The quality of filings was the largest impediment to the completion of the project. Ultimately, it required NORC to review virtually every filing in the database, sometimes with computer algorithms, but often by manually examining each filing. The following lists some major problems encountered in the qualityreview process:
- Insurers may file more than once each year. Possible errors include duplicate filings or misstatements of annualized increases in premiums.
- The “effective date of the premium increase” may sometimes have been listed as occurring prior to the approval date.
- The proposed rate increase was less than the rate increase approved.
- No effective date was included in the rate filing
- For estimated enrollment, the carrier confused the number of members and the number of contracts or labeled the figure ambiguously.
- In state summary websites, some carriers supplied data on the number of contracts, and some supplied data on the number of members in the same field.
- Many carriers provided identical enrollment for different products filed in the same year.
- Carrier filings on enrollment were sometimes highly inconsistent with enrollment figures from the NAIC.
- Some carriers used different company names when filing as health insurance carriers than they did when filing as life and health or property and casualty carriers. However, reported enrollment, premium increase, and MLR information may be identical so there was a question as to whether it was the same plan.
- A larger company may have two subsidiaries selling the same plan under different names. However, in one state, enrollments were separate, and in another they were identical.
With multiple sources of filings (Perr & Knight, state websites, and filings received directly from state insurance departments), duplicate filings often appeared in the database. The task of removing potential duplicates was not trivial. Some states had no assigned state filing number or SERFF filing. When multiple filings were identified, it was necessary to inspect them manually and determine if the seemingly identical filings were in fact different plans. Below we list some different duplicate-filing scenarios that NORC found upon detailed inspection of the database:
- In some states, carriers filed for multiple plans in the same filing. For example, a PPO, indemnity, and HMO plan might be included in one filing.
- Sometimes information in seemingly duplicative filings did not match for all variables.
- . Under the same filing number, one filing was for a grandfathered block of business, with the other filing for a non-grandfathered block of business.
The most intense quality assurance reviews occurred during February-May of 2012. In March 2012, NORC conducted an audit of 100 randomly selected filings, which involved coding the relevant data and comparing the results to NovaRest data for the same filings in the Excel database. Up to 23 data elements per filing were evaluated, and differences were identified and reconciled by reexamining the filings themselves. Most errors in the database were coding errors, although a few were errors of interpretation. The audit found an error rate of 1.56 percent. The subsequent quality review activities should have reduced this error rate.