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Stakeholders debate "significant" threshold in premium-change notice — 2% or 10%?
Summary
Industry representatives urged a higher numeric threshold for listing factors that "significantly contributed" to premium increases, arguing a 2% cutoff is too low; consumer advocates pushed for clearer disclosure and written follow-up when errors occur.
At the RAC meeting, participants focused on how the draft rule defines a factor that "significantly contributes" to a premium increase. The draft's working language referenced a small-percent threshold (discussed in the meeting as 2%), but several industry participants urged a higher cutoff. "We did, just address that as believing that was lower than necessary... we're hoping to stick somewhere near the 10% that was in the original bill," Brandon Vic said.
Kenton and other trade representatives said listing only the few most significant factors—rather than an exhaustive list—would be more practical for insurers and clearer for consumers. Consumer advocates and United Policyholders pushed back that measuring inquiries against all premium increases (including routine inflation-driven increases) would undercount the rule's effect; Joel from United Policyholders recommended measuring inquiries specifically against instances of rate increases rather than all premium changes.
Staff acknowledged the drafting history: an earlier bill version contained a larger numeric threshold, but the statute ultimately adopted and the department's draft diverge on specifics. No numeric threshold was adopted at the meeting; staff asked members to send written suggestions and planned another meeting before proposing formal rules.
