Reasons 1 and 2: Why Mods Increase and What You Can Do About It

by Tim Coomer, Specific Software CEO

An unexpected increase in a client’s experience mod rating can be one of the more unpleasant client relationship situations you can experience in the workers compensation arena. This blog takes a look at 2 reasons why a mod might increase from one year to the next, but more importantly, what you can do to anticipate, analyze, and respond to potential increases in your clients' mods. In the weeks ahead, I will be covering a total of 10 reasons a mod may increase. With your feedback, which I encourage, I'm sure we can expand to an even longer list! Through awareness of these various scenarios and through effective use of ModMaster, you should be able to anticipate and explain increases in the mod.

Please view the full blog at http://workcompedgeblog.com/

Have You Worked 10,000 Hours Toward Your Goal?

by Tim Coomer, Specific Software CEO

My office is filled with portraits of my heroes: astronauts Frank Borman and Buzz Aldrin, Albert Einstein, Abraham Lincoln, Vince Lombardi, and NASA Flight Director Eugene F. Kranz - famous for saying “Failure is not an option." Behind my desk is a large framed painting of George Washington kneeling by his horse and praying. As this collection implies, I love grit, determination, and bold individuals who use hard work and dogged perseverance to make a difference.

I also like good old fashioned motivational speakers, books, seminars, etc., that deliver powerful words of inspiration. I gravitate to the concept summarized in this quote by Calvin Coolidge:

“Nothing in this world can take the place of persistence. Talent will not; nothing is more common than unsuccessful people with talent. Genius will not; unrewarded genius is almost a proverb. Education will not; the world is full of educated derelicts. Persistence and determination alone are omnipotent. The slogan "press on" has solved and always will solve the problems of the human race.”

Please view the full blog at http://workcompedgeblog.com/

Top 10 ModMaster Features of the Year

by Kory Wells with Nick Cunningham

As the year draws to a close and "best of 2009" lists permeate the media - best films, songs, books, news stories, and so forth, we've decided to make our own contribution with a list of the best new features in our ModMaster software that calculates the workers compensation experience modification rate.

There's a long list of ModMaster enhancements we've implemented this year. Here are some of the best!

We've based this list on both our web stats, which give some indication of our most popular features, and on the comments of our tech support staff who talk to and email with ModMaster users every day. Our staff asked to include a few features that were actually introduced in 2008 based on some of our more frequent questions, such as, "What's the loss limit in my state?"

Please view the full blog at http://workcompedgeblog.com/

Workers Comp by Webinar and Kindle; Technology for Agencies

by Kory Wells, WorkCompEdge Blog Editor

Sometimes we think of technology only as an expense, but when it's well-implemented, it can be an effective time and money saver. Today's blog features news about a cost-effective work comp webinar at which you can train a room full of people at one low price; Kindle delivery of our blog; and a free newsletter that will bring you more technology tips on a regular basis.

Interested in workers compensation training?


Better understand - and communicate with others about - the experience rating mod, premium overcharges, expected loss rates, loss runs, and more. Our friend Bill Wilson, Director of the Big "I" Virtual University (VU), will be offering a Workers Compensation Experience Rating Webinar on January 14, 2010, from 2:00 - 4:00 p.m. EST. We heartily recommend that you check it out (and no, we don't receive any type of compensation for making that recommendation).

Please view the full blog at http://workcompedgeblog.com/

More Details on the Significance of the 1/1/2010 California Workers Compensation Experience Rating Plan Changes

by Jeff Adcock, FCAS, MAAA, Consulting Actuary, SIGMA Actuarial Consulting Group

Editor's note: This is our final and most detailed article in a series on the 1/1/2010 changes in the California workers compensation experience plan rates and rules. It explains more about the key factors we summarized in our previous post, California 1/1/2010 Mod Calculation Change Advisory.


