State Filings

State Filings Pulse: Latest Filing Statistics and Trends Now Available

by Brett Horoff

Perr&Knight has released the inaugural edition of State Filings Pulse, a quarterly publication that provides the insurance industry with insight into filing approvals in each state. These up-to-date filing statistics enable companies to observe the latest state filing trends more effectively. 

Want to explore State Filings Pulse? To obtain a free copy of the publication on a quarterly basis, please register at the following link: https://www.perrknight.com/insights/guides-white-papers/state-filings-pulse/

Information from 900,000+ filings

State Filings Pulse contains statistics, by state, for calendar years 2019 through 2023, including:

  • Median number of days from filing submission to approval
  • Disapproved filings as percentage of total closed filings
  • Withdrawn filings as percentage of total closed filings
  • Percentage of rate filings with approved rate change less than proposed rate change

The filing statistics are displayed on a combined basis for all property and casualty (P&C), filings excluding workers compensation, mortgage guaranty, financial guaranty, and title filings.

Additionally, the filing statistics are broken out separately for homeowners, personal auto, and other filings, which primarily include commercial products. They are also shown by filing type, rate filings, and excluding rate filings where rate filings are defined as filings that have a non-zero rate impact. Below is a sampling of the filing statistics for California.

How does State Filings Pulse help insurance companies?

As a leading provider of actuarial consulting and state filings services, we are often asked questions such as: 

  • How long does it take to obtain approval of a filing in a state?
  • Will the state disapprove or request a withdrawal of a filing? 
  • What is the probability the state will request a reduction in the proposed rate change? 

Our experienced state filings team keeps close track of statistics regarding approvals, rejections, and state-specific regulatory requirements. This knowledge empowers us to help our clients improve speed-to-market by ensuring that every filing meets supporting documentation and rate requirements, thereby reducing the risk of an objection.

By compiling and sharing this useful information, we aim to support insurance companies, insurtechs, and others within the industry in gaining a broader perspective on the state filings process. 

Download Your Copy of State Filings Pulse

All the information above – plus many more state-specific statistics – is now available in the Q4 2023 State Filings Pulse publication. Click here to obtain your free copy of State Filings Pulse and contact Perr&Knight with any questions.

Empowering Insurance Carriers and Program Managers with StateFilings.com

by Khushboo Jashnani

In the contemporary insurance landscape, insurance carriers are often looking to expand into niche or specialized markets without needing to develop their own in-house expertise. However, often they lack the skill set, distribution networks, and/or local knowledge required to tap into these unique markets effectively. This is where ‘Program Managers’ step in as essential partners in the insurance industry.

Program Managers often specialize in specific lines of insurance or industry segments, which allows carriers to access these markets more effectively. Program Managers are entrusted with underwriting multiple insurance policies on behalf of the insurance companies they collaborate with, allowing them to evaluate price risks, issue policies, and make decisions about policy terms and conditions. This collaborative relationship unlocks a world of opportunities for insurance carriers, enabling them to expand their market reach without the need to build and maintain their own distribution networks.

As a result, insurance carriers are often faced with the challenge of effectively managing the diverse range of program managers also sometimes referred to as ‘Managing General Agents (MGAs)’. On the flip side, program managers grapple with the distinct challenge of gaining comprehensive access to an array of filings, forms, and rules that are pertinent to the numerous insurance carriers with whom they collaborate.

Unleashing Streamlined Capabilities for Enhanced Insurance Management

Acknowledging this pressing need, StateFilings.com has emerged as a game-changer in the industry, providing a cutting-edge insurance state filings software that solves the challenges of program managers and insurance carriers that result from their unique relationships. As an industry leader for rate, rule, and form filings, StateFilings.com’s secure web-based application offers a user-friendly interface that centralizes essential information, offering access to projects, filings, forms, rates/rules, and activities across all authorized accounts.

By utilizing StateFilings.com, insurance carriers, and program managers gain unparalleled insights and comprehensive tools to facilitate insurance management on behalf of their clients. Here are some of the key functionalities that StateFilings.com offers to empower program managers and insurance carriers within the insurance state filings software platform.

Benefits for Insurance Carriers

  1. Project Organization: On StateFilings.com, filings are organized by project. A project can include multiple states and lines of business associated with a single program. This structure enables insurance carriers to provide program managers access exclusively to the specific projects associated with their programs. During project creation, insurance carriers have the ability to select the projects to which program managers should be granted access. This ensures seamless collaboration and an organized workflow. In contrast, SERFF does not categorize filings by projects, introducing an extra layer of complexity to the collaboration process.
  2. Proactive Email Notification: Automated submission, approval, and objection notifications are dispatched to insurance company employees and program managers with filing access, ensuring they receive real-time updates on project and filing activities. This allows insurance company personnel to monitor program filings in the insurance state filing software while relieving them of the burden of keeping program managers informed.
  3. Robust Search Engine: StateFilings.com features a robust search engine, providing insurance company employees and program managers with quick access to relevant information. However, this functionality comes with a built-in safeguard – program managers can only search for items to which they have access, ensuring data integrity. This feature not only enhances efficiency but also maintains security by limiting access to authorized data, safeguarding sensitive information, and ensuring compliance with data privacy regulations.
  4. Comprehensive Access to Forms and Rate/Rule Library: The insurance state filings software interface offers insurance company employees access to their extensive library of forms and rate/rules along with a user-friendly search feature. The ability to search by various criteria like states, dates, and TOIs empowers company personnel with the information they need at their fingertips, facilitating faster decision-making by reducing the time and effort required to find pertinent resources.

