Weekly Tip: Understanding the Insurance Compact Rulemaking Process Part 5 – Industry Participation

 

Weekly Tips

Understanding the Insurance Compact Rulemaking Process Part 5 – Industry Participation

8/23/2017

Now that we have explained how uniform standards are developed, in this week's Weekly Tip, we will outline how company filers can follow and participate in the process.

The most informed Compact filers assign a specific person the responsibility to review Product Standards Committee call summaries and gather company feedback on draft uniform standards in order to avoid any surprises or questions when the uniform standards are ready to adopt. Within a week of both member and public calls of the Product Standards Committee, the Insurance Compact Office posts the call summaries on the Insurance Compact website. Review of the call summaries is a good way to keep track of the progress of uniform standard development, as well as note concerns and recommendations made by regulators and interested parties. The call summaries may be found on the About the IIPRC page of the website, under "Product Standards Committee."

As uniform standards are being developed, the Product Standards Committee holds public calls to obtain feedback from interested parties. Notice of the call is issued at least 15 days in advance and all materials are posted to the Event Calendar on the Insurance Compact website. We strongly encourage interested parties to participate and contribute to these calls, since it is during this development phase that key issues are debated and draft language is recommended.

As mentioned in a prior weekly tip, once the Product Standards Committee has made its recommendations to the Management Committee, the proposed uniform standards are exposed for a 60-day comment period. During this time, companies are encouraged to conduct a final review of the uniform standards to be sure that all issues have been fully vetted and that the proposed uniform standards reflect the intent discussed during drafting. If companies have followed the uniform standard development process from the start, this 60-day comment period is more of a final review rather than the time to reiterate prior comments or raise new issues. Raising previously undiscussed issues during this final phase delays the adoption of uniform standards, so companies are strongly encouraged to participate from the start of development rather than wait until the last minute.

The Product Standards Committee is beginning the process of a Five-Year Review of the individual disability income uniform standards. This is a good opportunity to get involved in the process. If your company markets that product, we want your participation as outlined above so that the end result is well-informed and practical for today's marketplace.

There is one final way that companies can provide assistance in the uniform standard development process. If you see a gap in the Uniform Standards that results in a need to file directly with states rather than with the Insurance Compact, please let us know so we can consider the need for new uniform standards. The Insurance Compact Office tracks and prioritizes these requests. Additionally, as Uniform Standards are undergoing Five-Year Review, if you note areas where further clarification or guidance is needed, please submit suggestions. Your feedback should be sent to Comments@insurancecompact.org.

We hope that this series on the Rulemaking process has been helpful. If you have any questions on the process, please contact the Insurance Compact Office.