As you probably know from our previous blog entries, the Workers' Compensation Insurance Rating Bureau of California (WCIRB) pure premium filing with effective date 1/1/2010 proposed a 22.8% increase in the pure premiums, or filed loss cost benchmarks. In early November, the insurance commissioner rejected the proposed rate increase and ordered no change in the pure premiums overall, although individual class codes did see shifts.

The filing also proposed significant changes to the California Workers Compensation Experience Rating Plan (ERP), primarily driven by recommendations of the Experience Rating Task Force. The insurance commissioner accepted the proposed changes to the ERP, with the caveat that the Expected Loss Rates (ELRs) originally filed should be modified by 1% to maintain the same experience rating off-balance factor of 1.030 that was underlying the 1/1/09 pure premiums.

The following summarize the significant changes to the ERP effective 1/1/2010:

1. Changes/enhancements to the methodology for calculating the ELRs.
2. Use of a single split point of $7,000 to segregate individual claims into primary and excess components, in lieu of the current formula for splitting claims.
3. Changes to the D-Ratios and Credibility Values (“B” and “W” values) to reflect the adoption of a primary/excess split point of $7,000 and to reflect recent frequency and severity trends.
4. Increase in the experience rating eligibility threshold from $15,700 to $16,300 to reflect wage inflation.

The WCIRB states in its executive summary of the filing that “based on the proposed methodology change, the impact should be relatively minor for the overwhelming majority of experience rated employers”. However, based on the several moving parts above and particularly the significant changes in the ELRs for many class codes, it is our opinion that the experience modification factor for more than just a small minority will change. That’s why we believe it is more important than ever to consider in advance the impact these changes will have on a specific client, particularly those that must maintain an experience modification factor below a particular number. Now let’s explore these changes, and the mod trends we've seen in our analysis, in more depth.

Changes/Enhancements to the Methodology for Calculating ELRs

The WCIRB recommended changes to the calculation of the ELRs based on

• the final report of the Experience Rating Task Force and
• hindsight studies that showed ELRs for some groups were consistently higher or lower than indicated by actual experience.

The most significant change was using adjustment factors based on and grouped in accordance with the North American Industrial Classification System (NAICS). The following table taken from the WCIRB January 1, 2010 Pure Premium Filing (page B:C-12), shows the impact by NAICS group related only to the change in calculating adjustment factors at the NAICS group level:

Table 1: Approximate Impact of Recommended Methodology Changes on January 1, 2010 Expected Loss Rates
NAICS Sector Grouping	NAICS Sector Grouping Description	Approximate Expected Loss Rate Impact
11 & 21	Agriculture & Mining	+1.8%
22 & 23	Utilities & Construction	-7.1%
31	Manufacturing	+2.3%
42	Wholesale	+2.3%
44	Retail	+0.7%
48	Transportation & Warehousing	+0.5%
51	Information	+2.3%
52	Finance & Insurance	-0.5%
53	Real Estate	+15.9%
54	Professional Services	+2.1%
56	Administrative	+6.5%
61	Education	+7.3%
62	Health	+1.4%
71	Arts & Entertainment	+15.0%
72	Hospitality	+4.2%
81	Other	-5.0%
8742	Outside Sales	-12.2%
92 & 8810	Clerical & Public Administration	-4.1%

Again, the above estimated impacts reflect only the change in the methodology related to the adjustment factors. The ELRs effective 1/1/2010 also changed based on actual loss experience, of course. The individual class codes use between two and five years of policy year data (2002 through 2006) to calculate the indicated limited loss to payroll ratios which are the basis for the ELRs. For individual class codes, policy year 2006 rolling into the data while an older year rolls off may also have a significant impact.

The table below shows the change from 1/1/2009 to 1/1/2010 in the ELR for the 20 largest class codes by payroll. So for example, for class code 8742, even though the new methodology led to an expected decrease in the ELR of 12.2%, the actual change in the ELR including the impacted of updated experience in the filing, was a decrease of 20.0%.

