Archive for August, 2016

Identify Your Workers’ Needs, Consider Costs before Open Enrollment

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It’s almost time for small group open enrollment and you need to drive engagement so that your employees can make informed decisions about their health insurance options.

We want to help you help your employees understand all of their options so that they can purchase a plan that is appropriate for their situation. So here is our advice for the open enrollment:


Listen to your workforce

Before you make any decisions, you should listen to your employees and better understand their needs and preferences.

With answers and feedback in hand you can create a benefits package that is more appealing to them, which in turn gives you a competitive edge when attracting and retaining workers.

Engage employees and solicit feedback through quarterly employee-benefits round table meetings. Invite employees from different age groups and different departments to participate in these meetings, to ensure you have a good cross-section of your staff represented.


Give advance notice

You can start this month with simple reminders for them to start thinking about open enrollment and evaluate their current health plans. Send out memos and place posters in high traffic areas.

If you start with this in September or October, they can have time to assess their options, particularly if anything has changed in their lives like marital status, new children or health issues.


Costs are paramount

You can work with us to settle on plan arrangements that will be within your and your employees’ budgets (in their case, the plans also have to be deemed affordable under the Affordable Care Act).

Employees have a right to understand the costs, so let them know how to access the free transparency tools provided online by most medical carriers. Provide employees with a breakdown of medical and pharmaceutical cost increases to avoid sticker shock.


Get an early start

If your plan year starts Jan. 1, you should hold open enrollment meetings and dispense plan materials in October or November.

Avoid holding meetings in December. It’s too busy and the ramping up period is too short.


Communicate effectively

Your task is to get employees out of cruise control and truly assess all of their options.

This is especially true if you are making changes to cost-sharing, introducing new plans, introducing a wellness plan or health savings account or flexible spending account.

You should use a variety of different media to communicate with them. Use video, virtual and live meetings, e-mail communications and print materials to get through to your employees. While the attentive ones may think it’s overkill, using different forms of communication ensures that you reach the widest number of staff.


Get spouses involved

If you also offer insurance to spouses, you should communicate through your employees that they are also invited to join your open enrollment meetings.

You can also invite them to view any electronic material you may post online, like the aforementioned videos.

If they cannot make a general meeting, you can invite them to come in to meet with your human resources manager if they have questions.


Remind staff of the ACA

You can use open enrollment as a way to remind your workforce of their responsibilities to secure coverage under the Affordable Care Act.

Let them know that employees that refuse affordable coverage from their employer and opt to purchase it on a public exchange will usually not be eligible for government premium subsidies.

Ask us about the most frequently asked questions about the ACA and we can help you prepare a list of online resources that they can access to get answers to those questions you may not be able to answer.


The meeting

Send out meeting notices early to give your employees time to prepare and set aside time.

Try to make the meeting engaging. You may also want to consider video recording the session, and also providing remote access to employees that don’t work onsite.

Provide enough time for the main presentation, as well as for questions from your employees.


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Why You Need to Review, Update Your Business Continuity Plans

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We often urge you to have a risk management plan in place so that you are prepared for the many eventualities that can affect your business.

Your risk management plan should be part of a larger business continuity plan for keeping your organization going during periods of disruptions that are both large and small.

The plan should be broad to cover prevention and response, and that can only be done with input from representatives of all your firm’s divisions.

Companies can spend considerable time putting together a risk management plan that is unique to their workplace and operations. But, after they have created and implemented their plan, many businesses fail to evaluate and update it on a regular basis.

You will need to test, evaluate and update your risk management and business continuity plans regularly because risks can change as your business, your industry and the environment you operate in also change.

A prime example of a new risk is the cyber threat that continues to grow in significance, having cost many businesses millions of dollars in response, remediation and notification costs. If you have not included this eventuality in your business continuity plans, you should do so.

If you set aside time once or twice a year to review your plans, you can identify new risks and monitor the effectiveness of your current risk management strategies. This gives you an opportunity to modify or enhance your plan in response to those emerging or newly identified threats.

As you did when you created your original plans, you should involve personnel from your various departments and also consider inviting key vendors or customers to the planning sessions. This will help bring different perspectives to the table, resulting in a more comprehensive overall plan.


The business continuity plan

Besides identifying and trying to mitigate for risks that you identify, your risk management plan should be part of a broader business continuity plan that includes strategies for responding to and recovering from incidents if they do happen.

