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Business insuranceThis post is actually a long time in coming since Individual Disability Income Replacement and BOE policies often contain very complicated issues. Both types of policies can  become insureds’ worst nightmare if caution isn’t taken well in advance of a disability claim to match business expenses, tax reporting and Profit and Loss Statements. Most DI and BOE insurers learned a long time ago how disorganized self-employment professionals are and take full advantage of that fact to delay payments of claims for long periods of time – often 6-8 months beyond dates of application.

Individual Disability Income policies are non-ERISA and are underwritten separately by an insurer who assumes the risk of “replacing” lost income of business professionals with proven disability. Therefore, DI policies are intended to “replace lost income” if the owner, professional or key person is unable to work due to a claimed disability. Calculations of residual disability are contained within the policy and can be generally defined as “proportionate loss formulas” replacing lost income. DI policies are either payable to age 65 or Lifetime.

Business Overhead Expense policies are designed to pay fixed and variable costs of maintaining a business for a limited period of time when the owner or key person is unable to work. These policies allow physicians, dentists, executives and other self-employed professionals the time to “figure out” what to do with their businesses when disability makes it impossible to return to work. BOE policies are limited in the amount of award and also the time period benefits are to be paid. Items to be reimbursed are listed directly in the policy and sources not listed are not reimbursed.

Most professionals who buy DI and BOE insurance consider the coverage essential to the continuation of a going-concern without realizing what will be required in terms of paperwork if a claim is ever filed. Most insurers will request the following information when DI and BOE applications are made.

  • Copies of both personal and business tax returns for as much as 5 years, sometimes longer.
  • CPT or CDT billing codes broken down by MONTH. (Most software can do sorts of billings by month. This will become a huge issue if the doctor or dentist’s software cannot sort billing code information.)
  • Business Profit and Loss Statements by MONTH for at least the 12 months preceding disability and going into the future.
  • Lists of cases by MONTH for attorneys with client information redacted.
  • Detailed Job Description not only listing material and substantial duties but percentage of time spent in an 8-hour day on each duty.
  • Pension and 401(k) contributions received or contributed on your behalf.
  • Lists of employees and job descriptions.

Insurers marketing DI policies employ CPA firms to review and audit financial information on the level of an IRS audit. It is expected by these financial wizards that Profit and Loss expenses true-up to what is reported on tax returns. I always found this to be odd since there are valid reasons by P&Ls would not match taxable income such as depreciation expense. However, Unum’s newest tell is to demand reconciliation of taxable income with P&L expenses. Unless the numbers line up perfectly, no benefits under either type of policy will get paid.

Claims can go on for months while professional insureds attempt to provide information demanded by insurers. Even the issue of CPT billing codes can be problematic if procedures are billed by company and not by physician (as in physician medical groups.) To make matters worse, claims handlers begin to request the same information over and over again when it’s not received in the format it asks for. Insurers are really big on comparing “apples to apples.” Since benefits are paid MONTHLY, insurers insist all information must be provided “in monthly format.” This also becomes a problem when businesses do not have their CPAs publish monthly P&Ls.

The latest fiasco was a Principal BOE claim where benefits were not paid for such a long time, its owner had to sell the business. This scenario should never happen because it violates the real intent of BOE insurance which is to keep the business afloat for a period of time so that the owner can decide whether to return to work or let the business go.

Finally, business professionals who are residually employed won’t get paid until MONTHLY P&Ls and/or pay stubs are provided to the insurance company. If the numbers aren’t right…..no benefit.

DI and BOE policy holders should be aware that filing disability claims under these types of policies is no piece of cake. The administrative paperwork can become a nightmare. DCS recommends that changes in financial accounting and company procedures such as preparation of MONTHLY financial statements should be made long before it’s necessary to file a disability claim. DI and BOE policies carry tremendous accountability to provide proof of financial condition.

DI insurers rarely challenge proof of medical disability, but rather concentrate efforts on challenging the amount, format and quality of financial information submitted. If everything doesn’t “true-up” claims can be paid on Reservation of Rights that also carries some risk to insureds. In my experience it can take insurers up to 8 months before paying any benefit under the policy if the requested information is not provided in the format requested.

Insurers have a great deal of money at risk for DI and BOE policies, and as a result their “risk management” rises to levels of high risk and probable millions in benefit payments. It may be a pain to reorganize financial reporting internally, but it will pay off later if and when it becomes necessary to file a disability claim.

RetirementDisability Claims Solutions receives many questions during the year concerning various sources of Retirement Income and whether the additional income is an offset to private disability benefits. There are many different types of employer, union and/or state retirement programs employees are allowed to participate in. Therefore, by no means should this post be considered an all-inclusive discussion of employee retirement plans. Instead, consider the overall information as a guideline that may or may not pertain to your particular disability policy and LTD claim.

In order to explain most policy provisions I pulled one of Unum’s group LTD Plans and will be using its wording as an example. Claimants are highly recommended to find their own policies and read the specific retirement provisions relevant to them.

Unum describes retirement deductions as:

“The amount that you: 1) receive as disability payments under your Employer’s Retirement Plan; 2) Voluntarily elect to receive as retirement payments under your Employer’s retirement plan; 3)  and are eligible to receive as retirement payments when you reach the later of age 62 or normal retirement age, as defined in your Employer’s retirement plan.

Disability payments under a retirement plan will be those benefits which are paid due to disability and do not reduce the retirement benefit which would have been paid if the disability had not occurred.

Retirement payments will be those benefits which are based on your Employer’s contribution to the retirement plan. Disability benefits which reduce the retirement benefit under the plan will also be considered as a retirement benefit.”