Benefits for Program Managers

  1. Unified Login: Each program manager is granted a single, unique login with read-only access to their designated projects which can be selected from multiple insurance carriers. This personalized approach ensures that program managers can efficiently manage their responsibilities without having to rely on insurance carriers for updates on their filings. In contrast, utilizing SERFF to access filings requires program managers to manage multiple logins, one for each insurance company they collaborate with, resulting in added complexity and inefficiency within the process.
  2. Real-Time Email Alerts: Automated email notifications offer real-time project submission and approval updates to program managers, and program managers can receive automated email alerts when objections are received. This ensures that program managers can respond swiftly to any issues, ensuring project progress stays on track and reducing delays.
  3. Empowering Search Engine: The search engine facilitates easy access to projects, filings, objections, forms, and rules, enhancing program managers’ efficiency. Restricting search capabilities to only accessible items maintains data integrity and security, ensuring that program managers can confidently work within their designated programs.
  4. Tailored Access to Forms and Rate/Rule Library: This feature empowers program managers to access the approved materials for their specific programs, providing an organized view of both countrywide and state-specific versions of forms. This feature simplifies resource management, supports compliance, and streamlines decision-making.

The featured functionalities of the insurance state filings software hold immense significance for both insurance carriers and program managers, directly addressing critical challenges within the insurance industry.

In this new era of insurance management, StateFilings.com stands out as the go-to solution, providing program managers and insurance carriers with the tools they need to navigate the dynamic landscape and thrive in a competitive market. The platform’s commitment to excellence and customer-centricity cements its position as an invaluable asset to program managers, insurance carriers, and the entire insurance ecosystem.

Contact us to see a demo of our insurance state filings software: StateFilings.com.

Mastering Insurance Product Filings: Your Path to Precision and Efficiency

by Ashley Allen

Improving efficiency in state filings is becoming increasingly important for insurance companies in today’s competitive and regulatory-intensive landscape. Streamlining the filing process reduces operational costs and expedites product time-to-market, allowing companies to capitalize on market opportunities faster. Additionally, an efficient process minimizes regulatory risks, fostering compliance such to avoid potential penalties or reputational harm.

The launch of the System for Electronic Rate and Form Filing (“SERFF”) in 1998 represented a giant leap forward in efficiency. Members of an insurance company’s state filing departments could submit and track filings electronically, drastically reducing busywork and enabling teams to focus on bigger-picture thinking, like spotting trends and making sense of complex rate and rule filings.

Partnering with experts ­and leveraging easy-to-use state filing software reduces errors, enables better tracking of submissions, and accelerates the path to approval.

Swift Responses to Administrative Delays

The COVID-19 pandemic introduced delays for the Department of Insurance’s (“DOI’s”)  approval process, creating additional hurdles for insurers. The insurance filing support experts at Perr&Knight have longstanding relationships with all DOIs and can provide valuable insight into which ones are experiencing backlogs and how to minimize the expected time to gain approvals.

Two-way API-enabled communication between StateFilings.com and SERFF automates updates with status information, visible in real-time. This functionality empowers our filing support teams to identify delays immediately and rectify any issues.

Unparalleled Efficiency with Support from Digital Tools

The remote work era has underscored the importance of digital solutions that unify team members from wherever they are working. With seasoned, credentialed actuaries located across the country, Perr&Knight maintains a long history of collaboration between team members who are not in the same location everyday. This geographic dispersion enables us to deliver boots-on-the-ground support to clients nationwide and develops strong, local connections with regulators in various state DOIs.

Perr&Knight uses StateFilings.com as a shared hub for submitting and tracking filings wherever our clients operate. StateFilings.com is a web-based software hosted on a secure server, allowing our teams and clients access to the software from any web-enabled device, allowing visibility into the filing(s) without having to dig through files on local devices or await a callback from another team member. 

While person-to-person contact will always be welcome, the software is designed to enable teams to leverage advanced project management, research, and workflow assignment features that streamline collaboration and enhance productivity.

Gaining a Macro Perspective

To succeed in the complex world of insurance state filings, you must identify trends in DOI behavior and learn from rejection patterns. Our credentialed actuaries have decades of experience filing across lines of businesses throughout the nation. Not only do we monitor current trends, but our deep experience enables us to grasp the intricacies of DOI interactions and build robust relationships with DOIs – all benefits that help avoid costly errors and sidestep pitfalls on your path to approvals.

The Advantages of Partnering with Experts

Advanced technology can instantly elevate your day-to-day state filing operations. Still, there is no replacement for collaboration with seasoned experts who understand the nuances of filing across LOBs and jurisdictions.

Guided by deep industry expertise and supported by StateFilings.com – innovative insurance state filing software we developed for our own use – the experienced filing support team at Perr&Knight has optimized the process to keep insurance companies ahead of regulatory changes to speed their time-to-market. 

At Perr&Knight, we recognize the value of human relationships in enhancing business processes. This is why we maintain strong professional relationships with the DOIs as well as our clients. By using technology to our advantage, we do what we do best: help our clients become more efficient and effective at managing state filings.

Contact Perr&Knight today to learn how we can help you master your state filings process.

10 Questions to Ask a State Filings System Vendor

by Patrick Light

Authors: Patrick Light and Dana Pagliarulo, PMP, PMI-ACP

When it comes to choosing a state filings system vendor, it’s important to do your due diligence and ask the right questions. After all, your state filings system is a critical part of your business, and you want to get the best possible functionality, service, and support.

Here are 10 questions to ask a state filings system vendor:

1. Does the system vendor have a full-time Chief Technology Officer (“CTO”)?

Having a dedicated full-time CTO on staff is a sign that the vendor takes state filings technology seriously and has the expertise to provide a strategic vision and high-quality service and support.