Business continuity planning has four steps:

  • Prevention – This is essentially the risk management part of the plan, which is to prevent problems from occurring in the first place.
  • Preparedness – This should be the fruits of your risk management plan, requiring to you have plans and resources in place to respond and recover from an incident. You should conduct a business impact analysis that identifies all of the resources, personnel and equipment critical to keeping your business running.
    Your plan should identify external stakeholders, the skills and knowledge necessary to run your business and how long your business can survive without performing these tasks.
  • Response – This part of the plan should cover what you do following an incident, such as containing, controlling and minimizing the effects. This should include details on when the plan would be activated, assembling an emergency kit, having evacuation procedures in place and a communication plan to implement during an event.
  • Recovery – After the initial response to an incident you will want to ramp up to full operations again as quickly as possible. You need to map out strategies to recover your business activities in the quickest possible time. That entails a description of key resources, equipment and staff required to recover your operations – and a time objective.

Making sure your business continuity plan is reliable and up to date will help you resume operations quickly after an incident and reduce the effects on your business.

While you may be able to predict and deal with a number of potential risks, there will be some that are unexpected or impossible to plan for.

That’s why the last two parts of your business continuity plan – incident response and recovery – are important, as they can be used after both foreseeable and unforeseeable events.

Also, depending on the size of your business, you may choose to have separate risk management, impact analysis, incident response and recovery plans, or a single plan incorporating all of the above elements – known as a business continuity plan.

A business continuity plan is a practical blueprint for how your organization will recover or partially restore critical business activities after a c

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The Effects on Your X-Mod When Purchasing Another Company

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Many companies are often taken off guard when their workers’ comp X-Mod shoots up after a merger or acquisition.

The experience modifier spike is usually the result of the other employer having a less than stellar workplace safety record and high workers’ comp claims costs. But there are pre-emptive steps you can take to understand the impact of the merger on your X-Mod and the more you know, the better chance you’ll have at coping with the changed circumstances.

The reason is that workers’ compensation rating bureaus have strict rules regarding mergers and acquisitions to ensure that companies don’t engage in shell games to hide their true workers’ comp claims experience.

The majority of states have the same rules for ownership changes and their effect on X-Mods.

First, let’s look at what a rating bureau will consider to be a change in ownership. Typically that would mean:

  • All or a portion of the ownership in an entity is sold, transferred or conveyed from one person to another.
  • An entity is dissolved or non-operative, and a new entity is formed.
  • Two or more corporations undergo a statutory merger or consolidation.
  • All or most of the tangible or intangible assets of an entity are sold, transferred or conveyed to another entity.
  • A trusteeship or receivership is set up, either voluntarily or at the direction of the courts, to operate a business.


What will happen
Rating bureaus will have something known as the “Notification of Change in Ownership Endorsement,” which requires that the purchasing party or merged entity report the ownership change within 90 days of the transaction.

Once that is done, the rating bureau will combine the experience of the two companies on a weighted basis to calculate a new X-Mod. It will do that by transferring the experience of the selling entity to that of the purchasing entity.

It’s the rating bureau’s job to review information you submit and make a decision as to how the change in ownership will affect the X-Mod for both the selling and purchasing entity.

They will decide, according to the rules for the purchasing entity, whether the modification factor will be adjusted to reflect the experience of the newly acquired entity.


What you need to do

An ownership change can have a number of ramifications for an employer in terms of workers’ comp, the most significant of which would be a change to its X-Mod.

It may also have an effect on your anniversary rating date and your rating effective date.

If you run the purchasing entity, the best course of action is to review the workers’ compensation history of the company being purchased so you have a full understanding of its workers’ comp experience. If they have a high incidence of workplace injuries, you can take pre-emptive safety measures when integrating the other company’s workforce.

You should also come to us if you know that you will be merging or acquiring another entity. We can run a test calculation to approximate what your new X-Mod will be.

We will pull your company’s data from the unit statistical report that your insurer submitted to the rating bureau, as well as that of the company you are purchasing. We can at that point determine the accuracy of the report in terms of your claims costs, payroll and classification codes.

Once we have the other employer’s information, we can crunch the numbers to come up with an estimate for your new X-Mod.

