Ellen Sonkin—AIGJuly 23, 2014

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Confirm/validate the current state of PEO data reporting

Select best recommendation for enhancements within the current industry Data Standards

Review current industry Data Standards for POC and ER

Evaluate Data Needs for POC and ER

Evaluate carrier reporting requirements for regulatory compliance

Identify any enhancements to improve efficiency- With least disruption- Within industry standards

Assess all alternatives and recommendations

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To identify any issues/gaps/challenges in POC reporting: Reviewed current industry Data Standards (WCPOLS) for

Proof of Coverage◦ Evaluated PEO/Client Data Elements, including policy

types, P/C indicator, Adds and Deletes Reviewed reporting rules/requirements (IAIABC) that

vary by state◦ Client-level data—Employer legal name, job location,

FEIN Discussed state-specific requirements (NE, NV, IL) for

client notification of coverage and its status Discussed who is responsible party (PEO or Insurer) for

client notification and coverage status◦ Consider co-employees coverage; Replacement

coverage; Gaps in coverage

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Carriers have difficulty in obtaining client status and data details from PEO

Communications and education between the carrier and the PEO, and the PEO to its clients, such as:◦ Disseminating coverage information to the PEO

clients◦ Timeliness of coverage changes from the PEO to

the carrier for compliance reporting Identify changes at proper level to ensure

compliance◦ Communication of termination of coverage or

addition of coverage within POC compliance timeframes◦ Receipt of current client list to carrier from PEO

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Disconnects that may result in proof of coverage problems and/or queries Lack of establishing the accurate legal name and other

details and then maintenance of same over time Carrier challenges of validating data after receiving from

PEO Client changes to different business types, e.g. LLC and

or LLP◦ Clients or PEOs not updating all of their records in all

states where they conduct business◦ Client companies may fail to update the PEO with the

new changes in Names, Business types and FEINS, etc. Delayed client termination (sometimes month or two) Out of sequence of client adds/deletes

5

Carrier’s system limitation of adding client level detail◦ Some carriers may have limited space in

legacy systems Dependency on space allocations and data

input into various automation programs at multiple entry points and expenses associated with upgrades

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Lack of knowledge or misinterpretation of PEO/Client information from POC Users at State level

Searching outdated or deleted of W/C names and/or companies◦ Other state records or systems have not been updated in years

Lack of knowledge of how to look up a Master/MCP policy in POC database

States contact carriers to:◦ Verify if the PEO is covering all the employees of the client

company or if a client also maintains a separate WC policy in their own name

◦ Instruct clients to update their other state employer records with other state agencies Transmitted POC data is accurate, but in a different name than

displayed in other state records with other state agencies Separate policies in clients names are being misinterpreted as

duplicate coverage

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Current reporting process from carrier to NCCI is sufficient, and all data fields to support the reporting of PEO policies

and client detail data exist today

8

Have better communication between carrier and PEO, and PEO to its clients

Develop best practices/guidelines for carriers, PEOs and Client Companies (e.g. Published by NAPEO)

Provide education seminar or webinar (e.g. NCCI training for States):◦ New user training for state regulators to

access and inquire on database, and how to find the client details when the policy is in the name of the PEO

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Discussed current Data Requirements for Experience Rating◦ Reviewed manual Form NC2745◦ Explored any improvements to current requests for split data

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Carrier’s system limitation of adding clients Carriers currently provide manual Form NC2745 upon

PEO request only Obtaining/Identifying client level data◦ Reviewing audits and going back to history for client

exposure◦ Summing exposure information for client data

Identifying accurate payroll and claims information Getting data details from PEO for each client◦ Receiving and maintaining up-to-date changes

Contingent Experience Ratings result due to no trigger mechanism to follow up for updated losses/closed status on Form NC2745

Application of multiple revised PEO ratings

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No propose changes to industry WCSTAT standards or records for unit statistical reporting of Master Policy or

MCP policies

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Implement revise rules to keep experience of former clients in PEO’s modification—no revised rating of PEO

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Implement electronic reporting method to replace NC2745 Manual Form◦ Propose Electronic Layout (PEO Split Format) using NC2745 Manual Form data elements◦ Add new fields◦ Consider any implementation challenges for new PEO writers

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Suggest that NCCI create tracking mechanism to advise carrier for initial and subsequent requests of Client split data◦ Set due dates◦ Trigger when a client leaves the PEO NCCI receives data (Delete Employer

Transaction via endorsement) through WCPOLS

◦ Follow up for updated losses and closed status of claims

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