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Setting the Strategic Direction for 2025 - 2028
It has been five years since the Interstate Insurance Product Regulation Commission (Commission) set course on its first formal strategic plan, Insurance Compact Compass: Strategic Plan 2020 - 2022 (Compass). The Compass centered on three key priorities:
- Uniform standards states support and companies willingly use;
- Nationally recognized regulatory review process; and,
- Resource for Compacting States, regulated entities and consumers.
The Commission has fulfilled the objectives and goals set within the Compass and is ready to chart its route for the next three years and beyond. The Compass was focused on strengthening the organization’s governance, communications, processes, and financial, and operational health. The Insurance Compact Compass 2.0 (Compass 2.0) will utilize the three overarching priorities listed above, to plot its action items for the next voyage of its strategic journey.
The Compass objectives remain constant as the Commission develops strategic action items for Compass 2.0. Uniform Standards are robust, responsive, and reasonable and deliver strong consumer protection. Its regulatory review process is responsive and reliable and fosters regulatory collaboration. As a resource, it is perceived as responsible, respected and ready.
Compass 2.0 identifies 26 member-driven strategic action items to guide the work of the Commission and its Compact Office over the next three years and beyond. This new strategic plan visits the accomplishments under the previous plan and overviews the process for wide input from members, regulators, state legislators, consumer representatives, and industry/company representatives.
These detailed action items are positioned under the ballast of their priorities and objectives. They are balanced and centered on fulfilling the Insurance Compact mission and purposes for and on behalf of its 48 Compacting States.
Compact Compass 2.0 Action Items
PRIORITY I: UNIFORM STANDARDS STATES SUPPORT AND COMPANIES WILLINGLY USE
- Strengthen policies and processes to address regulatory concerns with mix and match to confirm companies are using this process for legitimate reasons and to prevent the combination of state and Compact forms from being 1) non-compliant if wholly filed with the Insurance Compact or the state; or, 2) used to effectively amend forms approved by the Insurance Compact or the state, respectively.
- Streamline the five-year review process of Uniform Standards to transparently recommend changes while ensuring ample opportunities for member and public input.
- Develop an accelerated rulemaking process allowing Compacting States to amend existing Uniform Standards to better respond and adapt to regulatory changes and innovative product development available in the insurance marketplace.
- Increase development capacity to fulfill requests for new Uniform Standards and updates to existing Uniform Standards by recommending new or realigned processes and approaches as well as possible tools and resources to facilitate multiple development workstreams.
- Provide more flexibility for state insurance departments to exercise regulatory stays and opt outs to address conflicts between the Uniform Standards and state laws, especially when there is a later change to a model law/regulation, state statute, or Uniform Standard causing a conflict to arise.
- Expand the applicability and types of Uniform Standards to apply to more parts of the regulatory review and approval process for Compact-authorized products including advertisements, point-of-sale disclosures, and administrative forms and processes.
- Recommend options for common or consequential variations between Uniform Standards and applicable state statute where a Compacting State may petition to accommodate a statutory conflict within the Uniform Standards while keeping as much uniformity as possible.
PRIORITY II: NATIONALLY RECOGNIZED REGULATORY REVIEW PROCESS
- Create written procedures for filers to appeal product filing decisions including a level of review by a body of Compacting State regulators that provides a path for filers to challenge how the Uniform Standards and Operating Procedures are applied to product filings.
- Complete the implementation of the Commission-adopted framework for the approval of group products for use by non-employer groups (i.e., other than employer groups) to enable a streamlined process for Compacting States and company filers that preserves compliance with applicable state filing and eligibility requirements.
- Recommend a pilot process to implement new and enhanced services for Compacting States and their regulated entities that simplifies the multiple-state review and approval of products within the Compact-authorized product lines but outside the scope of the Uniform Standards.
- Develop a center for product innovation that allows companies to leverage the Compact’s product and actuarial expertise and incubate novel products and benefit features within the Compact’s authorized product lines.
- Create a simplified review process for forms that comply with a standard form template that the Insurance Compact deems consistent with the Uniform Standards.
- Implement NAIC SERFF Appian for the Compact filing instance to employ superior tools and functionality for the submission, review, and approval of product filing submissions, explore the use of artificial intelligence to enhance filing compliance, and improve transparency and reporting for Compacting States.
- Assess options for periodic audits or other peer reviews of Compact-approved product filings across product and filing types and companies to validate consistent, thorough, and quality reviews for compliance with the applicable Uniform Standards.
- Conduct surveys to gather feedback and develop written filing guidance to clarify, where needed, the Insurance Compact’s filing processes and procedures, including the application of Uniform Standards, and provisions therein, in the review of product filings.
- Conduct surveys to gather feedback and develop a plan of action to modernize the statement of intent schedule in SERFF for better ease of use when inputting state form or filing information.
- Carry out the comprehensive employee professional development program to ensure training in current best practices, development in respective professional fields, and ongoing succession planning.
PRIORITY III: RESOURCE FOR COMPACTING STATES, REGULATED ENTITIES AND CONSUMERS
- Enrich awareness of the Insurance Compact’s capabilities through written materials and collaborative outreach with Compacting State regulators to expand their understanding of the role and relationship of the Insurance Compact and its mission within the broader spectrum of insurance regulation.
- Develop and deliver training content for Compacting States and industry representatives on various aspects of insurance products and benefit features within the Insurance Compact’s authorized product lines.
- Explore partnership opportunities with the NAIC’s designation program to provide, complement, or supplement curricula for regulators performing rate and form filing functions.
- Conduct regular Compact Roundtables of members, state legislators, and consumer and industry/company representatives to discuss continuous improvements, emerging products, and regulatory trends, and new opportunities for product regulation efficiencies.
- Provide information, including periodic reports, to Compacting States regarding the pre-filing communications, filing review, and post-disposition activities of the Insurance Compact’s product review operations and develop a method to exchange information from and between Compacting States on state filings used with Compact-approved forms or state forms that could be filed within the adopted Uniform Standards.
- Work cooperatively with national state government organizations and other state entities to provide regular updates, issue briefs, and other requested communications of the Insurance Compact at its meetings or through other forms of targeted communication.
- Provide Compacting States access to a simple, unified electronic platform to access member-only content to communicate the Insurance Compact’s regulatory activities and maintain timely, useful and easy-to-find information on the Insurance Compact’s public website.
- Work with the members of the Consumer Advisory Committee and interested consumer representatives to provide consumer-oriented material and website information to assist consumers of Compact-approved products in understanding the Insurance Compact and its role on behalf of Compacting States.
- Survey filing companies to identify additional guidance or tools that the Insurance Compact could provide to ensure better compliance with Uniform Standards and filing requirements and report the findings and possible recommendations for suggested changes in processes, SERFF functionality, or Uniform Standards, as applicable.