2. Is the system vendor SOC 2 Type 2 certified?

SOC 2 Type 2 certification is important for software vendors because it provides a level of assurance to their customers that the vendor has implemented effective controls to ensure the security, availability, processing integrity, confidentiality, and privacy of their systems and data.

SOC 2 Type 2 is a rigorous auditing standard developed by the American Institute of Certified Public Accountants that requires companies to demonstrate that they have established and followed strict information security policies and procedures. The Type 2 certification requires the vendor to demonstrate that their controls have been in place and operating effectively for a minimum of six months.

By obtaining SOC 2 Type 2 certification, software vendors can demonstrate to their customers that they take the security and privacy of their customers’ data seriously and have implemented appropriate safeguards to protect it. This can be especially important for vendors that handle sensitive data, such as financial or trade secret information, as it can help to build trust and confidence in their services.

3. Does the state filings system vendor have adequate staff to deliver enhancements?

It’s important to ensure the vendor has enough staff to handle ongoing enhancements and improvements to the system. This will ensure that your system remains up-to-date and meets your evolving needs.

4. Does the system vendor provide a customizable system?

A customizable state filings system can help you tailor the system to meet your specific needs and preferences. Individual insurance companies have processes tailored to their best efficiencies. Ensure that the vendor provides this feature including custom fields and configurable workflows.

5. Does the system vendor support bureau-based products?

Insurance Services Office and American Association of Insurance Services are rating bureaus (to name a few) that offer products that are constantly evolving. Having tools at your fingertips to assist with monitoring circular changes, and streamlining the adoption process can save money and get your products to market in a compliant fashion faster. Monitoring of bureau circulars specific to those that are underwritten by your company and quickly integrating them into filings is a feature that should not be overlooked. Inquire how this process is handled by the vendor and look for as much automation as possible and how many touch points are required by your staff. Lower touch points and higher automation are a win.

6. Does the system vendor support program business?

Fronting companies and Program Managers have unique needs when it comes to organizing and querying filings, forms, and rules. Fronting companies need access to projects and filings for its various Program Managers. At the same time, Program Managers may need access to filings from the various fronting companies they use to write business. Make sure your system vendor is capable of handling these complex queries and the various types of access so your data is organized, easy to access, and only provides access to users where required.

7. Does the system vendor integrate with external software and tools?

Integration with the National Association of Insurance Commissioners (“NAIC”) System for Electronic Rates & Forms Filing (“SERFF”) via an Application Programming Interface ensures direct communication between your filing team and the individual state filing analysts/reviewers. In addition to integration with SERFF make sure your system vendor can integrate with your internal systems via API’s and Web Hooks. Ask to see a list of third-party products and services that the vendor currently integrates with and the type of integration (e.g., push, pull).

Additional integrations may fit your company’s work culture, such as Microsoft Teams, to encourage more real-time inter-team communication.

8. Does the system vendor integrate with industry standard Single Sign-On (SSO)?

With all of the internal and external tools and applications used in a modern workforce, tracking multiple passwords and being slowed down by login screens is a pain point many companies are looking to remove. Single Sign-On is the current mainstream solution to this providing authentication at the corporate level and passing authentication tokens to external applications, like a state filing tracking system. Be sure your system vendor currently supports SSO or at least has it in their roadmap.

9. Does the system vendor keep up with changing workflows and requirements with the state filing process?

Building software applications is as much about the analysis of the business as it is about technology. It is important that the vendor has first-hand knowledge about the workflow and filing approval process, enabling the vendor to utilize this information to develop an accurate and streamlined experience. Although a vendor could build and maintain an application without such experience, the precision could be lower and time to implement could be longer. Seek a vendor who processes state filings and uses the system themselves for the best possible support.

10. Does the system vendor provide functionality and support beyond what you get within SERFF?

For decades, NAIC’s SERFF has provided basic functionality required to submit and track state filings. An alternative state filing system must provide important value-add features to the process that drives efficiency and simplicity. Some examples of value-add features include, but are not limited to, robust reporting, dashboards, enhanced form/rule/filing templates, a robust notification engine and an at-a-glance project/state status.

Perr&Knight satisfies or exceeds all 10 items outlined above. Learn more with a live demo.

Contact us to schedule your demo.

How to Navigate the California Rate Filing Environment

by Brett Horoff

Many insurers are struggling to obtain additional rate in California to address unprofitable programs and elevated loss trends. State Farm’s recent announcement in May 2023 that they will stop accepting new business for homeowners shines a spotlight on the issues with the California marketplace. While State Farm made a public announcement, Allstate quietly notified the state of their decision to stop writing new homeowners business (including condo) and commercial policies within the last year. AIG also decided in early 2022 to exit from the admitted homeowners market in California.

How long does it take for filings to be approved?

In Chart 1 below, we have displayed the time to approval for all filing types for the period January 2012 through May 2023. Figures worth noting:

  1. Rate/New Program Filings: Increased from 80-90 days in 2012 to around 350 days in 2023
  2. Other Filings (e.g., rule and form filings): Increased from about 65 days to approximately 150 days
Source: Compiled from filings available from S&P Market Intelligence

We further break down rate filings by line of business in Chart 2 below. Although there are some variations by line of business and fluctuations by year, all the lines of business are on a similar trend path: filings taking longer to be approved.

Source: Compiled from filings available from S&P Market Intelligence 

Based on information provided by our actuarial consulting and state filings experts, there are several factors that have contributed to the increase in the time to approval.

