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Mandatory Insurance Reporting - Frequently Asked Questions

New Insurance Reporting guide is available at:
http://transportation.ky.gov/mvl/insurance/ins_info.htm
Please be aware that the original layout has been modified in order to accomodate the input from some of the insurance providers/companies.

1.
What insurance policy reporting does Kentucky require under the new law?
2.
What types of policy coverage is to be reported?
3.
Will the company providing the data receive acknowledgement from Kentucky and how do we handle errors returned to us?
4.
Will VIN numbers be validated by Polk or some other source?
5.
Is there any ETA yet when final specs will be available after the March 23rd 2005 meeting? Updated 9/13/05
6.
Can the insurance companies implement earlier in the year (ex. May 2005) rather than later knowing that December 2005 would be the latest to meet the 1/1/06 deadline? Updated 9/13/05
7.
Will you be using an X12 format?
8.
What NAIC do you use for the F01 records and the F99 records.. Your F02 and F98 are the envelopes for each NAIC.
9.
What is the certification/registration process for a company to complete before sending data?
10.
What are the error messages that could potentially be sent back to the company providing the data? - Updated 12/08/2005
11.
1. Will "effective" and "expiration" dates be the same for each policy, insured, and vehicle record segments on a vehicle?
2. Would Kentucky ever want a policy effective date and a different vehicle or insured effective date for that policy?
12.
Does the Header and Trailer record count as part of the "number of records" field?
13.
What is the expected reporting schedule for data?
14.
What connectivity method will be used?
15.
What is the match criteria on the insurance transactions? Updated 9/13/05
16.
Does Kentucky proactively send out insurance verifications?
17.
What is your non-compliance process? / What is the penalty if I don't report full book of business? Updated 9/13/05
18.
What is the Kentucky Service Provider Code (PNNNN)? Will the 5 digit NAIC code be OK for this field?
19.
How do I find out what my three digit KOI license number is?
20.
How do I report cancellations on Commercial vehicles if I don't have VINS?
21.
What if my company has more than one VIN on a policy? How does the file look in that case?
22.
What is the penalty if I don't report Full Book of Business?
23.
If I am a provider and send in a data file for one insurance company and then later the same day I want to send another data file for another company how will you handle that?
24.
What type of data is allowed in the submission files? - NEW!
25 
What are the file naming conventions for sending and retrieving files from Kentucky? - NEW!
   
   

1)

Q:

What insurance policy reporting does Kentucky require under the new law?

 

A:

The new law specifies that as of January 1, 2006, 'Full Book of Business' (FBB) is to be reported for Personal Line Policies. This law eliminates reporting 'terminations' for Personal Line Policies. Terminations, which include 'cancellations' and 'non-renewals', for Commercial Line policies was not addressed in the new law and is still required.

Commercial Line Policies may be reported with FBB. However, Commercial Line 'terminations' are still required to be reported via a separate 'Cancellation' report. The only 'change' is both submissions are to be transmitted (no alternative media such as tapes, discs or hardcopy reports) in the same electronic format. A FBB submission is distinguished from a Commercial 'Cancellation' by an indicator in the Submission Header.

 

 

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2)

Q:

What types of policy coverage is to be reported?

 
A:
Kentucky law specifies that 'Motorized' vehicles 'Registered' in the Commonwealth must be covered by Liability insurance. However, it is doubtful that all insurance companies know which vehicles they insure in Kentucky are defined in our system as 'Motorized' and are 'Registered'. Therefore, it is recommended that 'if in doubt' send it in; our Insurance system will delete or ignore non-applicable policies.

For FBB, if the policy is active on the last day of the month prior to the submission, include it. 'Future' policies may be included, i.e., policies whose effective date is in the month of the submission.

For Commercial Policy terminations, report all terminations that occurred for the month being reported. Vins are to be included on terminations except for 'blanket policies' where they are not recorded with the policy; sometimes referred to as 'Unscheduled' or 'Commercial' Fleets.
   
3)
Q:
Will the company providing the data receive acknowledgement from Kentucky and how do we handle errors returned to us?
 