One more thing: Failure to report changes in ownership to your insurer may be considered X-Mod evasion and has serious implications. If the rating bureau determines evasion, it can go back as far as it chooses to examine your workers’ comp history.


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Pokémon Go and the Dangers to Your Business


The Pokémon Go craze has exposed people who play the game to new dangers that have previously not been associated with mobile phone apps.

But while many of these perils are associated with individuals who actually play the game, companies also have a lot to lose because of the game.

To play Pokémon Go, players follow their phone’s GPS, which leads them to various places in the real world where they encounter and capture in-game creatures called Pokémon.

In their zeal to catch these virtual critters, players have been robbed at gunpoint after walking into alleyways, been shot at for trespassing on private property, been hit by cars after walking into traffic – and even fallen off cliffs.

While these are all personal dangers, businesses also face risks, such as:

  • Workers’ compensation, if an employee plays the game while on the clock and gets hurt.
  • Data breaches, if employees who play the game on a company-issued mobile device download malware or are victims of phishing attempts.
  • Property liability, if players wander on to your business premises and are injured.


Workplace safety – The highly addictive game cuts across many demographics in terms of usage and is putting people in danger if they play it and are not paying attention. And since most people have jobs, the same people who play Pokémon Go are also employees, including yours.

As mentioned, many people have been injured playing the game. Already you must know that your employees are spending time on their smart phones doing things that are not associated with their jobs.

It doesn’t take much stretching of the imagination to understand that employees will play the game while on the clock.

If they play while driving on the job, they can not only injure themselves, but also add further liability if they injure someone else or damage a third party’s property. You may also have your own damaged property as a result.


Cyber security – The game was created by a company called Niantic Labs, which is owned by Alphabet Inc., the parent company of Google.

Problems at Niantic Labs have added to the security issues with Pokémon Go. Because of the company’s scalability problems, millions of users have had to download the app from third-party websites, where some of the software contains malware along with the game.


One version of the malware, called DroidJack, is able to gain access to anything on your Android phone, including all of your e-mail, contacts and text messages. In addition, this malware can access your keystrokes, on-board microphone and camera.

Now, imagine that an employee has downloaded the game onto their company-issued phone and that phone has as a result become a conduit for criminals to access your network.


Other liability – Businesses also face potential liability, as Pokémon Go players wander premises where they can hurt themselves. Construction sites carry specific dangers to anyone not paying attention if they enter the property. These include open trenches, trip hazards and nails and other fasteners strewn on the ground.

There was one report from Idaho of a Pokémon Go player wandering onto a farm and almost falling into a grain elevator.

So, if you have another commercial facility and players wander in and fall and hurt themselves, you could be held liable. Even if you face a lawsuit and eventually win, it will still cost you mounds in defense costs.


The takeaway

You should work with your company counsel to develop policies to address the phenomenon. These can include forbidding employees from playing the game on a company-owned device, while driving or during work hours.

You will also have to ensure that your properties are secure, especially after hours, to thwart overzealous Pokémon Go players from stepping onto your facilities and injuring themselves.

If you have security on your grounds, you should alert them to stop players from wandering into unauthorized areas.



OSHA to Issue Guidance on Acceptable Workplace Safety Incentive Programs

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Fed-OSHA has promised that it will soon publish guidance on what type of employee incentive programs discourage workers from reporting workplace injuries and illness.

The announcement comes after the workplace safety agency has clamped down on the use of programs that include incentives that can reduce the chances of workers reporting injuries so that they can receive rewards instead.

OSHA has been warning about the use of such programs since March 2012, but has issued no guidance to help employers. At the same time, it has increasingly been citing employers for using programs it considers problematic.

The problem for employers is that OSHA has not published guidelines to help them craft programs that are palatable to the workplace safety agency, but that looks likely to change.

David Michaels, assistant secretary of Labor, said in June that OSHA will publish a compliance directive that describes which types of incentive programs the agency wants to encourage and which types it has evidence discourage workers from reporting injuries and illnesses.

He promised that the directive would be published before 2017.

In a March 2012 memo, OSHA projected its disdain for worker incentive programs that may discourage workers from reporting injuries, saying they violate federal health and safety and whistleblower laws.

