The WCRIBMA has a number of data collection mechanisms including, policy and proof of coverage data, unit statistical report (USR) data and aggregate financial (AF) call data. By imposing fines for data errors and late reporting, these programs, in effect, transfer a portion of the data correction costs to those companies responsible for the errors. There are five data quality programs. These are:

1. Policy Data Quality Incentive Program (PDQIP)
2. Unit Statistical Data Quality Incentive Program (USDQIP)
3. Aggregate Financial Call Acknowledgment Process
4. Aggregate Financial Data Quality Incentive Program (AFDQIP)
5. Examinations and Reconciliations

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Programs Summaries

A summary of each Data Quality Compliance Program is listed below.

See the following Circular Letters for historical background on Data Quality Compliance implementation and changes:

Circular Letter #	Issue Date	Title
2336	06/29/2018	Unit Statistical Reporting Data Quality Incentive Program
2318	06/30/2017	Policy Data Quality Incentive Program
2317	06/30/2017	Unit Statistical Reporting Data Quality Incentive Program
2304	12/30/2016	Policy Data Quality Incentive Program
2303	12/30/2016	Unit Statistical Reporting Data Quality Incentive Program
2290	07/01/2016	Policy Data Quality Incentive Program (PDQIP)
2289	07/01/2016	Data Quality Incentive Program for USR Data Reporting (USDQIP)
2274	12/30/2015	Policy Data Quality Incentive Program (PDQIP)
2260	06/30/2015	Policy Data Quality Incentive Program (PDQIP)
2250	12/30/2014	Policy Data Quality Incentive Program
2224	08/30/2013	Revisions to the Massachusetts Workers' Compensation Statistical Plan
2220	07/24/2013	Policy Data Quality Incentive Program
2168	01/18/2011	Revisions to Parts I & II of the Massachusetts Workers' Compensation Statistical Plan.
2101	10/01/2008	Revisions to the Massachusetts Workers' Compensation Statistical Plan - Part I
2083	02/20/2008	Revisions to the Massachusetts Workers' Compensation Statistical Plan - Part I
2064	07/30/2007	Revisions to the Massachusetts Workers' Compensation Statistical Plan - Part II - Section V, Data Quality Incentive Program
1956	06/15/2004	Revisions to Part I of the Massachusetts Workers' Compensation Statistical Plan
1939	12/22/2003	Revisions to the Massachusetts Workers' Compensation Statistical Plan
1909	01/17/2003	Revisions to the Massachusetts Workers' Compensation Statistical Plan
1851	08/04/2000	Data Quality Incentive Programs

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Policy Data Quality Incentive Program (PDQIP)

Fines associated with Policy and Proof of Coverage Data will be imposed for the following situations:

Timeliness Fines

For residual market policies, policy data records with transaction type codes of 02 or 05 are subject to timeliness fines. For voluntary policies, policy data records with transaction type codes 01, 02 or 05 are subject to timeliness fines. For transaction type code 01 (New Policy) and 02 (Renewal Policy), timeliness fines are incurred when the data is accepted into the  WCRIBMA's system beyond 30 calendar days of the policy effective date. For transaction type code 05 (Cancellation/Reinstatement), timeliness fines are incurred when the data is accepted into the WCRIBMA's system beyond 30 days of the transaction issue date.

Data Quality Fines

A finable data quality edit is not corrected and/or adequately explained by the due date.

Invoicing

On the fifth of every month, notice of PDQIP invoices are emailed to data contacts on file. The invoices can be viewed in the Invoice Management Portal product within the SOSA area of the WCRIBMA website. Changes to contacts must be reported to Data Operations Department via email (DataOperations@wcribma.org).

Appeals

If the carrier or carrier group (carrier) is subject to a fine, which in the opinion of the carrier is inappropriate, the carrier is encouraged to work with staff of the Data Operations Department to address such issues within 10 business days of issuance of the invoice. Written appeals must be submitted to the Data Operations Department via email at DataOperations@wcribma.org. The written appeal must be submitted by an officer or senior manager of the carrier within 20 business days of the Invoice Date on the invoice for the particular fine(s) at issue. The appeal must include copies of the relevant invoice(s), all pertinent written communications and detailed statements that describe why the carrier thinks the fine(s) is inappropriate. The WCRIBMA will provide the carrier with its written decision on the carrier’s appeal within 5 business days of its receipt of the appeal.

If the carrier is not satisfied with the WCRIBMA’s decision, it may appeal to the WCRIBMA’s Appeals Subcommittee within 20 business days of the carrier’s receipt of the WCRIBMA’s written decision. To initiate an appeal to the WCRIBMA’s Appeals Subcommittee, the officer or senior manager of the carrier who submitted the written appeal to the Data Operations Department must send notice via email to DataOperations@wcribma.org. Indicate within the email if a representative for the carrier wishes to present its case in person to the WCRIBMA’s Appeals Subcommittee. Carriers are not obligated to have a representative present their case in person.

Upon the WCRIBMA’s receipt of timely notification by a carrier of its intent to appeal the WCRIBMA’s decision, the WCRIBMA’s Data Operation Department will forward an appeal package, containing the appeal materials previously submitted by the carrier along with the WCRIBMA’s decision to the WCRIBMA’s Appeals Subcommittee. The WCRIBMA’s Appeals Committee will then review the appeal and render a decision within 60 business days from the receipt of the appeal package.