Homeowners rate filings
 Starting in 2018, there has been a noticeable increase in the time to approval for homeowners. In response to a series of devastating wildfires, insurance carriers filed for more restrictive underwriting criteria and significant rate increases in wildfire areas. The CDI heavily scrutinized these filings to ensure the availability of insurance and to make sure that rates were not excessive for these risks. The CDI also added a layer of review that required signoff by upper management, including the commissioner, further increasing the time to approval.

Personal auto rate filings
 The CDI implemented a moratorium on personal auto rate increases during COVID-19. When the moratorium was lifted, the CDI started reviewing rate filings that had been on hold and pending – in some cases for more than a couple of years. At the same time, other insurers started submitting much-needed rate increase filings. Additionally, the CDI was concerned that insurers did not refund enough premium during COVID-19 and formed a committee to review the refunds. The committee coordinated the refund reviews with the rate filings being submitted by insurers, and this extended the review time for personal auto rate filings.

Changes to the filing review process
 Over the years, the CDI has changed its review process. For example, nowadays, you need to submit a complete rate manual with each rate and/or rule filing, and the CDI typically reviews the entire rate manual – not just the items being revised. Largely due to the CDI changing its position over time, it is not unusual to receive objections on items that are not being altered in the filing and were previously approved.

Staffing shortages
 Another factor impacting the time to approval is staffing shortages at the CDI. The CDI has had a number of experienced Bureau Chiefs and analyst retire over the last few years. With the CDI working remotely, it has also made training of new staff more difficult.

All of the above has led to an increase in the number of pending rate filings over the last several years. Fast forward to today, and the number of pending filings is almost 70% higher than the average of the five years pre-COVID. At the same time, the number of submitted rate filings per year from January 2021 to May 2023 is down between 20% to 30%.

Summary of pending and approved rate filings for homeowners and personal auto

There is a significant need for rate increases in California, as can be seen by the pending rate filings for homeowners and personal auto, which are displayed below for the top 10 carriers.

Below are some key figures on approved filings for homeowners and personal auto as of May 2023:
• 16 homeowners and 40 personal auto rate increases filings have been approved in 2023
• Two homeowners and six personal auto rate filings submitted in 2023 were approved
• Approved rate increases range from 3.5% to 65.0% for homeowners and 4.5% to 65.0% for personal auto

As can be seen from the above, there are rate filings that are being approved a lot faster than the overall average to time approval. Also, there is a wide range in the proposed rate changes that are being approved.

How can an insurer reduce the time to approval for filings?

According to our actuarial consultants and state filings experts, the key to reducing the time to approval for filings is to minimize the rounds of objections. To do this, an insurer should do the following:

  1. Expert rate filings reviews: Whether it is an internal review, or one done by an outside actuarial consulting firm, having an expert on California filings review your filings will reduce the number of objections.
  2. Perform data quality and reconciliation: The CDI has a data quality and reconciliation checklist, and companies should confirm that all items on the list reconcile. The checklist is not a required part of the filing, but it includes all the data checks performed by the CDI.
  3. Review updates to filing instructions: The CDI updates its filing instructions on a periodic basis, so insurers should monitor this for any new requirements or changes. For example, the CDI added a rating example requirement earlier this year, which the CDI will request in an objection letter if not provided.
  4. Have virtual meetings with the CDI: Virtual meetings are a good way to keep a filing moving and reduce correspondence back and forth. If you are unsure whether a response will satisfy the CDI, schedule a virtual meeting with the CDI, go through the response and get the CDI’s feedback. Pre-filing meetings or emails can also be used to answer questions on how items should be filed.
  5. File rate changes higher than 6.9%, if well supported: For many years, insurers filed successive 6.9% rate increases rather than requesting their full rate need in a single filing. Although consumer groups can force a rate hearing on personal lines with a rate increase above 6.9% (14.9% on commercial lines), the insurer can negotiate with the consumer group and the CDI on well-supported filings.

About Perr&Knight

Perr&Knight is a leading provider of actuarial consulting and state filing services to insurers in California. Our experts actively follow the California market and are deeply familiar with all the filing requirements in the state. We prepare and submit more California filings than any other company. Our experience includes expert testimony on rating filings and providing guidance to industry associations.

Please contact our team of actuarial consultants and state filing experts to assist with your California insurance products.

Best Practices when Performing Profitability & Competitive Analyses on Program Business

by Michael Covert

In our prior blog on Program Business, called “Guidelines for Filing Program Business,” we discussed how insurance carriers have become more and more interested in writing “program” business over the years. In this new blog, we provide guidance on how program administrators can maintain profitability and competitiveness of their programs. As a recap, we will reiterate the definition of program business.

WHAT IS PROGRAM BUSINESS?

According to the Target Markets Program Administrators Association, Program Business is defined as insurance products targeted to a niche market or class, generally representing a book of similar risks placed with one carrier. The administration of the program is done through Program Specialists, often referred to as Program Administrators or managing general agents (“MGAs”), who have developed expertise in that market or class.

Although administrative responsibilities are negotiated between the Program Specialist and Carrier, the responsibilities of the Program Specialist include underwriting selection, binding, issuing, billing, and often marketing, premium collections, data gathering, and claims management / loss control.

PROFITABILITY ANALYSES

Maintaining profitability can be difficult without a thorough understanding of the actuarial figures insurance carriers and reinsurers generally look at when reviewing Program Business. We discuss below a few types of standard actuarial analyses that are very beneficial to supporting a discussion around profitability.

Overall Rate Level Indications

A rate indication estimates the rate change necessary on an aggregate basis to balance the fundamental insurance equation, i.e., Premium = Losses + Loss Adjustment Expenses + Underwriting Expenses + Underwriting Profit, in the prospective / future period.

For admitted and non-admitted programs, this indication will provide actuarial support for any desired base rate changes, whether positive or negative, and indicates the change needed to meet the program administrator’s desired profit provision.

