proof of coverage state-specific reporting · proof of coverage state-specific reporting ncci’s...

Proof of Coverage State-Specific Reporting

NCCI’S 2016 DATA EDUCATIONAL PROGRAM

January 26–29, 2016

Palm Beach County Convention CenterWest Palm Beach, FL

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© Copyright 2016 National Council on Compensation Insurance, Inc. All Rights Reserved.© Copyright 2016 National Council on Compensation Insurance, Inc. All Rights Reserved.

Proof of Coverage State-Specific Reporting

Presented By:

Amy Royce and Jorge Acevedo


2016 DATA EDUCATIONAL PROGRAM

Objective

To provide you with state-specific Proof of Coverage (POC) requirements and exceptions to ensure POC reporting success.

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Agenda

POC State Overview

POC Data Element Requirements

State POC Processing

POC and Professional Employment Organizations

POC State Exceptions and State Programs

Policy and POC Resources

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NCCI DAILY POC: AL, AZ, KS, MD, MO, OK, VA, WV

NCCI POC States

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POC INQUIRY ONLY: AR, DC, GA, IA, IL, LA, NV, SD, TX, VT

IAIABC: AK, CO, HI, ID, IN, KY, ME, MS, MT, NE, NH, NM, NY, OR, RI, SC, TN, UTCT, FL,

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POC Data Element Requirements



POC Data Elements

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Amy’s Beach Club#123456789

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Federal Employer Identification Number

Required by NCCI and all POC states

NCCI returns Data Grade 7 edit for missing or invalid Invalid edit is limited Enhanced edit in November 2015 Employer records held Coming soon in Q4: Hold condition

removed

IAIABC Reject

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POC Data Elements

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State Unemployment Identification Number

UI, UIAN, DOL#

Required and will reject (TR) Maine Utah—if UI unknown, report seven zeros

Required and will accept with errors (TE) Rhode Island

Required and will send Criticism letter Hawaii

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POC Data Elements

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Manufacturing Contracting Office & Clerical Goods & ServicesMiscellaneous

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Industry Code

NAICS vs SIC

Data Grade 7—Missing or Invalid FL, KS, KY, ME, MT, NM, OR*, WV

*NCCI edits on Oregon for Policy Effective Date 7/1/15 and later only

IAIABC Transaction Reject FL, KY, ME, MT, NM, OR*

*Oregon will reject on Policy Effective Date 7/1/2015 and later only

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POC Data Elements

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Prior Policy Number

Renewal Rejected for Prior Policy Number No match on database because state was not on prior term Maine and Kentucky Contact NCCI NCCI will manually resend as an Add

Jurisdiction transaction

IAIABC 3.0 provides Reason State Was Added to Policy Code

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POC Data Elements

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Insurer FEIN

New writers (affiliated and licensed) in states need to have their FEIN added to states trading partner table before sending first policy

Following states will reject POC AK, CO, FL, ME, NE, NM, OR, RI, SC, TN

State special forms KY and NY

All instructions provided through POC State Guide

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State POC Processing

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Hold Conditions

NCCI currently holds Employer Records from POC data file for: Missing or invalid FEIN (All states) Missing or invalid UI (ME) All names and addresses linked together

(All states) Unlinked names and addresses (All states)

Policy data receives Data Grade 7 Uncorrected data viewable in Monthly

Data Grade 7 Report

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Hold Condition Changes

NCCI will no longer hold Employer Records in 4Q 2016 Missing or invalid FEIN Missing or invalid UI All names and addresses linked together

NCCI will continue to alert through Data Grade 7 on NCCI reports

POC state may reject and alert on IAIABC reports

Note: Unlinked names and unlinked addresses will continue to be held

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Address Reporting for POC

When employer does not have physical location in jurisdiction:

Report Address Type 6

Report Address Type 2—Out of State Address

Note: Not all states accept both types of addresses

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Data Grade 8 Address Record rejects implemented January 7, 2016

Circular and State Applicability Chart published October 2015 (in Supplement)

POC State Guide updated to reflect requirements

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States that do not accept Address Type 6 Employer Records: AZ, IA, IN, KY, MT, OK, TX

States that do not accept Address Type 2—Out-of-State type Employer Records: AK, CO, FL, ID, MD, NM, OR, UT

All other POC states will accept either type of address

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Received Dates

The following states DO NOT recognize NCCI Received Date as their Received Date: HI, KY, ME, NH, NY, OR

State considers Received Date as the date the transaction is accepted

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Continuous Coverage

Nonrenewals are required to expire coverage at Policy Expiration Date

The following POC states are considered Continuous Coverage states: AK, DC, FL, ID, IL, KY, MD, MS, MT, NE,

NH, NY, RI, SC, TX, UT, VT

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Continuous Coverage

Other states that require Nonrenewals, however, do not call themselves Continuous Coverage: AZ, MO, NV, NM, VA

If Nonrenewals are reported, they are not sent to the following states: CO, ME, OK

Check POC State Guide for requirements

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POC Coverage Notice/Binders

State Filing Requirements

Not allowed in Idaho and Maine

Be Careful When Entering Florida does not extend filing requirement New Hampshire employers

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So What If?

2015 Policy term covered five states

2016 Renewal only covers four states

State not covered on Renewal is New York (Continuous Coverage state)

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How would you end coverage for New York?

