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The Insurance Compact has maintained a waiting list for the Expedited Review Program for most of the year. While we are pleased that this optional program is in demand, we researched factors that add to review time in the expedited review queue. All filers interested in this filing option should read this weekly tip and share it with your team.

The Expedited Review Program is designed for filings that are ‘clean’ or substantially compliant and require minimal objections. This ensures review efficiency therefore fulfilling the purpose of expedited review and keeps the expedited review queue moving quickly for the benefit of all participants. The Compact Office has identified a list of yellow flag issues that slow down review time even though the eligibility criteria for expedited review were satisfied.

In lieu of modifying the eligibility criteria for expedited review for all filers, the Compact will monitor the presence of yellow flag issues in expedited review filings. A filing that generates any of the listed concerns could affect your company’s future ability to utilize the expedited review process until the filer has demonstrated the ability to avoid yellow flag issues in up to three subsequent filings in the regular review queue. The Compact Office will notify the filer who made the expedited review request if there is a yellow flag after the review is complete and advise about next steps to maintain eligibility for expedited review.

1. Referring to a previously approved filing when a new form contains extensive changes from the approved form.
2. Referring to a previously approved filing while adding a feature that is unique which more appropriately should have been the subject of a pre-filing request.
3. Sloppy objection response preparation which includes incomplete attachments, wrong attachments, incomplete responses or not using the current version of a form when providing a response letter.
4. Incorrect filing information especially as it relates to the purpose of the form or how the form is used.
5. Pushing back on objections.  Remember, filings that are good candidates for expedited review are quality filings that will not require substantial objections.
6. Filing communication outside of SERFF to address or clarify objection issues.
7. Requiring conference calls to discuss objection issues.

The criteria for the Expedited Review Program are found on the Insurer Resources page of the Compact website. If you have any questions about the Expedited Review Program, or about filing with the Insurance Compact in general, please contact the Insurance Compact Office.