For example, if your projected loss ratio is 55.0%, this would be compared to the target (or permissible) loss ratio of say 65.0%. The division of these two results in a factor of 0.846 (rounded to three decimal places). By taking 0.846 minus 1.000 you get an overall indication of -15.4%. This implies rates could be decreased by 15.4% while still achieving the desired profit provision.

Historical and Projected Loss Ratio Analysis

While very similar to the Overall Rate Level Indications, these have more of a focus on the historical ultimate loss and defense and cost containment expense (“DCCE”) ratio and the projection of that ultimate loss and DCCE to the prospective / future policy period as compared to determining the amount rates many need to increase or decrease.

The historical ultimates are used to produce loss ratios from more of a financial standpoint and how the program has performed up to the evaluation date of the analysis (for example, an analysis with data as of December 31, 20XX.) The projected ultimate loss and DCCE ratio (i.e. also called “the loss pick” by many program administrators) gives the program administrator an expectation of how the program might perform, from a loss ratio standpoint, over the next policy year all else being equal.

Rating Factor / Class Plan Analyses

A rating factor or class plan analysis will review all rating variables in a rating manual. Rating factors, for example, might include territory (or zip code), limit of insurance, deductible, class code, age of building, credit score, etc.

There are two main types of class plan analyses: one-way analyses and multi-variate analyses. One-way analyses review each rating variable on a standalone basis while not considering any correlation with other rating variables. Multi-variate analyses, which typically involve modeling, such as generalized linear modeling, or other techniques, help to remove correlation between rating variables. Multi-variate analyses typically require much more data, time, and effort.

Program managers will want to determine which analysis makes the most sense for their specific book of business. These types of analysis are very helpful in determining which rating factors are profitable and unprofitable and what changes should be implemented to maintain or improve profitability.

COMPETITIVE ANALYSES

In conjunction with profitability analysis, reviewing the rates, rating plans, forms and endorsements of your competitors are key to help maintaining profitability. It is important that a rating plan achieves an appropriate rate for the risk.

If your competitors have more advanced rating plans or different rating variables that achieve a better rate for the risk, you will likely be adversely selected against and lose your profitable business to a plan with lower rates for these good risks. Conversely, the unprofitable business will stay with you since you are unable to charge them the higher rates needed to achieve profitability.

Finally, there are many differences in policy forms and endorsements that could cause you to pay claims your competitors would otherwise exclude and enhancement endorsements making your competitor’s program more attractive.

The majority of competitor information used in these comparisons comes from publicly available filings or company / industry financial information. We discuss three types of competitor analyses below.

Competitive Analyses – Rates: Along with the above-noted actuarial analyses, it is beneficial to analyze your competitive position at the same time to help ensure any changes made based on your data do not adversely impact your competitive position.

Premium comparisons compare your policy premium, for a specific number of rating examples, to that of your main competitors. Rating factor / class plan comparisons are similar to premium comparisons, except they compare all the underlying factors by rating variable in your rating manual to your competitor’s rating factors. While performing this review, you can also determine if your competitors are offering different or more competitive coverages and/or different rating variables not currently a part of your rating plan, that achieve a better rate for the risk, and might be worth implementing.

Competitive Analyses – Forms:  In conjunction with the premium and rating variables analysis above, it is important to review your policy form and endorsements to help ensure you are offering (and excluding) similar coverages.

If not, you may want to make changes – or at least acknowledge the differences are intentional – and ensure that the rates appropriately reflect the differences. When reviewing endorsements, the entire forms library is usually compiled to see if any key exclusionary or broadening endorsements are missing that might assist in profitability as well as competitiveness.

In addition, if it has been quite some time since a state-by-state compliance review has been performed, our product design team could uncover non-compliant forms or endorsements.  Making appropriate adjustments ahead of time will prevent painful market conduct exams in the future.

Market Research – It is also good to monitor new programs or filing revisions your competitors are implementing. If you are aware of when your competitors are increasing rates, adding new rating variables, changing coverages, adding new forms etc., you can make changes accordingly to maintain your competitive position.

Do you need guidance from a profitability or competitive standpoint on your program or a specific book of business? The actuarial consulting, product design and state filings experts at Perr&Knight are here to help. Contact us today.

Technology Tools to Optimize Your State Filings Process

by Patrick Light

By Patrick Light and Khushboo Jashnani

Though submitting and tracking state filings has improved dramatically over the last decade, many insurance companies are not yet taking full advantage of state filings software and technology that could further improve efficiency and visibility.

Many processes are still locked in emails and Excel spreadsheets on individual computers, decreasing visibility for business partners and other stakeholders. In addition, the lack of a standardized, centralized, and easily accessible repository for state filings increases the workload on insurance companies’ state filing teams.

As consulting and state filing support leaders for some of the nation’s top insurance companies, we have developed innovative state filings software to help our teams increase visibility and control. This industry-leading software, StateFilings.com, is available for our clients to license.

A Streamlined Workflow

StateFilings.com was designed by the state filing experts at Perr&Knight. This advanced, intuitive software streamlines the state filing workflow, enabling greater transparency, accessibility, and efficiency.

Here’s a process demonstrating how this tech-enabled workflow helps state filings departments:

Business Partner Creates a Project

Business partners have a designated role with specific permissions in StateFilings.com. Business partners are generally “read-only.” However, they can enter a new project and hand it off to the state filings unit. Business Partners cannot submit filings or add or edit any other data in the system. A business partner-specific view streamlines their ability to monitor multiple project statuses simultaneously.

