Weekly Tip: Common Objections Series – Long-Term Care Advertising

 

Weekly Tips

Common Objections Series – Long-Term Care Advertising

3/07/2014

Continuing our series on commonly issued objections, today's tip involves another objection frequently issued on long-term care advertising filings submitted under Standards for Individual Long-Term Care Insurance Advertising Material, IIPRC-LTC-I-3-ADV. This aspect of the uniform standards is unique to the IIPRC and trips up many first-time advertising filers. We find that there is a learning curve with the uniform standards for long-term care advertising filings, so reinforcing commonly overlooked aspects of these uniform standards may help new and experienced filers address these areas and avoid objections.

Today's common objection is that the type of advertisement must be identified. The standards provision is found in Section 1A(6) as follows: "Include an identification of the type of advertisement submitted, i.e., institutional advertisement, invitation to inquire, or invitation to contract." This means that the filer must classify each unique form included in the advertising filing as institutional advertisement, invitation to inquire, or invitation to contract. Each type of advertisement is defined in the Uniform Standards definition section under the Scope provision. The reason the type of advertising is important is that certain requirements apply only to certain types of advertising. For example, only an invitation to contract must "clearly disclose the total period of time for making late premium payments." We rely on the filer's identification of the type of advertisement and apply those requirements to the form. The form review cannot start until the type of advertisement has been identified. This identification is included in the Filing Description on the General Information tab and in a cover letter when additional advertisements are submitted.

Determining and stating the type of advertising of each form in an advertisement filing will reduce the number of objections during your filing's review. Being mindful of which requirements apply to which types of advertising should also simplify the drafting process. Using the checklists for the applicable Uniform Standard(s) found on the Record along with the Best Practices Checklist found on the Company Resources web page will help remind you of the required information each time.

If you have any questions about IIPRC submission requirements, please contact the IIPRC Office.