The paper, known as the “Fairfax memo,” gave examples of what the then-deputy assistant secretary for Labor, Richard E. Fairfax, called “discriminatory policies,” as follows:

  • Those that have the potential for unlawful discrimination because management or supervisor bonuses are linked to lower reported injury rates.
  • Entering employees who have not been injured in the previous year in a drawing to a win a prize, or rewarding a team of employees if nobody on that team is injured during a certain time period.
  • Those that disqualify an employee or an entire work group for receiving incentives if one of them is injured.
  • Any other programs that may dissuade workers from reporting injuries.


Besides the under-reporting of injuries, OSHA says the fallout from not reporting injuries goes deeper.

Such programs conceal workplace hazards that can instead remain unabated and continue to threaten workers’ health and safety. If workers don’t report injuries, management or the in-house risk manager will not know to investigate the incident and nothing can be learned from it.


Meanwhile, acceptable incentive programs may:

  • Reward workers who demonstrate safe work practices, and when they take proactive measures such as reporting close calls.
  • Reward workers who take steps to abate hazards, and use their stop-work authority to prevent a workplace injury.


Programs already under scrutiny

OSHA has taken a tougher tack on incentive programs since 2015, when it updated its safety and health program management guidelines.

Lawyers say that employers are being cited more often for having incentive programs that OSHA considers as discouraging reporting. And although all of the cases have been settled before going to trial, barristers say that defending against the citations cost the employers both time and money.

Insurance companies and employers have criticized the agency for its new stance, saying that it made its decision on employee incentive programs despite the fact that they have shown to be effective in reducing workplace injuries and illnesses.

And even though OSHA has not implemented regulations for incentive programs, the warnings have prompted some employers to stop using them, workplace safety experts say.



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OSHA’s Electronic Reporting Rules Contain Hidden Requirements


By now you should be aware of Federal OSHA’s new rules on the electronic reporting of workplace injuries and illnesses that will take effect next year.

But, while the new rules focus mainly on employers with 250 or more workers submitting Form 300A electronically starting in 2017, the new regulation actually contains a number of other rules that employers need to know about – in regard to additional notification and anti-discrimination implications for organizations.

One of those rules concerns “retaliatory adverse actions by employers.” The rule unsettled some employers groups, which have challenged it in court. As a result of the challenge, OSHA announced that it would delay enforcement of the provisions until Nov. 1, 2016, from the original implementation date of Aug. 10, 2016.

OSHA said it would use the next few months to “conduct additional outreach and provide educational materials and guidance for employers.”

Specifically, the new electronic reporting rules contain provisions on discrimination and retaliation, post-incident drug testing, and workplace safety incentive programs.


Discrimination and retaliation

Here’s what you need to know about the new rules:

  • Employers must ensure that their reporting procedures are designed so that they do not deter or discourage employees from reporting job-related injuries and illnesses.
  • Employers cannot have in place reporting mechanisms that are too burdensome, or require employees to take too many steps to report an injury or illness promptly.
  • Employers may not have in place policies that discipline employees for failing to report an injury in a timely fashion. This mainly concerns injuries that develop over time, like repetitive motion and cumulative trauma injuries.
  • Employers’ reporting mechanism and discipline policies must allow for reporting of injuries and illnesses within a reasonable timeframe after the employee has realized that he or she has suffered a work-related injury or illness.
  • Employers must inform employees that they have a right to report work-related injuries and illnesses free from retaliation. The workplace safety agency recommends posting OSHA’s “It’s The Law” worker rights poster, which is available on the agency’s website.
  • While retaliation against an employee who reports a workplace injury or a safety concern is already prohibited, the new regulation includes a provision stating employers must not discharge or in any manner discriminate against any employee for reporting a work-related injury or illness.
    While this seems redundant, it’s not. The change allows OSHA to issue citations for retaliation or discrimination even if an employee has not filed a complaint with OSHA.


Post-incident drug testing

Some workplace safety experts have said in the past that employer rules that require post-injury drug testing, may actually discourage workers from reporting injuries.

So, OSHA stated in its commentary on the regulation that blanket post-injury drug testing policies can be a form of retaliation.

“To strike the appropriate balance here, drug testing policies should limit post-incident testing to situations in which employee drug use is likely to have contributed to the incident, and for which the drug test can accurately identify impairment caused by drug use.”

It cited as examples of unreasonable testing, the drug testing of an employee who reports a bee sting, a repetitive strain injury, or an injury caused by a tool malfunction or lack of a machine guard.