Adding and Sharing Documents

Next, the business partner can add documents they want to hand off to the state filings unit. Using the project attachments feature enables the uploading of Word and Excel documents, which can be shared and edited by multiple users simultaneously. Business partners can also create a form template in the exact format that a filer would file it.

Sharing a template with business partners eliminates a manual handoff — the state filings unit can apply the template to a filing instead of re-typing the information into the system.

Read more: 5 reasons why state filings are rejected.

A Smooth, Instant Handoff

After creating the filing template and attaching relevant documents, the business partner changes the project’s status to “Submitted to Filings Unit.” From this point forward, the business partner can no longer edit the project — they are read-only. The system then automatically fires an email to the state filing unit. A state filing analyst can then accept the project and change its status to “Assigned” to begin their review.

Tracking Work in Progress

Once documentation is finalized, the state filing analyst can create filing drafts and change the project status to “Work in Progress,” indicating the filings have started. The analyst can apply templates to multiple filings simultaneously, saving time by eliminating the need to enter form data manually. The state filings software further streamlines the process by enabling analysts to submit numerous filings to SERFF at once.

Authors can include important information and track the status of each filing in real time. Each submission contains inputs for the following:

  • Filing requirements
  • Project expectations (TOI, form/rate/rule, etc.)
  • Peer review tracking and feedback notes
  • Filing submission dates
  • Objection tracking and corresponding follow-up and due dates
  • Approval communications and dates
  • And more

Automated Objection Handling

When an objection is received, built-in email functionality proactively fires an email to all authors, eliminating the need to proactively monitor SERFF. StateFilings.com stores all past objections, enabling data mining and specific information searches. Two-way integration with SERFF allows authors to issue a response directly from StateFilings.com. Consolidation of all filing-related communications saves time by eliminating the need to track down disparate emails.

Automated Approval Notifications

StateFilings.com automatically notifies authors when SERFF issues an approval. API integration enables companies to update external systems upon SERFF approval, further streamlining the workflow and supporting stakeholder visibility.

Advanced State Filings Software Improves Efficiency

Homegrown systems like Excel, email, and hard drive storage may have been cutting-edge technology in the past but are now outdated. Companies still using these non-centralized technologies compromise efficiency and increase the risk of crucial information falling through the cracks.

StateFilings.com consolidates all data to eliminate manual handoffs and improve tracking visibility. Collaboration in a shared platform enables business partners, analysts, and other stakeholders to keep current on all filings while working together toward a common goal.

See how StateFilings.com can improve your filing process. Contact the experts at Perr&Knight to schedule a state filings software demo.

How to Navigate California Personal Auto Rate Increases

by Dee Dee Mays

Personal auto writers in California have been abuzz with news of the recent rate increase approved for Allstate Northbrook Indemnity Company. This is the first rate increase approved by the California Department of Insurance (“CDI”) on any type of personal auto program since April 2020. There are many filings still pending. Here are insights on common questions our insurance filings support team hears from insurers:

How did Allstate get their filing approved so quickly?

That is the $165 million dollar question. The Allstate filing was submitted on June 30, 2022, well after many other filings that remain pending. Consumer Watchdog sent a letter to Commissioner Lara urging him to reject the filing, but does not appear to have submitted a formal petition to intervene. In October 2021, the Commissioner mentioned Allstate as one of three companies that needed to provide additional COVID-19 refunds to their policyholders. At this time, there is no publicly available information indicating that Allstate has issued any additional refunds subsequent to Commissioner Lara’s letter.

Allstate provided the following information on refunds to date in their approved filing:

In the final correspondence on the approved filing, that was submitted on the day before the filing was approved, Allstate confirmed that the next rate filing for their program in California would include the removal of their remaining affinity group rating program. This affinity group is for Specialized Professionals. Allstate’s approved manual includes a 4% discount for policies where the “named insured/applicant or spouse is a degreed professional in one of the following occupational groups: Education or Library Science, Science, Engineering, or Information Technology.” This “two-tiered system” was one of the concerns mentioned in the Consumer Watchdog letter.

Is it true that an increase greater than 6.9% requires a public hearing?

No. This is a common misconception. In fact, any filing can result in a public hearing, if a consumer group petitions to intervene and the Commissioner grants their request for a hearing. California Insurance Code 1861.05(c) includes the following [if] “the proposed rate adjustment exceeds 7% of the then applicable rate for personal lines or 15% for commercial lines … the commissioner must hold a hearing upon a timely request. “ In practice, consumer groups petition to intervene on filings with changes lower than 7% as well as higher.

There are currently 51 rate increase filings pending with the CDI. Of those, 5 have proposed increases of more than 7%.The oldest pending filing was submitted in October 2019.

If I have a rate change pending, can I revise it to propose a higher rate change?

Yes. This is similar to submitting a new filing and will result in the new change being added to a future public notice list, usually within two to three weeks after the change is submitted. The filing cannot be approved any earlier than the 46th day after public notice, which gives a consumer time to petition to intervene on the filing. Progressive initially submitted their filing for a 6.9% rate increase on January 7, 2022. This change appeared on the January 21, 2022 public notice list. Progressive amended their filing on September 30, 2022 to propose a 19.3% increase.   his change appeared on the October 14, 2022 public notice list. After no correspondence from the CDI since Progressive submitted the letter to waive the deemer date on March 9, 2022, the CDI issued an objection letter on November 3, 2022 with an November 18, 2022 due date.

What usually happens if a consumer chooses to intervene on a filing?