Change in the ELR for 20 largest class codes in California based on 2006 payroll:

Class Code Number	Class Code Description	2006 Payroll	ELR Effective 1/1/2010	ELR Effective 1/1/2009	ELR % Change
8810	Clerical Office Employees Draftspersons Libraries — librarians or professional assistants Libraries — public	136,415,539,366	0.18	0.21	(14.3)%
8742	Salespersons — Outside Bookbinding — Salespersons — Outside Boy and Girl Scout Councils — executive secretaries Newspaper Publishing or Newspaper Printing — reporters, advertising Printing —Salespersons — Outside	35,047,398,931	0.20	0.25	(20.0)%
8859	Computer Programming or Software Development Internet or Web-Based Application Development or Operation	22,273,831,140	0.07	0.07	0.0 %
9079	Restaurants or Taverns Vending Concessionaires	12,756,678,084	1.43	1.36	5.1 %
8834	Physicians	11,581,691,389	0.55	0.61	(9.8)%
8820	Attorneys	9,349,385,502	0.20	0.21	(4.8)%
8017	Stores — retail Stores — hardware — retail Towel or Toilet Supply Companies Product Demonstrators and Sample Distributors — by contractors — in stores	9,283,425,404	1.49	1.46	2.1 %
8808	Banks	7,877,334,077	0.29	0.34	(14.7)%
8868	Colleges or Schools — private — academic professionals	6,724,807,252	0.45	0.45	0.0 %
8741	Real Estate Agencies	6,637,524,359	0.08	0.06	33.3 %
8803	Auditors or Accountants	5,580,897,170	0.14	0.14	0.0 %
8822	Insurance Companies	5,403,413,749	0.32	0.41	(22.0)%
8601	Engineers — consulting Oil or Gas Geologists or Scouts Geophysical Exploration	4,856,913,985	0.38	0.37	2.7 %
3681	Instrument Mfg. — electronic Computer or Computer Peripheral Equipment Mfg. Telecommunications Equipment Mfg. Audio/Visual Electronic Products Mfg.	4,593,377,471	0.63	0.66	(4.5)%
8018	Stores — wholesale	3,844,316,702	2.58	2.52	2.4 %
7610	Radio, Television or Commercial Broadcasting Stations	3,588,314,397	0.45	0.39	15.4 %
8830	Institutional Employees	3,403,364,192	0.89	0.85	4.7 %
9043	Hospitals	3,403,364,192	0.89	0.85	4.7 %
9610	Motion Pictures — production — all employees	3,335,051,000	0.77	0.92	(16.3)%
8391	Automobile or Automobile Truck Dealers	3,306,056,911	1.51	1.54	(1.9)%

PDF documents listing all class codes and their ELR and D changes, sorted three different ways, are available below

Sorted by Class Code Number

Sorted by Payroll (highest to lowest)

Sorted by Percentage Change in ELR between 1/1/2009 and 1/1/2010

Since most risks have several class codes, the impact on the individual risk will depend on the mix of payroll by class code. It's interesting to note that 116 out of 500 class codes, representing almost 50% of the total payroll in the state, have decreases of over 10% in the ELR from 1/1/2009 to 1/1/2010. 96 out of 500 class codes, representing less than 10% of the total payroll in the state, have increases of over 10% in the ELR from 1/1/2009 to 1/1/2010.

Impact of Change to a Primary Split Point of $7,000 per Claim

The ERP effective 1/1/2010 defines the primary loss amount as the actual loss amount capped at $7,000. Contrast that with the prior method of calculating the primary loss using the formula (9,000 x Total Loss) / (Total Loss + 7,000). A single split limit was recommended to simplify the experience rating formula and to be consistent with the experience rating formula used in other states. While the split limit in most states is $5,000, the limit amount of $7,000 limit was selected to minimize the impact, in total, of the change in formula. As noted on page B:C-35 of the WCIRB January 1, 2010 Pure Premium Rating Filing, based on the 2006 policy year projection, the D-Ratio for the $7,000 split is 0.203 and the D-Ratio based on the old formula is 0.199. So the change in the formula had minimal impact on the overall D-Ratios.

