INSURANCE ANTI-FRAUD PLAN REPORTING

Rule Chapter 69D-2, FAC was adopted September 15, 2006. Effective 20 days from this date insurers and Health Maintenance Organizations (HMO) were required to file updated SIU Descriptions or Anti-fraud plans pursuant to section 626.9891, Florida Statutes. The type of filing will be differentiated by the insurer’s volume of Florida annual direct written premium for calendar year 2006. Those insurers that write $10 million or more in annual direct written premium are subject to Section 626.9891(1), F.S. and 69D-2.003, FAC and those that write less than $10 million in annual direct written premium are subject to Section 626.9891(2), F.S. and 69D-2.004, FAC.

Rule Chapter 69D-2, FAC requires that insurers and HMOs file the updated SIU descriptions and anti-fraud plans on the division’s on-line, electronic database known as IFPR (INSURANCE FRAUD PLAN REPORTING). Further, the rule stipulates that insurers and HMOs must file the updated SIU descriptions AND/OR anti-fraud plans on FORMS specified by the division. There are only two types of forms available. The available forms are indicated below. An insurer or HMO will only make one filing, either the SIU description or anti-fraud plan depending on their premium volume.

At the time the rule was promulgated, there was no requirement* to submit annual or subsequent SIU descriptions or anti-fraud plan filings UNLESS THE CARRIER MAKES CHANGES in its anti fraud personnel (#2) or contact information (#6). If a carrier changes its name or is sold to a different insurance group, the carrier should submit an updated SIU description and or anti-fraud plan filing. The carrier should contact Denise E. Prather, DIF, FL DFS at Denise.Prather@MyFloridaCFO.Com to advise the proposed changes. *This is always subject to change so please periodically check to determine if DIF has modified the rule or the statute.

The following are required forms for submitting the SIU description and anti-fraud plan filings:

Form DFS-L1-1689/SIU Description – Word/PDF – if more than $10 million in Florida annual direct written premium.
Form DFS-L1-1689 (Word)
Form DFS-L1-1689 (PDF)

Form DFS-L1-1690/Anti-fraud plans – Word/PDF – if less than $10 million in Florida direct written premium
Form DFS-L1-1690 (Word)
Form DFS-L1-1690 (PDF)

Once the form is selected, the user will click on the form and “save” the form file to your computer files. You can save it as the form number, but it may be better to rename it after the form has been completed. The insurer or HMO should complete each of the component requirements (Questions) on the form. You can click “Instructions for Filing SIU Descriptions and Anti-fraud plans to IFPR” for detailed instructions to make the filing. For background, our division is seeking declaratory statements acknowledging the component requirements of the rule in the form filing. The rule filing allows an insurer to acknowledge specific component requirements without having to submit the detail of these requirements to the division. However, FL OIR Market Investigations may conduct audits of insurers. The insurer must be prepared to show that it has documented measures and plans in place that demonstrate the component requirements are viable within the SIU or insurer organization. We are only looking for acknowledgements of the component requirements as shown in the rule as Florida has a broad public records law and the anti fraud plan and SIU descriptions are subject to public record. However, it is important that your company develop viable investigative and detection techniques for their anti fraud personnel and claim staff. The OIR will look at training documentation records, referrals made to the division, claim files to be certain that adjusters have knowledge of “red flags” to detect insurance fraud, and tracking the time frame from when the suspected fraud is detected to when the suspected fraud is referred to the Division.

Frequently Asked Questions on Insurance Fraud Plan Report Filing

Insurance Fraud Plan Report Filing – IFPR to make filing

Rule 69D-2, F.A.C. Insurer Anti-Fraud Investigative Units and Anti-Fraud Plans

DFS Informational Memorandum