Hearings are fairly rare, even after a consumer group petitions to intervene. Typically, the CDI will allow the consumer group to be involved in the filing review process and provide their feedback on the filed change. The CDI will hold one or more meetings with the insurance company and the consumer group to discuss the support for the changes and encourage the insurance company and the consumer group to come to agreement on a change and avoid the hearing process. The consumer group will then submit their invoice for their costs that, if approved by the CDI, are paid by the insurance company.  The amount of compensation paid to intervenors from 2003 to 2020 is available at http://www.insurance.ca.gov/01-consumers/150-other-prog/01-intervenor/report-on-intervenor-program.cfm.

This shows the following amounts paid in 2020:

What happened with the Wawanesa personal auto rate increase filing?

As we mentioned in an earlier blog post on the moratorium, Wawanesa Insurance Company chose to reactivate the deemer on their filing, thus triggering a hearing. Our insurance filings support experts have recently learned from a representative of the CDI that “The Hearing for this matter was taken off calendar and a stipulated settlement agreement is being reviewed.”

What should my company do if we need a rate increase in California?

We have provided some additional ideas in our earlier blog. For example, consider accompanying class plan and rule revisions to improve segmentation and underwriting and to alleviate common concerns from the CDI. Regardless of how you proceed, having an insurance filings support expert with years of experience preparing personal auto rate filings in California could improve the time to approval and potentially save a company a substantial amount of money. Whether it is preparing the actual rate filing or performing a review of a rate filing prepared by the company, an expert can provide guidance that will increase the chance of having the most successful filing. There are many hot-button topics that may come up during a review of the filing.  An expert can make you aware of these to reduce the potential for surprises.

Perr&Knight is a leading provider of actuarial and state filing services to insurers in California. Our actuarial consulting team actively follows the California market and is very familiar with all the filing requirements in the state. We prepare and submit more California filings than any other company. Our actuarial consulting experience includes expert testimony on rate filings and providing guidance to industry associations.

Please contact us for any insurance filings support that is needed with your California insurance products.

Managing State Filings Just Got Easier

by Patrick Light

Updating and tracking filings in the System for Electronic Rates & Forms Filing (SERFF) has always been a tedious, time-consuming process for state filings departments at insurance companies. Manual data entry runs the risk of human error and creates the potential for information loss. Both of which can slow the filing pace or set the whole process back to zero with a disapproval.

When Perr&Knight introduced our proprietary StateFilings.com software in 2015, we knew the ability to submit and track filing information from a single, real-time cloud-based platform would save state filings teams a significant amount of time and guard against the minor errors that can negatively impact approvals. For years, companies were manually downloading filing documents from SERFF, entering the filing details into their state filing management system, and sending out filing status reports to interested parties. Those days are over. All of this has been automated through StateFilings.com. Filings departments have been freed to dedicate more time to addressing DOI requests and objections, which helps speed up the time to approval for filings and has a direct impact on a company’s bottom line.

Two-way communication with SERFF is here

Though the initial version and subsequent updates of StateFilings.com was a massive time-saver and a huge help for state filings departments, there was just one piece missing: the system only worked in one direction. Filings departments could use StateFilings.com to monitor information coming from state Departments of Insurance (DOIs) but initiating new filings and uploading information to SERFF still required lengthy manual processes on SERFF’s cumbersome website. Now, we are excited to say that the 4.0.0 release of StateFilings.com has solved the communication challenge by enabling two-way exchange functionality with SERFF. This update streamlines the filing process for insurance companies even further.

StateFilings.com’s recently launched system upgrade uses a two-way API to push data into SERFF, so users are no longer required to access the SERFF website directly. Instead, the entire scope of state filings management can be handled on a single platform via a streamlined, intuitive interface.

A recap of StateFilings.com’s capabilities

As mentioned above, we developed the StateFilings.com software to accelerate the filing process by streamlining workflows for insurance company state filing departments. Because we used this software internally for many years before licensing it to our clients, we knew the platform provided measurable value.

In place of the time-consuming manual processes most state filing departments relied on, our software harnesses the power of technology to manage and automate many mundane (but crucial) state filings tasks. Here are some of the system’s key features and benefits:

  • A cloud-based system enables 24/7 access
  • User-level security and role-based permissions protect sensitive data
  • Filing management (including status)
  • Objection and response library
  • Forms libraries for document management
  • Real-time information updates

More useful features

This year’s upgrades to StateFilings.com build on all the features and functionality above, further streamlining the filing process. Here’s how:

Work while SERFF is down

Users can continue to access and review filings, even if SERFF experiences problems.

‘Note to Reviewer’ improvements

Users are now able to submit notes to DOI reviewers en masse across multiple filings and projects. Editable temple language ensures consistency and cuts down on time spent drafting emails.

Filing cloning ability

Users can create a single countrywide draft and with one “save-as” clone for all 50 states, instead of one by one. When submitting to more than one state, generating multiple clones of one filing with a single click eliminates the repetitive process of filing initiation.

Scheduled item template enhancements

Create and update your scheduled item templates for each project and then save time by applying a template to multiple filings at once instead of having to import the template into each individual filing.

Developed specifically for insurance companies

The SERFF system was a major industry breakthrough for insurance companies who were accustomed to filing paperwork via mail or fax. However, as times have changed, state filings departments have increased the demand for a streamlined, user-friendly experience that mimics many of the other digital tools in the modern office suite.

We applied our decades of experience providing insurance support services for products in every line of business to develop a straightforward but powerful tool based on the realities of companies’ state filing department workflows.

The updated StateFilings.com is the latest advancement to accelerate the filing process, enabling insurance companies to be more efficient with their time and more cost-effective overall.

Interested in learning more about what StateFilings.com can do for your business? Schedule a demo today.

Top 5 Reasons State Filings Are Rejected or Disapproved

by Ashley Allen

Staying on top of state filings can be tricky. Demanding regulators, detailed filing requirements that vary by state and mountains of required supporting documentation can quickly become overwhelming, even for insurance companies with robust in-house filing departments.

