensure better data quality (if
needed.)
4. Review the NAIC Market Information
Systems and develop a way that analysis
can be performed on an insurance group
basis instead of limited to the individual
company (CoCode) basis.
5. Find a way to allow state users of I-SITE
data to query the NAIC Market
Information Systems.
6. Monitor how state data entry to the NAIC
Market Information Systems has changed
after the action plan has been implemented.
12-31
2015
X
X
X
X
X
X
Market Conduct Examination Standards (D) Working Group
Action Items and Deadlines for Completion
Action Items
7-31 8-31 9-30 10-31
1. Review the Core Competencies to
determine which competencies need to be
X
updated.
2. Update the core competency addressing
contract examiners. Ensure contractors are
required to provide status reports to state
insurance regulators, and send state
employees to visit contractors on site at
examinations.
3. Consider revising the sampling procedures
outlined in the Market Regulation
Handbook to provide for greater flexibility,
© 2014 National Association of Insurance Commissioners
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X
12-31
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Attachment C
as appropriate.
4. Collect and then post a list of best practices
for state use of the Market Regulation
Handbook on MyNAIC.org.
5. Review Chapter 16 of the Market
Regulation Handbook (General
Examination Standards), and determine
which standards would not be applicable to
all exams so they can be moved to the
appropriate chapters.
6. Reevaluate the use of the 10% and 7%
tolerance thresholds outlined in the Market
Regulation Handbook.
X
X
X
Market Analysis Procedures (D) Working Group
1.
2.
3.
4.
5.
6.
7.
8.
9.
Action Items and Deadlines for Completion
Action Items
7-31 8-31 9-30 10-31
Develop routine trending reports for the
analysis of Market Conduct Annual
Statement (MCAS) data.
Develop a standard process for
determining MCAS outliers at the state
level.
Identify ways to notify companies that they
are attesting to the accuracy of MCAS data
and that entering incorrect data may result
in regulatory actions. This may include a
review of the attestation language.
X
(Because many incorrect filings are related
to life insurance, MAP should notify ACLI
of potential regulatory actions for incorrect
filings.)
Explore ways to obtain more current
market regulation data.
Establish a process for the better
coordination between states when issues
are identified during the analysis of the
MCAS data.
Establish a process for the better
coordination between states when
validation issues are identified during the
MCAS filing process.
Review the market analysis process, and
determine what analysis can be done on a
more frequent basis than annually.
Review analysis-related chapters of the
Market Regulation Handbook on a rotating
basis to ensure information is current.
Investigate ways to better tie complaints to
X
© 2014 National Association of Insurance Commissioners
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X
X
X
X
X
X
X
Attachment C
premium amounts. (Re-assigned from the
Market Information Systems (D) Task
Force.)
Market Actions (D) Working Group
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Action Items and Deadlines for Completion
Action Items
7-31 8-31 9-30 10-31
Distribute the Market Actions (D) Working
Group policies and procedures to all
X
regulators who participated in the Summit,
and make sure the procedures are available
on MyNAIC.org.
Make sure a summary of ongoing actions
is available to Collaborative Action
X
Designees after each Working Group
meeting or call.
Discuss ways to make the annual National
Analysis Project more of an ongoing
X
process.
Explore ways to make the Working Group
more proactive rather than reactive, such as
X
increasing Working Group-dedicated
resources.
Develop a process to fast-track referrals to
the Working Group that are close to
settlement.
Prepare a summary report of the National
Analysis Process that shows what activities
occurred because of the national analysis.
Explore ways to look at groups (and not
just individual companies) on a national
level. (Discussions Ongoing)
Consider ways to increase participation of
all states, such as (a) clarifying that a
state’s referral to the Working Group does
not commit the referring state to a role as a
X
lead or managing lead state and (b)
combining the NAIC’s Exam Tracking
Systems and Market Initiative Tracking
System for enhanced collaboration through
the Working Group.
(Discussions Ongoing)
Discuss the Working Group’s structure and
membership to evaluate whether
X
membership on a rotational basis would be
desirable. (Discussions Ongoing)
Review collaborative actions-related
chapters of the Market Regulation
X
Handbook on a rotating basis to ensure
information is current. (Discussions
© 2014 National Association of Insurance Commissioners
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X
X
2015
Attachment C
Ongoing)
NAIC Education & Training Department
Action Item and Deadline for Completion
Action Item
7-31 8-31 9-30 10-31
1. Develop a training program on how to
properly use the Market Regulation
Handbook.
11-30
12-31
2015
X
NAIC Market Regulation Department
Action Items and Deadlines for Completion
Action Items
7-31 8-31 9-30 10-31
1. Conduct annual webinars on Market
X
Regulation Handbook updates.
2. Conduct a webinar regarding Market
Actions (D) Working Group policies and
procedures. (On demand webinar
developed/notice needs to be sent to
regulators)
11-30
12-31
2015
12-31
2015
X
X
NAIC Information Systems Division
Action Items and Deadlines for Completion
Action Items
7-31 8-31 9-30 10-31
1. Train states on ways to query the data in
the NAIC Market Information Systems.
2. Develop training and webinars regarding
submission of data to each of the NAIC
Market Information Systems.
3. Identify and maintain a list of NAIC and
X
state contacts responsible for data entry.
W:\National Meetings\2014\Fall\Cmte\D\MR Summit Status\MR Action Items Final Status 121714.docx
© 2014 National Association of Insurance Commissioners
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