A:
The report will be processed overnight on the day it was received. Upon processing the file an e-mail acknowledging this will be sent to the technical contacts provided to KYTC during company registration. The e-mail will specify whether the file was successfully processed or rejected and will include a Summary Processing Report specifying the number of policies and vehicles added, updated and deleted (cancelled) from the master Insurance File for each company (NAIC) included on the submission.
Additionally, a detailed 'Processing Report', primarily errors, will be placed in a secure dataset where the company can retrieve it using the same software used for submitting the report. A complete list of possible errors is located on our web site www. . . . . . . . . . . . Except for errors preventing file processing, all can be corrected and included in the following month's report.
Note - the only practical way to determine whether the file was truly intended for Kentucky is to look at the number of policies submitted. If all were added and a similar number were 'cancelled', then more than likely the policies were not intended for Kentucky.
Kentucky will not report 'Vin errors': all that may be known from the submitted FBB or Commercial termination is the submitted Vin does not match a Vin on our system; it does not tell whether the submitted Vin is erroneous or whether the vehicle is currently registered in our system. Furthermore, the system is not capable of researching the database with a non-matching Vin to determine the problem and there is a mechanism available during the Registration process when the discrepancy is accurately resolved.

   

4)

Q:

Will VIN numbers be validated by Polk or some other source?

 

A:

Yes, we will be using Polk via our AVIS system.

 

 

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5)

Q:

Is there any ETA yet when final specs will be available after the March 23rd 2005 meeting?

 

A:

There is now a Draft Insurance Guideline dated 8/15/05. The Guideline is currently going through the regulatory process to be approved as part of the regs.

 

 

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6)

Q:

Can the insurance companies implement earlier in the year (ex. May 2005) rather than later knowing that December 2005 would be the latest to meet the 1/1/06 deadline?

 

A:

October 1, 2005 is Kentucky's target date to start accepting test files. Once the actual data is tested for validity and the submitting company is set up for connectivity the state can begin receiving production files. However, every company and service provider must successfully complete a test run prior to submitting a production file.

 

 

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7)
Q:
Will you be using an X12 format?
 
A:
The X12 format will not be used. The format to be sent will be a proprietary file format. Please see the Draft Insurance Guideline for details.
   
8)
Q:
What NAIC do you use for the F01 records and the F99 records.. Your F02 and F98 are the envelopes for each NAIC.
 
A:
The purpose of the Submission Header and Submission Trailer records (F01 and F99) is to accommodate Service Providers, or Insurance Companies acting as Service Providers, where more than one company is included in the submission (report). The NAIC on the F01 and F99 is that of the submitter. If the submitter is an insurance company and only reporting one company, the NAIC on the Submission Header and Company Header will be the same.

The NAIC of Service Providers (who are not insurance companies) will be assigned by the system at the time the service provider registers with the Transportation Cabinet (KYTC). At that time, they will be informed of their 'NAIC'.

   
9)
Q:
What is the certification/registration process for a company to complete before sending data?
 
A:
Contact the Transportation Cabinet at KYTCLiabilityInsuranceContacts@ky.gov. They will e-mail a form for you to fill out regarding contact information etc. You will then be logged in as "In test". Once Kentucky can process your submissions, essentially an "Acceptance Test", you will be certified to submit production files. If you will be representing additional companies there is a section on the form where the NAIC's of those companies are to be listed.
   
10)
Q:
What are the error messages that could potentially be sent back to the company providing the data?
 
A:
Insurance Error Report - Word or Acrobat Reader
   
11)
Q:
1. Will "effective" and "expiration" dates be the same for each policy, insured, and vehicle record segments on a vehicle?
2. Would Kentucky ever want a policy effective date and a different vehicle or insured effective date for that policy?
 
A:
1. Yes. 2. No. For Kentucky's purposes we just need to know the Effective and Expiration dates of the policy. As vehicles are added or deleted from the policy their VIN's will be included or not included on the monthly submission and consequently added and deleted from Kentucky's data.
   
12)
Q:
Does the Header and Trailer record count as part of the "number of records" field?
 
A:
The field F98-NUM-RECORDS will count the trailer for the NAIC totals in the count. The field F99-NUM-RECORDS will include the header and trailer for the Submission Totals in the count.

