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Compliance 101

Compliance 101. Mission. Get a Policy Pay uninsured injured workers. Mission. Get the “right” Policy Pay uninsured injured workers. Compliance. Education. Field Investigations. Section 57. IC-2. IC-2. IC-2. DOL. Carriers. Employers. Policies. Employers that

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Compliance 101

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  1. Compliance101

  2. Mission • Get a Policy • Pay uninsured injured workers

  3. Mission • Get the “right” Policy • Pay uninsured injured workers

  4. Compliance Education Field Investigations Section 57 IC-2

  5. IC-2 IC-2 DOL Carriers Employers Policies Employers that don’t match a WC Policy are processed further Employers are matched with a WC Policy Inquiry Letter is sent §52-5 Penalty is assessed Referral is made to Collection Agency Judgment is filed

  6. UEF Receipts less Disbursements1998-2008

  7. UEF Receipts1998-2008

  8. Dependencies Employer Files Carrier Files DOL Carriers IC-2 Uninsured Employers

  9. IC-2 Dependent on Carrier Filing Carriers • 1/1/07-9/30/07, Penalties were issued to 3,001 employers in the amount of $22 million dollars. • 3,001 Inquiry letters • 3,001 Penalty notices • 3,001 + Phone Calls • Penalties were ultimately rescinded when the untimely Proof Of Coverage information was submitted to the Board by the carrier. • This business model was not acceptable! Policies IC-2

  10. Insurance Carrier Outreach Begins • 12/27/07 letters identifying open/expired policy terms were sent to carriers requesting corrective action. • E-mail notices listing open/expired policy terms were sent to carriers requesting corrective action. • 3/26/08 • 7/18/08 • 10/15/08 • 10/20/08 the WCB published reports listing quarterly performance results for insurance carriers for late Proof of Coverage filings and Open Expired Terms. • 1/6/09 e-mail notices listing open/expired policy terms were sent to carriers. • 3/30/09 the WCB released Subject No. 046-304 to carriers implementing Proof of Coverage penalties.

  11. Timely Proof of Coverage Filings Third Quarter 2007 - Second Quarter 2009

  12. Compliance Rate

  13. Second Leg-Field Investigation Compliance Education Section 57 Field Investigations IC-2

  14. Stop Work Orders 2/08 3/08 4/08 5/08 1/08 10/08 11/08 12/08 1/09 8/07 9/07 6/08 7/08 8/08 9/08 2/09 3/09 4/09 5/09 6/09 7/09 7/07 11/07 10/07 12/07

  15. Third Leg-Education Compliance Education Section 57 Field Investigations IC-2

  16. Fourth Leg-Section 57 Compliance Education Section 57 Field Investigations IC-2

  17. New Penalties-New Work • WCL Section 52-1-d • WCL Section 131.3 • WCL Sections 54 and 226 • Procedural Penalties

  18. Staffing From April 2008 to August 2009 Compliance lost 20 of 195 positions

  19. Thank you Compliance Staff!

  20. Thank you Compliance Managers! Peter Michels Paul Celentano Helene Hewitt Keith Bellamy Steve Carbone Michele Santiago Michele Granger Teri Cooper Jim McGinn Marion Kinch Julie Squadrito Len Frasco Denise Hughes Vicky Plotsky

  21. Thank you CMO

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