© 2008 National Association of Insurance Commissioners Insurance Consumer Affairs Exchange Marian Drape Information Systems Division Market Information Systems Team September 30, 2008 NAIC Complaint Data What Comes In What Goes Out

© 2008 National Association of Insurance Commissioners CMS CIS I-SITE Closed Consumer Complaints

© 2008 National Association of Insurance Commissioners Agenda What Comes In –Where do we get complaint data? –When do we get complaint data? –What data do we get? –What do we do with complaint data? What Goes Out –CMS –CIS –I-SITE Questions?

© 2008 National Association of Insurance Commissioners A Complaint Is… Any *written communication that expresses dissatisfaction with a specific person or entity subject to regulation under the state's insurance laws. Market Regulation and Consumer Affairs (D) Committee, June 13, 2006 *Note: An oral communication, which is subsequently converted to a written form, will meet the definition of a complaint for this purpose.

© 2008 National Association of Insurance Commissioners What Comes In

© 2008 National Association of Insurance Commissioners Where do we get complaint data? State insurance departments Voluntary Electronic transmission

© 2008 National Association of Insurance Commissioners When do we get data? Monthly - 2 nd business day Daily

© 2008 National Association of Insurance Commissioners What data do we get? Closed Consumer Confirmed/Unconfirmed Firm/Individual Medicare Types of Insurance

© 2008 National Association of Insurance Commissioners NAIC Standard Complaint Data Complaint identification Complaint against Complainant/Insured information Type of coverage Reason for complaint Disposition

© 2008 National Association of Insurance Commissioners

Complaint Identification State State complaint number Date opened Date closed

© 2008 National Association of Insurance Commissioners Complaint Against Name Address NAIC company code FEIN National producer number Date of birth

© 2008 National Association of Insurance Commissioners Complainant/Insured Zip code Age group Complainant type –Insured, beneficiary, military personnel

© 2008 National Association of Insurance Commissioners First Level Coverage Auto (8) Fire, Allied Lines, CMP (7) Homeowners (7) Accident & Health (4) Life & Annuity (7) Liability (6) Miscellaneous (18)

© 2008 National Association of Insurance Commissioners Second Level Coverage Auto (17) Fire, Allied Lines, & CMP (7) Homeowners (13) Accident & Health (24) Life & Annuity (11) Liability (24) Miscellaneous

© 2008 National Association of Insurance Commissioners Reasons Underwriting (29) Policyholder Service (22) Claim Handling (36) Marketing & Sales (30)

© 2008 National Association of Insurance Commissioners Dispositions 45 disposition codes Determines confirmed complaint –At least one disposition is confirmed

© 2008 National Association of Insurance Commissioners Dispositions Unconfirmed dispositions –Unable to assist –Cancellation upheld –Non-renewal upheld –No action requested/required –Referred to proper agency/section –Company in compliance –Company position upheld –No jurisdiction –Insufficient information

© 2008 National Association of Insurance Commissioners What do we do with the data? Validate Load Quality Present

© 2008 National Association of Insurance Commissioners Validate Form and format Entity Error resolution –NAIC Transmission Viewer –Internal NAIC applications

© 2008 National Association of Insurance Commissioners Load All valid data CDS – Complaints Database System

© 2008 National Association of Insurance Commissioners Complaints Database System – CDS operational – Expansion of coverage types, reasons, dispositions – MAP (D) Working Group review of complaint handling and reporting

© 2008 National Association of Insurance Commissioners Complaints Database System 10 year retention 2,000,000+ complaints 22,000+ Medicare complaints

© 2008 National Association of Insurance Commissioners Quality Frequency –Monthly Currency –Within last month Accuracy Completeness

© 2008 National Association of Insurance Commissioners Quality Firm/Individual Life, Health & Annuity/Property & Casualty Confirmed/Unconfirmed Medicare Use of ‘other’ Error rate

© 2008 National Association of Insurance Commissioners Quality Market State Audit System –Compare state data to data in CDS –Identify discrepancies –Suggest resolutions

© 2008 National Association of Insurance Commissioners Quality MIS Metrics –Counts –Timeliness –Error rates –Types of complaints

© 2008 National Association of Insurance Commissioners Metrics

© 2008 National Association of Insurance Commissioners Quality Participating state reports –Counts –Earliest/most recent submission dates –Earliest/most recent closed complaint dates

© 2008 National Association of Insurance Commissioners What Goes Out

© 2008 National Association of Insurance Commissioners CMSCISI-SITE Who has access? Federal government Public State insurance regulators Types?Medicare Confirmed only All Risk bearing entities Retention? 3 years plus current 10 years

© 2008 National Association of Insurance Commissioners Complaints in CMS Centers for Medicare & Medicaid Services State’s compliance with OBRA 1990 Quarterly Data sent from NAIC’s Government Relations Office

© 2008 National Association of Insurance Commissioners Complaints in CIS

© 2008 National Association of Insurance Commissioners Complaints in CIS Closed Consumer Risk bearing entities Confirmed –At least one disposition is confirmed Three years (plus current, if applicable) Voluntarily reported by states Public data

© 2008 National Association of Insurance Commissioners Complaints in CIS Complaints against a selected risk bearing entity –4 reports Aggregate consumer complaints reports –3 reports

© 2008 National Association of Insurance Commissioners Complaints in CIS Complaints against a selected risk bearing entity –Counts by state –Counts by code –Trend –Ratio

© 2008 National Association of Insurance Commissioners Counts by State Report For selected company By state Filters –By year –By complainant

© 2008 National Association of Insurance Commissioners Counts by Code Report For selected company By code –Coverage –Reason –Disposition Filters –By year –By complainant

© 2008 National Association of Insurance Commissioners Trend Report Change in complaint counts –Total –Percent Three year trend Filters –By complainant

© 2008 National Association of Insurance Commissioners Ratio Report Company’s complaint index National median complaint index Filters –By year –By insurance type

© 2008 National Association of Insurance Commissioners Complaints in CIS Aggregate reports –By type of insurance –By reason –By disposition Updated monthly

© 2008 National Association of Insurance Commissioners Complaints by Type of Insurance Summary –Seven primary coverage types –By year Detail –All secondary coverage types –By year

© 2008 National Association of Insurance Commissioners Complaints by Reason Summary –Top ten reasons –By year Detail –All reasons –By year

© 2008 National Association of Insurance Commissioners Complaints by Disposition Counts By year

© 2008 National Association of Insurance Commissioners Complaints in I-SITE All 10 years Voluntarily reported by states Regulator only

© 2008 National Association of Insurance Commissioners Complaints in I-SITE Complaints against a selected entity –Counts by state –Counts by code –Trend –Index Summary Market analysis

© 2008 National Association of Insurance Commissioners Count, State, Trend Reports States/regions Complainant Role code Medicare supplement policy Date range More selection criteria

© 2008 National Association of Insurance Commissioners Complaint Index Report Selection criteria –States/regions –Policy type –Premium year –Complaint year Results for confirmed and total (complete) complaints

© 2008 National Association of Insurance Commissioners Complaint Summary Report List of risk bearing entities Complaint and market share statistics Selection criteria –Policy types –By state or region –Comparison to other states or regions –All or confirmed

© 2008 National Association of Insurance Commissioners Using Complaints in I-SITE Market analysis Coordination with other states Target insurance company exams Compare complaints with premium volume Compare complaints with other entities Trending of business practices Identify need for regulatory action Public disclosure of complaints data

© 2008 National Association of Insurance Commissioners CMS CIS I-SITE Closed Consumer Complaints

© 2008 National Association of Insurance Commissioners Marian Drape