In other words, if there is a reasonable possibility that drug use was a contributing factor to a reported injury, then testing would be permissible.

If you have a policy like this in place, you may want to review and revise it.

And OSHA seems to be focused on the “impairment” rather than just the presence of a drug. For example, a person can test positive for marijuana use for 30 days after ingesting it, but testing positive does not mean they were high at the time of the injury.


Workplace safety incentive programs

OSHA also stated in its commentary for the proposed rules that certain incentive programs that reward employees for remaining injury free at work can be retaliatory and deter reporting of injuries.

Although some employers offer to pay employees or a bonus or enter their names in a drawing for a prize in an effort to encourage workplace safety, OSHA states that these types of incentive programs result in the significant underreporting of recordable injuries, especially if employees are subjected to peer pressure from coworkers who also will be denied the award/prize as a result of a reported injury.

According to OSHA, this violates anti-retaliation regulations because an employer would take an adverse action – like denying a reward or benefit – because a worker reports an accident.

Instead, OSHA asks that employers use incentives for identifying hazards, participating in safety committees and similar activities.



IRS Proposes New Rules Making Health Coverage Opt-out Arrangements More Difficult


The IRS has proposed new regulations that add another layer of complication to any employer that offers or is considering offering the option of cash in lieu of payment to employees that decline employer-sponsored health coverage.

Already, any employer offering to pay employees who decline coverage has to walk a fine line and clearly state that the cash in lieu of payment is not to be used to purchase coverage elsewhere.

As a result of these newly proposed rules, employers that are still offering cash in lieu of coverage may want to reconsider doing so because if they make a mistake they could be subject to the biggest fine available under the Affordable Care Act: $36,500 ($100 for each day) per employee.

Under the proposed rules, employers that offer an unconditional cash-in-lieu option would be required to add the payment to what the employee would have been required to pay for coverage (had they elected to take it) in order to calculate if the plan is affordable under the ACA.

For an employer’s health plan to pass the ACA’s “affordability test,” it must cost the employee no more than 9.5% of their W-2 salary.

You should note that the opt-out arrangement must be completely unconditional and should in no way be tied to requiring proof of alternative coverage, such as through an exchange or a spouse’s employer-sponsored health plan.

There is one caveat under the new rules, though: the employer would be exempt from adding the cash in lieu of payment to the employee’s expected contribution if the employee can show proof that they have secured insurance that covers the “minimum essential coverage” standard under the ACA.

The employee would have to show reasonable evidence that they are insured. Under the proposed rules, sufficient evidence would be an employee’s affidavit that they have coverage or soon will have it.

The evidence must be provided in a timely manner, like during open enrollment, and must be provided annually, under the proposed rules.

Employers that still want to offer cash to employees that reject employer-sponsored coverage should carefully study the regulations, so that they can structure the arrangement in a manner that reduces the risk of being assessed penalties.




Why Your Employees Need Voluntary Disability Coverage


No one plans on becoming disabled and missing work, but it can happen. An illness or an accident could cause one of your employees to be unable to work for months, or even years.

While their health insurance will cover their medical expenses, it won’t cover the cost of living while they recover.

Only 30% of American workers in private industry currently have access to employer-sponsored long-term disability insurance coverage, according to the U.S. Bureau of Labor Statistics. That means most workers – and their families – do not have adequate protection against one of the most significant financial risks that they face.

That’s why you should be offering your employees voluntary short-term and long-term disability insurance. These policies provide income replacement to enable employees who are disabled to pay bills, including mortgages and college expenses, and to maintain an accustomed standard of living.

Disability insurance replaces a percentage of pre-disability income if an employee is unable to work due to illness or injury.

Employers may offer short-term disability coverage, long-term disability coverage, or integrate both short- and long-term coverage.

Short-term disability policies: These policies have a waiting period of zero to 14 days, with a maximum benefit period of no longer than two years.

Long-term disability policies: These policies have a waiting period of several weeks to several months, with a maximum benefit period ranging from a few years to the rest of your life.


Disability policies have two different protection features that are important to understand:

Non-cancelable – This means the policy cannot be canceled by the insurance company, except for non-payment of premiums. This gives your employees the right to renew the policy every year without an increase in the premium or a reduction in benefits.

