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ICAE position paper targets the need for industry uniformity in
complaint handling definitions and reporting
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Marty Fisher, president, Martha
Fisher & Associates, facilitates Exchange attendees
toward agreement on ICAE’s position paper, Consistency
and Uniformity in Complaint Handling and Reporting. |
One of the issues that has dogged the efficient handling, logging,
analysis and reporting of complaints and complaint data has been
the issue of uniformity – meaning commonalities in the acceptance,
processing, handling and reporting of customer complaints. Lack
of uniformity can and does affect efficiency, turnaround time and
the accurate defining of and reporting of complaints.
Charting a course out of the wilderness of inconsistent and disparate
handling and reporting styles to the goal of uniformity among companies
and regulatory agencies was the impetus for the creation of an
ICAE position paper on the subject. The process kicked off during
the ICAE Roundtable held in Columbus, Ohio in April 2005.
During the 2005 Nashville Exchange, Marty Fisher, professional
facilitator and president of Martha Fisher & Associates, briefed
attendees on the objective, process and progress to date related
to ICAE’s position paper on the need for DOI and insurer
uniformity in the acceptance, handling and resolution of complaints.
An exercise in change management
“This is truly an exercise in change management for the
ICAE,” commented Fisher. “Change is difficult for business
generally, and it can be particularly difficult in the financial
services industry. The creation of this paper and its proposals
represents the first major change in this area in the last 10 years.”
And as is characteristic when change is involved, some of the
early feedback was a bit on the negative side.
“We heard a number of things during the early discussions,” Fisher
said. “There were concerns that the proposals being made
in the paper were not how things are done at different organizations
today, combined with a sense that a uniformity effort like this
simply would not work. Others expressed concern that the devils
we do know in our processes are better than the ones we don’t.
Still others said they were not the right people to decide anyway.
All of that said, we were able to move ahead and reach substantial
agreement in a number of key areas. And these days, those of us
in the change management field have a much better handle on the
specific factors that we know will make change management work.”
Fisher pointed out several factors that are critical to the change
management process:
- Strong leadership able to remove obstacles
- The existence of a shared need.
- A shared vision of the future.
- A proposal that the change be mobilized into commitment.
- A diverse audience willing to commit to a shared vision and
goals
“In the case of the need for greater uniformity in the handling
of consumer complaints in our business, I think it’s fair
to say that these conditions and factors exist,” Fisher said. “The
job now is to coordinate them to get the job done.”
The ICAE position paper has been organized to address five specific
areas:
- The definition of a complaint
- Communication from regulators to insurers
- Communication from insurers to regulators
- Standardization of reporting
- Recordkeeping
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Fisher stresses of all the factors
critical to implement change, the most important is a shared
vision of the future – of which ICAE attendees agreed. |
Pursing a shared vision
As Fisher pointed out, there is a misconception that change is
a straight line.
“That’s simply not so,” she said. “There
are risks involved in any change scenario. There is usually a temporary
dip in proposed service delivery and the fear is that heads will
roll whenever there is such a dip. But there are risks in not changing.
If you are standing still, you are losing ground. If you are not
moving forward, there’s a good chance you’re going
to move backward instead. And if you don’t provide active
input in change, you’ll have it dictated to you.”
Whatever disagreements may have existed during the initial stages
of the uniformity paper discussions, there was no disagreement
over a shared vision. During the Columbus session, the paper was
reviewed section by section, with some sections fully endorsed,
some partially endorsed and others the subject of dissent. The
Executive Committee addressed dissent in the appendix.
Defining what is and is not a complaint was a major point of disagreement.
As a result, the definition of a complaint was removed and placed
in the appendix, at least for the moment. Written comments regarding
the nature of the disagreement were included.
- Communication from regulators to insurers
The section related to communication standards between regulators
and insurers passed on a 2/3 vote of the attendees at the Columbus
Roundtable. The issue of due dates as well as the development
of checklists for complaint-related issues received considerable
discussion. Some attendees were concerned that staff people within
the various DOI’s administrative offices would simply run
down any checklist and marked every entry. It was concluded that
this eventuality could be addressed with appropriate staff training.
Overall, the idea of a checklist was considered to be a good
starting point, with the potential for different checklists for
different areas, such as claims, billing, rates, etc.
- Communication from insurers to regulators
This section of the position paper related to standards of communication
from insurers to regulators was passed by a similar 2/3 margin.
Once again, issues related to due dates and turnaround time requirements
received considerable discussion.
A recommendation regarding standardized coding and reporting
of complaints passed on a 2/3 vote, with general agreement that
the process is indeed broken. “It’s broken, so let’s
agree on that and move forward,” Fisher remarked.
- Recordkeeping and confidentiality
This area was the subject of substantial disagreement. It was
withdrawn and placed in the appendix, with comment.
Key messages to NAIC
According to Fisher, the overriding message behind the effort
is the desire to improve the industry.
“Time is on our side,” Fisher added. “This has
been a long-term project for the ICAE, beginning with our Columbus
Roundtable in April and continuing through the October Exchange.
The potential benefits of this process are important enough that
it’s worth it to get it right.”
While the process of developing the ICAE’s Uniformity position
paper has been a deliberate and long-term one, a decision was made
to make a concerted attempt to get a re-draft before the NAIC at
its regular meeting scheduled for December 2005. Given the short
window of time, Fisher committed to incorporating ICAE member input
on the Position Paper into a redraft that would be submitted to
the NAIC in time for review at its December meeting.
The session concluded with a sharing of ideas about the key messages
to be presented in the cover letter that will accompany the redraft
being provided to the NAIC meeting. Those messages included the
following:
- A statement that ICAE has a consensus moving forward.
- Both regulators and companies have a desire for improvement.
- We don’t expect change to happen overnight, but we have
high hopes to get it done within a mutually agreed upon time
frame.
- ICAE is presently the only realistic forum to discuss these
issues.
- In case of snags or disagreements, we agree to move one step
at a time.
- The submissions and recommendations contain regulator input.
- NAIC can take a role in moving the process forward by stressing
the need for improved uniformity and market analysis.
- ICAE will make recommendations to the NAIC regarding what we
hope they will do with the proposals contained in the position
paper (call to action).
- The paper represents true Interstate collaboration.
- The ICAE strongly wishes to partner with NAIC in this matter.
- Given the increased volume of complaints and the introduction
of new technologies, this is exactly the right time for both
organizations to partner in this effort.
- The ICAE will interface with other stakeholders, including
various national insurance industry trade organizations, in the
ongoing uniformity process, soliciting their opinions and ideas
on a range of issues surrounding the topic.
At a time when the expectations of insurance consumers are increasingly
being driven by the immediacy of the Internet and other technology-based
solutions, the ICAE’s tackling of uniformity in the acceptance
and handling of customer complaints represents an important and
necessary initiative. Watch for more important developments regarding
the Uniformity position pper on the ICAE web site in the weeks
and months ahead.
CONTACT INFO
Marty Fisher
Martha Fisher & Associates
614.457.8585
Email: mfishercompany@aol.com
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