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ADVISORY 2003-19

SUBJECT: Insured Names in Proof of Coverage Reporting (Commercial Carriers)

By Advisories 2002-07 and 2002-07B, Electronic Submission of Proof of Coverage (Commercial Carriers), the Texas Workers' Compensation Commission (Commission) instituted electronic filing of Proof of Coverage information by insurance companies (commercial insurance carriers) on September 1, 2002, as part of its Business Process Improvement Project. Self-Insured Governmental Entities and Certified Self-Insureds were not affected by this change. The Commission also designated two data collection agents: The National Council on Compensation Insurance, Inc. (NCCI), and Insurance Services Office, Inc. (ISO), to submit Proof of Coverage information to the Commission in accordance with the Texas Labor Code 401.024(c), 402.042(b)(11) and 406.009 and Rule 110.1.

Experience to date with electronic proof of coverage reporting, particularly where that reporting is accomplished through submission of Workers' Compensation Policy Reporting Specifications (WCPOLS) transactions to the Commission's designated data collection agents, has revealed significant problems with the reporting of insured employer names. These problems include such practices as reporting multiple names in a single name field, including non-name text in the name fields, indicating in the name field that the names of the insured are included in attachments that are not transmitted as part of the record and failure to follow proper name and address linking when reporting using WCPOLS.

The Commission recognizes that in some cases these problems result from characteristics of the carrier's automation system and cannot be changed without the expenditure of significant time and resources. The purpose of this Advisory is to state the Commission's requirements for the reporting of insured employer names and to encourage the carriers to make all reasonable efforts to improve reporting quality.

The basic requirement is that proof of coverage information be reported to the designated data collection agents in a manner that it results in one insured employer name per record when converted to the International Association of Industrial Accident Boards and Commissions (IAIABC) Proof of Coverage Release Two, May 1, 2002, data format. The following recommendations are offered for achieving this objective:

  • Do not use the "String name type" when reporting using WCPOLS (Workers Compensation Insurance Organization (WCIO) Workers Compensation Data Specifications Manual, Reference: under Products: Workers Compensation Policy Tape Reporting Specifications (WCPOLS), specifically:

  • II. Name Record Field No. 4 Type of Name Record Code (position 48),
    Code 3 String Name Type (a name record consisting of a string of names corresponding to one Name Link Code). Format is free?form.)
  • Follow proper name and address linking when reporting using WCPOLS. Each name should be individually linked to the appropriate address, specifically:

  • II. Name Record Field No. 5 Name Link Identifier (position 49-51),
    Report the 3-digit identifier representing one name or a group of names. The primary name(s) on the policy must always be reported as 001. Each name should have a separate Name Link Identifier in order to link to a specific address and exposure (if possible). If this is not possible, you may provide more than one name for each name link identifier reported.
  • Do not include non-name text in the name field (i.e. Named Insured:, Additional Named Insured:, etc.)

  • Do not list insured employer names in attachments - they must be entered in the data fields.

  • Coordinate with your designated data collection agent to take advantage of the agent's ability to parse multiple names into single name records. Both agents have developed algorithms for this purpose and will provide assistance in developing reporting techniques that will take advantage of their capabilities.

As all members of the workers' compensation system move to ever-greater use of automation and direct data transfer to achieve economies and efficiencies, data quality becomes more and more critical. We solicit the cooperation of all parties toward this end.

Questions concerning Advisory should be directed to Robin Miksch, Chief, Records Processing, (512) 804-4372,

Signed on this 28th day of August, 2003

Richard F. Reynolds, Executive Director

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