Even though the intent of the plan is neutrality in terms of the split of losses between primary and excess, the impact on individual losses varies. The table below summarizes the impact on the actual primary losses included in the experience rating formula for several individual loss amounts.

Change in primary losses for various loss amounts, old vs. new split method

Loss		Prior Method			Method Eff. 1/1/2010			% Change in
Amount		Primary	Excess		Primary	Excess		Primary Loss
2,000		2,000	0		2,000	0		0.0 %
2,500		2,368	132		2,500	0		5.6 %
5,000		3,750	1,250		5,000	0		33.3 %
6,000		4,154	1,846		6,000	0		44.4 %
7,000		4,500	2,500		7,000	0		55.6 %
10,000		5,294	4,706		7,000	3,000		32.2 %
15,000		6,136	8,864		7,000	8,000		14.1 %
20,000		6,667	13,333		7,000	13,000		5.0 %
24,500		7,000	17,500		7,000	17,500		0.0 %
25,000		7,031	17,969		7,000	18,000		(0.4)%
30,000		7,297	22,703		7,000	23,000		(4.1)%
40,000		7,660	32,340		7,000	33,000		(8.6)%
50,000		7,895	42,105		7,000	43,000		(11.3)%
75,000		8,232	66,768		7,000	68,000		(15.0)%
100,000		8,411	91,589		7,000	93,000		(16.8)%
125,000		8,523	116,477		7,000	118,000		(17.9)%
150,000		8,599	141,401		7,000	143,000		(18.6)%
175,000		8,654	166,346		7,000	168,000		(19.1)%

Losses less than $24,500 are included at higher amounts in the primary layer and therefore lead to an increase in the experience mod factor, all else being equal. Losses greater than $24,500 are included at lower amounts in the primary layer and therefore lead to a decrease in the experience mod factor, all else being equal.

Impact of Changes in the Credibility Values (“B” and “W” Values)

The last significant change to the ERP effective 1/1/2010 is the impact of the updated credibility values – calculated as a function of the Ballast (“B”) and Weighting (“W”) values. The current “B” and “W” values were adopted effective 1/1/1997, so it has been a significant amount of time since those have been updated. In the 13 years in between, claim frequencies have decreased and claim severities have increased.

The decrease in claim frequencies and the increase in claim severities are reflected in the approved “B” and “W” values effective 1/1/2010. The primary credibility, which is a function of the “B” and “W” values, increased by over 20% for risks with total expected losses (limited to $175,000 each) of between 11,820 and 40,147 during the experience period. Risks with total expected losses (limited to $175,000 each) of greater than 40,147 have primary credibility of 100%. With the prior “B” and “W” values, a risk needed expected losses of over $1.4 million for full primary credibility.

The higher the primary credibility, the greater the impact of the actual loss experience of the risk. Higher primary credibility will raise the experience mod on a risk with primary losses greater than expected primary losses. Conversely, higher primary credibility will lower the experience mod on a risk with primary losses less than expected.

The excess credibility has decreased on risks with expected losses (limited to $175,000 each) greater than $708,762.

Bottom Line of Impact of Changes to ERP Effective 1/1/2010

1. Change in ELRs - ELRs decreased by 6.4% in total, due to change in methodology and actual experience. 116 out of 500 class codes, representing almost 50% of the total payroll in the state, have decreases of over 10% in the ELR from 1/1/2009 to 1/1/2010. 96 out of 500 class codes, representing less than 10% of the total payroll in the state, have increases of over 10% in the ELR from 1/1/2009 to 1/1/2010.
2. Change in primary loss “split amount” – The move to a fixed amount of $7,000 per claim leads to individual losses less than $24,500 being included at higher amounts in the primary layer and increases the experience mod factors, all else being equal. Losses greater than $24,500 will be included at lower amounts in the primary layer and therefore decrease the experience mod factors, all else being equal.
3. Change in credibility values (“B” and “W” values) – Credibility factors related to the primary layer have mostly increased, and full primary credibility (i.e. 100% primary credibility) is now given to all risk with total expected losses (limited to $175,000 per claim) of $40,147. This increase in credibility will lower the experience mod for risks with primary loss experience less than expected. The opposite will occur for risk with primary loss experience greater than expected.

