by Courtney Hughes, JD, CPCU, Manager, Regulatory Compliance & Patrick Light, Principal and Director of Enterprise Software Solutions
There are many reasons to try to expedite your state filings approvals. Whether you are changing rates, launching a new product, or updating a product to meet your customer’s needs, speed is critical in today’s immensely competitive insurance market.
Obtaining approvals quickly is a huge competitive advantage. Bureau filings, in particular, can be especially difficult to keep up with, because new circulars and info come out every day. For ISO, AAIS or other bureau-based products, staying on top of the frequently-changing requirements gives you a significant edge over companies that are lagging behind. For independent products, it’s all about getting your new product or coverage to market before your competitors.
Speedy approvals can help lighten your workload by ending that process sooner, allowing you to focus your attention on the next big project. Here is a list of useful tips that can help you avoid the stumbling blocks that slow down state filings approvals.
Get prepared before submitting.
Thoroughly research the filing requirements for the states in which you plan to file well in advance of your target filing date. Understanding and complying with these requirements up front avoids the issue of states coming back to you requesting that you correct avoidable procedural issues, such as providing the wrong edition of a required transmittal document. Issues like this can delay your approval by weeks.
You can obtain current information from state department of insurance (DOI) websites, SERFF or your insurance consulting services partner. For bureau adoption filings, make sure you have collected and organized all the information from the circulars before you begin so you can provide the states with all necessary pieces of information, like the ircular number, bureau filing number and state filing number.
Submit compliant, complete, and consistent material,
Reviewers can’t approve filings that are not in compliance with their state laws. Every time they kick your filing back with questions, it slows down the time to approval. Make sure that your product development staff and actuaries, or your insurance consulting services partner, confirm that the forms, rates, and rules you plan to submit are in line with state requirements. Not all objections or issues can be prevented, but where possible, anticipate the state’s requirements for your product and try to answer any expected questions in the explanatory memorandum you submit with your filing.
Completed material also goes a long way in speeding up approvals. For example, some states require a form usage rule in your manual for each form submitted. By providing the form usage rules in your manual at submission, you avoid the objection coming in and having to scramble to create the form usage rules and get internal stakeholder approval before the deadline.
Finally, consistency is important because it makes your filing easier to review so it is more likely to be approved quickly. After the forms, rates, rules, and supporting documentation have been developed, take some time to review them carefully. Make sure, for example, that your program name is consistent between the documents, or that your explanatory memo is not referring to a form you decided not to file.
Submit your objection responses ASAP, but always before the due date.
DOIs like to speed up their workflows too, so give them everything they need to close the filing as soon as it becomes available. If you received an objection with a due date in a week, submitting your response by that deadline is good, but submitting it within two days is even better. And always be sure to respond to the state by the due date they set. If you know you will not be able to respond by that due date, contact the DOI analyst and request an extension. If you miss a due date, there’s a good chance your filing will be disapproved or rejected, putting you back to square one.
Have a plan for objection responses and status checks.
Staying on top of filings once they have been submitted is challenging because there are lots of moving pieces to manage. You need to keep track of DOI questions and their due dates and ensure that you are consulting the right internal teams for answers. You will also want to keep track of when filings have been submitted so you know when it is time to check in with the DOI to see how their review is progressing. Before you submit, you should have a plan in place for how you will keep all of the outstanding filings organized.
Use tracking software designed for insurance.
When you have a clear insurance software tracking system in place instead of a hodgepodge of spreadsheets, databases, SharePoint, and/or emails, you can easily keep track of DOI questions and due dates. The more seamlessly you can manage the questions the reviewer throws at you, the sooner you can get the ball back into their court.
Avoid double work.
Review your internal systems to make sure they’re not slowing you down. If you use an ad hoc tracking process, you are likely doubling up on data entry, entering the information once in SERFF and again in your company’s tracking system. This can cause delays in your ability to respond to reviewer questions or use the time of valuable internal resources who could be focused on the next project. Evaluate your company’s state filings process, looking for areas you can streamline. Working with an outside insurance consulting partner can help reveal inefficiencies that you might overlook.
There are never any guarantees with state filings approvals. But preparation, planning, and organization can mean the difference between a product that is launched on time, and one that gets lost in a maze of questions and confusion.