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State-level NonRenewals

State-level Nonrenewal to be accepted in Q4 2016 for multistate policies

Change to WCIO WCPOLS State Code applicability scheduled for Spring 2016

State-level Nonrenewal—looking at State Code when reported

State-level Reinstatement only accepted for State-level Nonrenewal

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State-level Nonrenewals

Full Reporting rules provided in circular Must reinstate each state prior to

accepting a Cancellation Must reinstate each state prior to

accepting a Policy Level Nonrenewal If State-level Reinstatement and Policy

Level NonRenewal are submitted the same day, original Received Date will be retained

Cannot nonrenew a state on a Cancelled policy

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State-level Nonrenewals

Scenario #1 Policy Effective 01/01/2016—1/01/2017 Multistate policy covering NY, OK, and OR NY will not be on 2017 Renewal Filing Requirement—30 days prior to effective

date of nonrenewal Report Transaction 05

Cancellation/Reinstatement ID Code 3 State Code 31 Effective Date 01/01/2017

Report 01/01/2017 Renewal with OK and OR

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State Level Non-Renewals

Scenario #2 Policy Effective 01/01/2016—01/01/2017 Multistate policy covering FL, NY, OK, and OR

FL and NY have been Nonrenewed

Now need to Nonrenew full policy

Report 2 Transaction Code 05 Cancellation/Reinstatement ID Code 2 State Code 31 and 09 Effective Date 01/01/2017

Report 1 Policy Level Nonrenewal

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State Level Non-Renewals

Scenario #2 Continued

If State-level Reinstatements and Policy Level Nonrenewal reported in same day:

NY and FL will not receive transactions Original State-level Nonrenewal still in effect

OR will receive Nonrenewal

OK will not receive NonrenewalAnyone know why?

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IAIABC Update

States evaluating 3.0 format: Florida Montana New York

IAIABC developing POC training webinar for release in 2016

POC “Community” section on iaiabc.org

Request in pipeline for Employer Email Address reporting

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Proof of Coverage and Professional Employer

Organizations



POC and PEO Reporting

Oregon

Master Policies = PEO Policy Type 2 All employees (leased and nonleased) are

covered All clients should be reported on PEO Policy

Types 4 or 5, which are used for Experience Rating purposes only State requires PEO to report client information

directly to state

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POC and PEO Reporting

Florida State database used to check validity of PEO

status Will reject for PEO Policy Type 8

Virginia Only one licensed PEO reported per policy

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POC State Exceptions and State Programs

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Hawaii

IAIABC POC 3.0 implemented October 2013

State still unable to process change transactions

Manually updating state system with NCCI POC or data received on WC36 forms

State Email Communication process

Potential future fining program based on timeliness of corrections only

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Idaho

Record Type 43 required to capture Losses Subject to Deductible Code

Compare process with Idaho Fiscal Department

NCCI will perform carrier outreach if necessary

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Maine

Matches POC to existing Department of Labor database

Matching criteria is FEIN, UIAN, and Address (not Name)

Provides separate error code in state comment section of IAIABC Error/Reject report Link to list of error messages in POC

State Guide

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Maine

If Name Standardization splits names, Maine considers second part a duplicate and will reject* Ex: Jorge Acevedo dba Jorge’s BBQ

Maine will provide correct UIAN if necessary—email contacts available

Fines for timeliness

Appeal process in place

*Name Standardization changes coming!

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New Hampshire

If you report a NH State Premium Record, you must report at least one NH employer Address Type 2 or 6 linked to State Code Link 28

Matches POC to existing DOL database

Matching criteria is Name, FEIN, and Address

NH employers reported on POC Notices

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New Hampshire

Fines for timeliness Fines are per employer, not policy Looking at making changes due to Assigned

Risk policy assignment date, insured originating changes, and changes due to audits Appeal process in place

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New York

Same prior policy number cannot be reported on multiple renewals If you split coverage at time of renewal, you

need to report one as New and one as Renewal

Opt-In POC state Form in POC State Guide NYWCB website allows for changes but consult

with NCCI first

Fines for timeliness of establishing coverage and midterm cancellations


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Oregon

Performs additional editing on FEINS and will reject

PEO reporting

Fines for timeliness of establishing coverage and midterm cancellations


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Utah

Requires UI number

Utah will provide correct UI number through online look-up tool or via email

Penalty process in place Changes in process announced in FYI

December 2015. No longer penalizing: Add/Delete Employers Add/Delete Jurisdictions Insured/Employer FEIN changes Changes to Policy Effective Date

Performance threshold still 99%

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Virginia

If you report a VA State Premium Record, you must report at least one VA employer Address Type 2 or 6 linked to State Code Link 45

Matches POC to existing DOL database

Matching criteria is Name, FEIN, and Address

Fines for timeliness Fines are per policy Made changes to look at assignment date on

Assigned Risk policies Appeal process in place

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Policy and POC Resources



Policy Resources for POC

Policy and Proof of Coverage Reporting Guidebook POC data element requirements by state

POC State Guide State contacts Filing requirements Exceptions

Data Manager Dashboard Monitor POC state timeliness

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Other POC Services

Coverage Verification Service (CVS) 32 of 38 POC states have link on their websites Public access Search by Employer Name or FEIN Coverage date driven

Workers Compensation Coverage Verification (WCCV) Mobile application through Apple, Google, or

Windows stores All 32 states available

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Questions

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Supplemental Information

Presenter Biographies

Amy Royce joined NCCI 20 years ago and is currently a consultant in the Data Services Department of Data Resources. Her primary responsibilities include Proof of Coverage management and industry communication. She also represents NCCI on the International Association of Industrial Boards and Commissions POC Committee.

Amy earned a bachelor’s degree in human resource management from Palm Beach Atlantic University in Florida as well as Associate of Commercial Underwriting (AU) and Associate in General Insurance (AINS) designations.

Jorge Acevedo has been with NCCI since 2005. He is the Proof of Coverage lead data analyst on the Policy/Proof of Coverage Team in the Data Collection Department. Prior to joining Data Collection in 2007, he worked in the Experience Rating Department as an analyst.

Jorge’s professional background includes technical support for a major computer company and fraud detection for an Internet hosting company.

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