Question: Why did the WCIRB file for a 22.8% increase in pure premiums, but ELRs decreased approximately 6.4%? Aren’t they related, and shouldn’t the ELRs be increasing in line with proposed pure premiums?

WCIRB filed the 22.8% increase in pure premiums and the decrease in ELRs effective 1/1/2010 at the same time. It should be noted that the ELRs were later adjusted by 1.0% to take into account the impact of the experience rating off-balance.

There are probably a variety of factors at work including:

• the impact of reforms (the 2010 modification factors use 2006 through 2008 which are all post-reform)
• slight differences in indications based on policy year data used in setting the ELRs and the accident year data used in determining the overall pure premium increase
• the future impact of the Ogilvie and Almaraz/Guzman decisions

However, the main reason the indicated change in the ELRs and pure premiums are so different seems to due to the way the insurance commissioner has handled each in the past few rate decisions. While the insurance commissioner has not always approved the increase in the pure premiums proposed by the WCIRB, he has typically approved the changes (most increases) in the ELRs with only minor adjustments due to the impact of changes in the expected off-balance amount.

For example, as of 1/1/2009 the WCIRB filed for a 16.0% increase in pure premiums. The insurance commissioner approved a 5.0% increase in pure premiums but accepted the ELRs with only a 1% modification based on the off-balance factor change.

Question: Are certain mods more likely to increase as a result of these rate and rule changes?

While there are clearly no hard and fast rules about how a particular mod will change under the new rules, we have observed these trends in our analysis:

• For insureds with a mod above or below 1.00, the new mod formula will increase the gap from 1.00.
• For insureds with a high frequency rate - that is, numerous losses under the 7,000 split point - the new mod formula will increase the mod.
• For insureds with high severity - that is, relatively few losses greater than the 7,000 split point - the new mod formula will show little change.
• The new mod formula will penalize the smaller insureds while having minimal impact on the larger insureds.

We'd love to hear from you. Let us know if your experience and observations with mods under the new California rates and rules coincide with our analysis.

California 1/1/2010 Mod Calculation Change Advisory

by Kory Wells with Jeff Adcock and Tony King

ModMaster update 09.11, available to our clients on Friday, November 20th, includes support for the California rates and the split calculation change recently approved by the California insurance commissioner, effective 1/1/2010. If you do business in California - whether you use ModMaster or not - you need to be aware of how these changes may affect your or your client's workers compensation mod.

Our actuaries have been analyzing the data, and it's going to take us a few more days to get more details in a form to share with you. (Don't miss our previous post that excerpts the WCIRB summary of changes.) But we wanted to go ahead and alert you to a few key principles that may affect your mod under the new rules:

1. Our actuaries have determined that, on average, expected loss rates (ELRs) have decreased 6.4%. In fact, over 100 payroll codes had ELR decreases of 10% or more. While your results will depend entirely on the mix of payroll codes in your mod, an overall decrease in ELRs means that, if everything else stayed the same in your mod, you would have a good chance for your mod to increase in 2010.

2. An important loss level to keep in mind is $24,500. Under the new primary/excess split method, losses under $24,500 will have a greater primary value than they did under the old method. Since primary losses affect the mod more than excess losses do, this is another factor that may drive your mod up, especially if you tend to have more smaller losses than very large losses. Losses over $24,500 will generate a lesser primary value than they did under the old method, so if you have only losses over $24,500, this may benefit your mod.

