Weekly Tip: Common Objections Series – Statement of Variability Consistency


Weekly Tips

Common Objections Series – Statement of Variability Consistency


Returning to our series on common objections issues on IIPRC filings, today's tip is common to all TOIs and especially actuarial objections. It arises when a filer has made a change to the initially filed form or Actuarial Memorandum, perhaps in response to an earlier objection, but the change is not accurately reflected on the range of values for a particular item that is bracketed in the form and described on the Statement of Variability. Overlooking the need to make a corresponding change to the Statement of Variability can result in a second objection and additional time before compliance with the Uniform Standards is achieved. For example, a filer receives an objection that the Actuarial Memorandum and specifications page for a submitted policy form include a lower-end limit of zero for a certain benefit. A zero value in a range is impermissible under the applicable Uniform Standards. The filer makes a correction to the Actuarial Memorandum and the specifications page so that the lower-end limit is no longer zero, but neglects to make the same correction to the Statement of Variability. This results in a second objection on the same issue asking for the values stated in the Actuarial Memorandum, policy form and Statement of Variability to be consistent.

How can the filer avoid an objection relating to variability of items revised during the review process? Carefully checking revisions made post-submission against the originally filed Statement of Variability should eliminate the second objection. When responding to objections involves multiple business units within the filer's organization, an important assignment before the response is submitted is for the submitter to check the form, Statement of Variability and Actuarial Memorandum, if any, for consistency. Ensuring that revisions made during the review process are carried consistently through the Statement of Variability will reduce the number of objections during your filing's review.

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