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Unit Statistical Data Quality Incentive Program (USDQIP)

Fines associated with Unit Statistical Reports (USRs) will be imposed for the following situations:

Timeliness Fines

Missing policies – a USR was submitted and rejected because no corresponding Policy and Proof of Coverage Data is in the WCRIBMA system, and the policy still has not been submitted or the USR is still not in an accepted status before the 21st month from the policy effective date.

Delinquent USR – a USR is expected as a consequence of Policy and Proof of Coverage Data reporting, but it is not submitted before the 21st month from the policy effective date.

Rejected Correction Report – a USR correction report remains in rejected status for 3 months, following the last day of the month in which the unit was rejected.

*Data reporters have access to due, delinquent and rejected unit statistical data via the Manage USR Unit Statistical Tracking System (USTS) found within the SOSA area of the WCRIBMA website.

Data Quality Fines

A finable data quality edit is not corrected and/or adequately explained by the due date.

Invoicing

On the fifth of every month, notice of USDQIP invoices are emailed to data contacts on file. The invoices can be viewed in the Invoice Management Portal product within the SOSA area of the WCRIBMA website. Changes to contacts must be reported to Data Operations Department via email (DataOperations@wcribma.org).

Appeals

If the carrier or carrier group (carrier) is subject to a fine, which in the opinion of the carrier is inappropriate, the carrier is encouraged to work with staff of the Data Operations Department to address such issues within 10 business days of issuance of the invoice. Written appeals must be submitted to the Data Operations Department via email at DataOperations@wcribma.org. The written appeal must be submitted by an officer or senior manager of the carrier within 20 business days of the Invoice Date on the invoice for the particular fine(s) at issue. The appeal must include copies of the relevant invoice(s), all pertinent written communications and detailed statements that describe why the carrier thinks the fine(s) is inappropriate. The WCRIBMA will provide the carrier with its written decision on the carrier’s appeal within 5 business days of its receipt of the appeal.

If the carrier is not satisfied with the WCRIBMA’s decision, it may appeal to the WCRIBMA’s Appeals Subcommittee within 20 business days of the carrier’s receipt of the WCRIBMA’s written decision. To initiate an appeal to the WCRIBMA’s Appeals Subcommittee, the officer or senior manager of the carrier who submitted the written appeal to the Data Operations Department must send notice via email to DataOperations@wcribma.org. Indicate within the email if a representative for the carrier wishes to present its case in person to the WCRIBMA’s Appeals Subcommittee. Carriers are not obligated to have a representative present their case in person.

Upon the WCRIBMA’s receipt of timely notification by a carrier of its intent to appeal the WCRIBMA’s decision, the WCRIBMA’s Data Operation Department will forward an appeal package, containing the appeal materials previously submitted by the carrier along with the WCRIBMA’s decision to the WCRIBMA’s Appeals Subcommittee. The WCRIBMA’s Appeals Committee will then review the appeal and render a decision within 60 business days from the receipt of the appeal package.

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Aggregate Financial Call Acknowledgement Form Process

Fines associated with the Aggregate Financial Call Acknowledgement Form will be imposed for the following situations:

Timeliness Fines

A completed form is not submitted by the due date.

Inappropriate Signatory Fines

Forms that are submitted without the signature of a company officer or a company actuary who is a member of the Casualty Actuarial Society and/or a member in good standing of the American Academy of Actuaries will incur a fine. Additional fines will begin to accrue if a corrected form is not submitted by the due date.

Aggregate Financial Data Quality Incentive Program (AFDQIP)

Fines associated with the Aggregate Financial Calls will be imposed for the following situations:

Timeliness Fines

Data calls are not submitted by their respective due dates.

Data Quality Fines

Basic Edit Failures – Per Occurrence Fine - a call is submitted with a basic edit failure.

Basic Edit Failures – Timeliness Fine - a basic edit failure is not corrected by due date.

Actuarial Edit Failures – Timeliness Fine - an actuarial edit is not corrected and/or adequately explained by the due date.

Invoicing

On the first of every month, AFDQIP invoices are emailed to data contacts on file. Changes to contacts must be reported to Data Operations Department via email (DataOperations@wcribma.org).

Appeals

If the carrier or carrier group (carrier) is subject to an AFDQIP fine, which in the opinion of the carrier is inappropriate, the carrier may submit a written appeal to the Data Operations Department via email (DataOperations@wcribma.org) or to the following address:

Data Operations Department
WCRIBMA
101 Arch Street, 5th Floor
Boston, MA 02110

Appeals must be received within twenty (20) business days from the invoice date in order to be considered.

The WCRIBMA’s decision may be appealed to the Commissioner of Insurance. An appeal to the Commissioner must be filed within thirty (30) days of receipt of the WCRIBMA’s decision.

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Examinations and Reconciliations

Fines associated with Examination and Reconciliations will be imposed for the following situation:

Timeliness Fines

A Triennial AUP findings report is not submitted by the due date.

Disciplinary Fine

Disciplinary fines are in addition to the Data Quality Compliance Program fines described above.

Sample of reasons for Disciplinary Fines:

1. In a filing the WCRIBMA must adjust, correct or make allowances for inaccuracies in the data supplied by a carrier or carrier group.
2. Unsuitable data for use in a WCRIBMA filing.
3. Unresponsive to requests for overdue calls.
4. Unresponsive to requests or unsatisfactorily responses to attempts to resolve data anomalies.
5. Uncooperative with WCRIBMA and/or auditing firms in connection with Targeted AUP.
6. Noncompliance with triennial examination.
7. Missing, rejected or filtered data excluded from data reconciliation process.
8. At the direction of the Commissioner due to unreliable, incomplete, untimely or otherwise defective aggregate financial data that materially impacts a filing submitted to the Commissioner.