3. The best defense is to be prepared for a mod increase, and a good way to do that is to compute your old mod with the new rates and split method. In ModMaster, this is easy to do (remember, you must be on update 09.11, code level 091118, or later):

• Select the desired mod file with a 2009 effective date, and note the current mod value. Use the Utilities/Copy feature to make a copy of the file with a new name.
• On the Company Setup page, change the effective date to 1/1/2010. Don't worry that this isn't the policy anniversary date, and don't change any other policy dates or other data.
• Calculate the mod and see what the 2010 value would be. You may want to look at your favorite ModMaster reports for the 2009 vs. 2010 files side-by-side, but don't forget that the Mod Comparison report will do a quick comparison for you.

Of course, in the real world, your 2010 mod will have different payroll and loss amounts due to the oldest policy period leaving the experience period and the new policy period coming in. In the real world, there are also a lot of other moving parts to the mod formula aside from the ELRs and the primary/excess split values. Certainly not everyone is going to see a mod increase, and some entities will see a decrease. But our testing and analysis has revealed some cases of attention-getting mod increases.

More details of our analysis are forthcoming. In the meantime, we'd love to hear from our users how the 2010 changes appear to impact the mod files they run with a 1/1/2010 effective date in ModMaster.

How Will the 1/1/2010 California Workers Compensation Split Formula Change Impact the Mod?

by Kory Wells with Jeff Adcock

The fact that California Insurance Commissioner Poizner has once again rejected an increase in workers compensation pure premium rates (read the November 10th Insurance Journal article California's Poizner Rejects Workers' Comp Increase Request, Again) is almost overshadowing the fact that he approved other changes that will interest workers compensation agents and others advising clients in the work comp arena.

As stated in the WCIRB's November 9th announcement:

The Insurance Commissioner approved amendments to the USRP include changes to the Standard Classification System and the elimination of the requirement of insurers to report social security numbers due to privacy concerns. The approved amendments to the ERP include (a) changes to the eligibility threshold, (b) classification expected loss rates, (c) the split formula used to segregate individual claims into their primary and excess components and (d) the ERP credibility ("B" and "W") values.

This announcement undoubtedly prompts questions such as:

How will these changes to the California rating plan affect the mod?
Part B of the 2010 Regulatory Filings posted on the WCIRB site goes into the changes and their anticipated impact in great detail. A brief summary (emphasis ours) lies in this sentence from page B:C-12:

While this methodological enhancement will improve the accuracy of experience modifications, the 2010 experience modifications for some employers will be impacted.

For those of you who are interested in learning more about the anticipated impact on the expected loss rates and the mod, we've packaged an excerpt of Part B in pdf form.

The first page (B:C-12) of the excerpt has a chart showing the impact on expected loss rates (not the mod itself) by industry sector that may be of interest. As you can see, real estate, arts and entertainment, and outside sales are some of the areas where the expected loss rates will change the most, with utilities and construction, education, and administrative also showing fairly significant impacts.

The second page (B:C-36) of the excerpt makes it clear that while the overall statewide average mod is NOT going to change, there will be some variability. The following pages, Exhibits 2.1 through 2.7, show the expected variation in the mod by size of account as measured by expected losses (Exhibits 2.1 through 2.5) and then by existing mod (Exhibits 2.6 and 2.7).

One of our actuaries, Jeff Adcock, consolidated the exhibit data into this spreadsheet (also available in pdf format) so you can have a one-page overview of the estimated impacts. The interesting thing about the existing mod analysis is how current risks with a mod of over 1.00 have a higher percentage of anticipated increase. Jeff is continuing to study the WCIRB documentation and may provide further analysis here on this blog, as warranted.

When will these changes be available in ModMaster?
The change in the split formula requires a ModMaster programming change. We were already working on this change prior to the commissioner's approval and now have it in testing. This change - along with the new expected loss rates and B and W values - should be available within a couple of weeks.

In the meantime, if you already have 2010 California mods that you could share with us for testing purposes, we'd certainly appreciate you doing so - contact support for more information.