Consider the following example:
F01: F02: F03: F04: F05: F05: F05: F98: F02: F03: F04: F05: F03: F04: F05: F05: F98: F99
The first F98-NUM-RECORDS would be 7. The second F98-NUM-RECORDS would be 9. The F99-NUM-RECORDS would be 18.

   
13)
Q:
What is the expected reporting schedule for data?
 
A:
As of January 1, 2006, "Full Book of Business" reporting is required for Personal Line policies and is required to be submitted between the 1st and the 15th of each month. Commercial Line policies are optional on "Full Book of Business" reporting. Terminations (i.e., cancellations and non-renewals) are required for Commercial Lines policies and are due within one (1) week; this is no change from the current requirement and will remain in force.
   
14)
Q:
What connectivity method will be used?
 
A:
Starting in August 2005 companies may submit via FTP or FTPS. A system upgrade is scheduled later in August that will process SFTP. Eventually, for production data, the insurance company will be able to choose FTP, FTPS, or SFTP.
   
15)
Q:

What is the match criteria on the insurance transactions?

 
A:
The only mass criteria used is the vin number. As each citizen comes to the county clerk office 'first time' or to renew their vehicle registration, the insurance file will be accessed using the VIN from our Titling and Registration System to verify the vehicle is insured. If the VIN cannot be located in the insurance file the citizen will be required to show the proof of insurance card. The company NAIC and policy number from the card will then be entered and another access made against the insurance file. All VINS associated with that policy number are retrieved and the county clerk can manually determine if the vehicle is insured based on the VIN's found. If the county clerk determines this is the same vehicle the computer application will add the Titling and Registration System's VIN to the policy as an "alias". Thereafter the citizen will not have to show the proof of insurance card on that VIN with that policy.
   
16)
Q:
Does Kentucky proactively send out insurance verifications?
 
A:
No.
   
17)
Q:
What is your non-compliance process? / What is the penalty if I don't report full book of business?
 
A:
After the 15th of each month the system will be checked to see if any companies have failed to report for that month. A list of companies that have not reported will be forwarded to the Department of Insurance for follow-up enforcement.
   
18)
Q:
What is the Kentucky Service Provider Code (PNNNN)? Will the 5 digit NAIC code be OK for this field?
 
A:
The Kentucky Service Provider Code (PNNNN) is for third parties that provide the reporting service for some insurance companies. An insurance company may also provide such services for other companies.
   
19)
Q:
How do I find out what my three digit KOI license number is?
 
A:
You need to create a request on your company letterhead asking for the KOI number. This request should be faxed attention PNC to (502) 564-2728
   
20)
Q:
How do I report cancellations on Commercial vehicles if I don't have VINS?
A:
Please read the KRS that refers to Commercial vehicle cancellations, http://www.lrc.ky.gov/krs/304-39/085.pdf.
   
21)
Q:
What if my company has more than one VIN on a policy? How does the file look in that case?
A:

Consider the following example:

F01: F02: F03: F04: F05: F05: F98: F99
This example shows one submission header (F01), one NAIC header (F02), one policy info (F03), one policy holder info (F04), and 2 vehicles (F05, F05). This is the correct format for reporting when you have more than one vehicle on a policy.

   
22)
Q:
What is the penalty if I don't report Full Book of Business?
A:
This information will be forwarded to the Kentucky Office of Insurance for appropriate administrative action.
   
23)
Q:
If I am a provider and send in a data file for one insurance company and then later the same day I want to send another data file for another company how will you handle that?
A:
As you send in the data be sure to use the append command so your file will always add on to the end of a file that is already sitting in your folder. Kentucky will process the files once a day so if you send more than one file in a days time you will cover it up unless you append the data. Along those same lines, if you find you have sent an incorrect file you can re-send the correct one and it will cover the first file as long as this is all done within the same day.
24) Q:
What type of data is allowed in the submission files?
  A:
We can only accept data in submission files in UPPER CASE only, lower case data cannot be accepted.
25) Q:
What are the file naming conventions for sending and retrieving files from Kentucky?
  A: File naming conventions.
   

 

Tonya Davis, Division of Motor Vehicle Licensing
200 Mero Street, W2-09-05
Frankfort KY 40622
(502) 564-5301 Ext. 4071
E-mail: Tonya Davis for more information.

 

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