Objections or disapprovals from Departments of Insurance (DOIs) can and do happen, but there are some things you can do to mitigate that risk. Though it is impossible to know exactly what a regulator may take issue with, our experience providing state filings support for insurance companies has revealed certain things are likely to cause your state filing to get kicked back to you.

Here are the top five reasons regulators reject state filings.

1. Unclear understanding of each state’s filing requirements and expectations

Unfortunately for insurance companies, every DOI has unique requirements for submitting filings, amending filings, and addressing objections. Failure to comply with each DOI’s requirements can turn a simple objection into outright disapproval.

Incorrect formatting or failure to submit the correct information in the right spot can lead to a rejection. For example, certain states require insurers to submit redlines (marked-up versions) in the same area as final new forms in SERFF. In other states, this documentation is simply considered supporting documentation.

Obtaining clarification is not always easy. Regulators in Maryland, Alaska and Pennsylvania are known for being accessible to answer questions before and during the filing. Some states are less likely to respond to inquiries, leaving you on your own to figure things out.

Unless you are keeping close track of what each state requires for new filings, amendments, objections and overall processes, you risk committing an error that can send your filing back to square one.

2. Failure to comply with state regulations

Your company’s regulatory compliance department should know what is and isn’t permitted within your jurisdictions and lines of business. Submitting forms or rates that aren’t permitted by a specific DOI is a surefire way to receive an objection or flat-out disapproval.

States are particular about what they will allow. Some states won’t permit ranges of rates.  Some won’t allow certain types of forms or Defense within Limits, which is commonly used for professional liability products.

You can often find this information on the state’s DOI website, but it may not always be available.

Incorporating regulators’ expectations into your product design process can facilitate a more timely approval. Your state filings teams may need to work closely with your product development team to make sure your company’s insurance products are designed with compliance in mind from the start.

3. Lack of response to objections

Slow response to objections trips up many state filings departments. Unfortunately, timelines to address objections vary wildly. Some states can give a month or more to respond to an objection.  Others may require an answer in two days. We’ve seen instances of regulators requesting corrections within hours.

If you are not able to respond to an objection by the due date and an extension is not granted, you may want to consider withdrawing the filing and resubmitting later, rather than risk running out of time. Not responding could trigger an automatic disproval—and may land you on the wrong side of regulators.

At Perr&Knight, we use a sophisticated software application, StateFilings.com, that we developed for internal use and then made available for license to our clients. StateFilings.com is a sophisticated tool in the management of state filings. It communicates directly with SERFF, pulling in objections and due dates to make managing workflows less risky.

4. Not reviewing/following the general instructions in SERFF

It may seem like a no-brainer, but it’s surprising how often this happens. Failure to follow directions outlined in SERFF can lead to rejection right off the bat.

While the filing wizard in SERFF led to a massive leap forward in efficiency, some parts of the interface can trip up your filing if you’re not careful. For example, Utah requires a specific certification statement for all filings. If you fail to include this statement with your filing, the Utah Insurance Department will issue an immediate rejection. But SERFF doesn’t have a specific spot for it. Therefore, knowing where to include this information is essential, even if there is no obvious designated area. Many states have unique questions or informational requirements such as this. If fields are blank, SERFF will not let you submit the filing. But knowing when to include specific information in certain fields, even if it’s not technically correct, will enable submission and may provide regulators with the information they require.

Until SERFF includes state-specific filing workflows that match what regulators are looking for, state filings departments will be forced to employ workarounds. Not completing the workarounds correctly—or worse, not knowing they are necessary—could lead to a swift rejection of your filing.

5. Missing or incomplete transmittals or checklists

If your filing is missing a transmittal or checklist, regulators may reject it without even an initial review.

Reasons for incomplete information vary: You may not realize a checklist or transmittal applies to your filing. Some checklists are complex and confusing. In some cases, you may be unsure how to answer a question on a checklist. Depending on the line of business, finding the appropriate checklists and transmittal requirements can be a challenge.

Though the oversight may not be intentional, DOIs don’t care. Missing or incomplete transmittals or checklists mean regulators do not have what they need to move forward, so they may issue a rejection and you’ll be forced to start over. Additionally, using the incorrect version of a transmittal or checklist can also result in an objection.

Ensuring your checklists and transmittals are complete, current, and correct is one of the most basic things you can do to guard against a state filings rejection. Working with partners like the state filings support team at Perr&Knight strengthens your position. Our experts know the requirements of every checklist and transmittal. We peer review your filings to make sure they are complete before submission.

State filings are never static

Our extensive experience providing filings support has shown us that the only constant is change.  Insurance regulators have evolved, so certain shortcuts that worked years ago may no longer be enough. Some states permit longstanding workarounds, but others are becoming stricter about following the rules to a T. Regulations vary by state, which can cause hiccups when filing.

Partnering with state filings experts like the team at Perr&Knight can help protect you against avoidable mistakes that lead to rejections. Our state filings support teams dig into the minutiae, tracking nuances by state and line of business. Working with a team with decades of experience helps you avoid missteps from the get-go.

Beyond filing support, our actuarial consulting and product development teams can make sure the products you plan to offer are designed with compliance in mind. This type of up-front work can pay off huge when it’s time to file. A holistic understanding of the intersection between profitability, compliance, and regulatory approval helps you avoid costly mistakes that can slow your time to market.

Whether you handle state filings in-house or offload submissions to an experienced filings support team, keeping the above in mind will protect you against avoidable errors that put your approvals at risk.

Let our experts help you make state filings more manageable. Contact Perr&Knight today.