Guaranteed renewable – This gives your employees the right to renew the policy with the same benefits and not have the policy canceled by the company. However, the insurer has the right to increase the premiums as long as it does so for all other policyholders in the same rating class as your employee.


Policy Options

In addition to the traditional disability policies, there are several options that you can also offer as part of the voluntary benefit package:

  • Additional purchase options. The insurer gives your employees the right to buy additional insurance at a later time.
  • Coordination of benefits. The amount of benefits your employees receive from the insurance company is dependent on other benefits they may receive because of their disability. The policy specifies a target amount they will receive from all the policies combined, so this policy will make up the difference not paid by other policies.
  • Cost of living adjustment (COLA). The COLA increases disability benefits over time based on the increased cost of living measured by the Consumer Price Index. Your employees will pay a higher premium if they select the COLA.
  • Residual or partial disability rider. This provision allows your employees to return to work part-time, collect part of their salary and receive a partial disability payment if they are still partially disabled.
  • Return of premium. This provision requires the insurer to refund part of the premium if no claims are made for a specific period of time declared in the policy.
  • Waiver of premium provision. This clause means that your employees do not have to pay premiums on the policy after they are disabled for 90 days.

 Doctor talking to patient getting MRI scan


New X-Mod System Reduces Effect of One Large Claim

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One of the biggest complaints in workers’ comp – that one large claim can skew an employer’s X-Mod – is about to finally be addressed in California.

The Workers’ Compensation Insurance Rating Bureau’s “split-point” experience rating system, in which an employer’s actual workers’ comp losses are divided into actual primary losses and actual excess losses, will be overhauled for 2017.

The Bureau will do so by replacing the current static $7,000 split point for all industries and employer sizes with a variable split-point system.

This change is expected to limit the impact of one large claim on an employer’s (particularly a small business’s) X-Mod. At the same time, an employer’s X-Mod would be more affected by the frequency of claims.

In other words, an employer that had one large $50,000 claim over three years would likely see a lesser impact on its X-Mod than a like employer with five $6,000 claims during the same period. Actuaries say this is because one large claim is not necessarily indicative of an employer’s safety efforts, which more claims are.

Under the current system, the first $7,000 worth of losses for each claim are considered primary claims costs, which count fully when calculating an employer’s X-Mod. Any losses above $7,000 are considered excess and have less weight in the experience rating formula.

Under the new system, the split point will vary from $4,500 to $75,000, depending on the size of the employer and their industry. The Rating Bureau predicts that there will be up to 90 different split points.


The effects

According to the Rating Bureau, the effects of the change to the split-point system include:

  • There will be no overall pure premium impact (no impact on average X-Mod).
  • Impacts on any individual employer’s X-Mod will depend on their claim and exposure history.
  • The variable split-point plan will generally be less volatile. It will be more sensitive to claim frequency and less sensitive to large claims.
  • The overall impact of the new plan will be generally modest.
  • Net movements of modifications above/below key thresholds – such as 100%, 125% and 200% – are expected to be less than 1%.
  • Modifications over 200% for small risks will be significantly reduced.

One thing that won’t change under the new rules is that X-Mods with only one loss in the calculation will continue to be limited to no more than a 25-point increase.

Right now the rating values have not been set. The Rating Bureau will include them in its rate-change filing for 2017, which it is scheduled to submit to the state’s Insurance Commission in August.


X-Mod eligibility

The Rating Bureau has also changed the way X-Mod eligibility is determined for California employers.

Starting in 2016, qualification is based on payroll over the past three years and on expected loss rates for the employer’s industry. Prior to 2016, X-Mod eligibility was solely based on premium level.

As a result, some single-employee companies in high-risk industries could be eligible.

For example, in the logging industry, an employer would need just one employee earning more than $60,000 a year to qualify for experience rating, while it would take an accounting firm 82 $60,000-a-year workers to qualify. That’s because expected claims for logging are so much more significant than those for accountants.

One of the main reasons for the change in X-Mod eligibility was that the Bureau was unable to issue X-Mods for an upcoming year until only after the insurance commissioner had approved the rates for that year. Sometimes that didn’t happen until November, which left precious little time for calculating X-Mods.

Under the new regimen, X-Mods can be issued as early as September for the upcoming year.

As a result, the expected loss-rate-based eligibility for 2016 was $10,300. That figure will change every year based on claims cost inflation.


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