Avoiding Common Filing Errors

Transcription

1 2014 Industry Conference Navigating the Changing Insurance Environment Avoiding Common Filing Errors Life & Health Product Review Forms Staff October 30, 2014

2 Welcome Teresa Howell, Health Forms Analyst Supervisor James Dunn, Government Analyst II, Health Forms Tiffany Nelsen, Government Analyst II, Health Forms Jim Walker, Life Forms Analyst Supervisor 2

3 Highlights Include: Required filing content Expectations for a cover letter The importance of using the correct Product Code Other mistakes that can easily be avoided 3

4 Choosing the Correct Product Type: Avoiding an Incomplete Filing Teresa Howell, Health Forms Analyst Supervisor 4

5 Defined by Florida Rules and Statutes Rule 69O-154, F.A.C. Section , F.S. Examples: Minimum Standards for Benefits Major Medical Expense Basic Hospital, Medical, Surgical Expense Hospital Confinement Disability Income Limited Benefit (Critical Illness) Accident Only (Accidental Death & Dismemberment (AD&D) 5

6 Rule 69O (2), F.A.C. Each filing shall contain forms for only one type of coverage, i.e., Ordinary Life, Variable Life, Major Medical, etc. However, a filing may contain more than one form if the forms are for the same type of coverage. 6

7 What if You Have One Form That May Be Used With Multiple Products? 7

8 Accepted Multiple Lines of Business Filings Examples: Applications Riders Endorsements Amendments Health Other 8

9 What is Expected in a Cover Letter? James Dunn, Government Analyst II, Health Forms 9

10 Cover Letters Ensure the cover letter is complete Rule 69O , F.A.C. - State the nature of the filing - Is this a resubmission? If so, provide previous file log number. 10

11 Cover Letters Is this a combination filing? Are any other filings related? Health Life 11

12 Cover Letters Are there any related forms? File log numbers Forms numbers Approval dates 12

13 Cover Letters Rule 69O , F.A.C. Describe the distribution system Who is the target market? - If group, which statutory group? 13

14 Filing Requirements Tiffany Nelsen, Government Analyst II, Health Forms 14

15 Filing Requirements Correct product code The product code cannot be changed once a filing is submitted An incorrect product code will result in the filing being returned as Incomplete 15

16 Filing Requirements Cover letter Universal Data Letter (UDL) Forms checklist Policy Certificate Application/Enrollment form Riders/Endorsements/Amendments 16

17 Electronic Applications Certify compliance with the Uniform Electronic Transaction Act (UETA) Section (5), and (8), F.S. Certify agent involvement Section (1), F.S. 17

18 Supporting Documents Statement of Variability - Required if variability not defined in form - Must list all wording options, applicable circumstances, and numerical possibilities Section , F.S. Rule 69O (6)(c), F.A.C. 18

19 Supporting Documents Previous approval information - Rule 69O (6)(c), F.A.C. Filing authorization letter (if applicable) Flesch score certification - Section (3), F.S. 19

20 Actuarial Memorandum Supporting Documents - Forms only filings must have a signed actuarial memorandum - Must state: There is no impact on rates OR Rates are not required to be filed (provide a reason) Rule 69O (1)(b)6, F.A.C. 20

21 Reminders Form Numbers Each form must have a unique form number Form numbers should not be bracketed Section (4), F.S. 21

22 Reminders Types of Insurance Only one type of insurance submitted in each filing Disability Cancer Hospital Indemnity 22

23 Reminders Variable Benefits Forms with bracketed benefits: The unbracketed benefit determines the product code Forms providing multiple benefits: The predominate benefit determines the product code 23

24 Reminders Variable Benefits Riders attached to ONLY ONE base: File under base s product code Riders attached to MULTIPLE bases: File under rider s product code 24

25 Reminders 45 Day Review Period Ensure everyone working on the filing will be available for the duration of the filing Ensure every filing submitter has a back-up who knows the iportal password 25

26 Reminders 45 Day Review Period Contact person: - If out for vacation/extended leave, give access to a back-up staff member who can check their periodically for Office correspondence related to the filing - Use the additional address field and add other staff members who can receive Office correspondence about the filing Response due dates matter - Your filing may be disapproved for no response Rule 69O (6)(c), F.A.C. Section , F.S. 26

27 Annuity Suitability Information Jim Walker, Life Forms Analyst Supervisor 27

28 Annuity Suitability Information Description of the target market Description of any bonus feature Tracking sales Monitoring market practices Monitoring in-force business Corrective action Use of suitability forms Section (5), F.S. 28

29 Questions? Teresa Howell James Dunn Tiffany Nelsen Jim Walker 29