The above provision is one of the most difficult and misinterpreted provisions of group LTD policies. For the most part, claims handlers and their managers often do not have a clear understanding of what these provisions mean and how they should be adjudicated.

First of all, in general terms, some retirement plans pay “disability benefits” in addition to regular retirement payments, if the employee is determined to be disabled. Many other plans do not provide for LTD at all, but describe in their literature payments for “retirement disability” if employees are unable to return to work long-term.

Finally, the part of the above provision that is usually an issue is the statement, “Retirement payments will be those benefits which are based on your Employer’s contribution to the retirement plan.” Employees should be well-informed concerning the type of retirement plan they have, i.e. defined contribution, or defined benefit, 401(k) etc. See below.

A defined contribution plan specifies how much money will go into a retirement plan today. The amount typically is either a percentage of an employee’s salary or a specific dollar amount. Then, those funds often are invested in portfolio securities available inside the retirement investment plan. The amount you have at retirement depends on how much your employer contributes to the plan, how much you as the employee save in the plan, how long you leave those funds invested, and how well your investments perform inside the plan. The plan defines periodic contributions that go into the plan; how much employees receive at retirement depends on the earnings and profitable investments made over time.

Many employers are replacing defined benefit plans with defined contribution plans, primarily due to the expense and long-term obligations associated with running a defined benefit plan.

A defined benefit plan identifies the specific benefit your employer will pay to once you reach retirement age. Basic retirement benefits are usually based on a formula that takes into account factors like the number of years a participant works for the employer (years of service) and the participant’s salary. Your retirement benefit is generally provided in the form of regular payments over your lifetime beginning at what the plan calls “normal retirement age,” which is typically age 65. This stream of periodic payments is generally known as a pension or sometimes called an annuity.

Offset provisions (including the above) concerning retirement always refer to both employer and employee contributions to the plan meaning employer retirement plans defined as “defined contribution plans” are considered offsets from LTD, but “defined benefit plans” are not. Although claims handlers should obtain copies of actual retirement plans to determine whether it is a defined contribution or defined benefit plan, in most instances they are not trained to know the importance of the information, or for that matter the difference between the two.

Nevertheless, it is up to employees and eventual LTD claimants to know the difference between the two plans and how benefits from LTD may be affected. It’s my guess, most employees with employer retirement plans do not have copies of those plans and have never read them.

To simplify, employer “defined contribution retirement plans” are considered offsets from LTD benefits; “defined benefit retirement plans are not.” 401(k) plans are not considered offsets from LTD mainly because contributions to 401(k) plans are made with pre-tax dollars. The problem is that by far, the majority of claims specialists and managers have absolutely no idea how group LTD retirement benefits should be regarded and will put up a fight about removing inappropriate retirement offsets.

Again, I need to caution insureds from presuming any facts related to their retirement distributions without having copies of both retirement plans and LTD policies in hand. But, this post does introduce the fact that not all retirement plans are offsets from LTD benefit plans and that it is up to claimants to prove their case for unreduced LTD.

Incidentally, Unum’s policy also states the following: “Amounts received do not include amounts rolled over or transferred to any eligible retirement plan. Unum will use the definition of eligible retirement plan as defined in Section 402 of the Internal Revenue Code including any future amendments which affect the definition.” Lump-sum distributions rolled over to qualified retirement plans within 60-days are generally not classified as offsets although not all LTD policies have this provision.

Friday Q&A

Q&AWhy does it take Unum so long to make a decision on my claim?

Unum Group is perhaps the most procrastinating disability insurer because of its internal procedures designed to “stack the deck” against insureds and not pay claims. There are eligibility Team Meetings, medical walk-in and physician reviews, vocational and financial reviews, possible surveillance, additional roundtables etc. One might say Unum does everything it possibly can to collect documentation as proof the claim should not be paid. A good indication of an unfair insurer is how much time and money it puts into NOT paying claims rather than paying them.

In theory, ERISA group LTD decisions should be made within 30-45 days, but then who’s enforcing that rule? A subsequent judge can rule arbitrary and capricious due to many ERISA deadline violations, but in the meantime there isn’t any entity enforcing 45-day decisions. Insurers can extend for another 45 days for a total of 90. Last year, Unum was actually asking claimants to sign-off, or give permission for violated ERISA deadlines.

Perhaps the worst delay abuse I’ve observed is in Unum’s review of Individual Disability Income policies where decisions are delayed for nearly 6-8 months. Claims are placed on extended Reservation of Rights, a pay status allowing Unum to show partial profits on claims by understating its financial reserves. Unum then refers claims to its CPAs who put the application through an intensive financial review similar to IRS audits. The company actually seeks to find more and more financial reasons NOT to pay claims by demanding receipts to reconcile with tax returns.

There are always reasons by Unum can’t pay DI claims in a timely fashion. Attorney insureds are asked to provide lists of cases, which of course are protected by attorney/client privilege. Physicians and dentists must submit CPT/CDT billing codes by month on an excel spreadsheet; P&L statements by month; and detailed tax returns going back nearly 5 years.  Financial analysts are asked to produce client lists, also considered private and confidential. There does not appear to be an end to Unum’s demands for more and more paperwork as the company attempts to find reasons not to pay claims.

Self-employed professionals are really given a hard time by Unum if paperwork isn’t well prepared. Expectations of receiving any money at all from Unum in a timely fashion go out the door as claims handlers not only seek new information at every juncture, but ask for the same information over and over again.

Unum’s entire internal review process is designed to produce file documents in support of NOT paying claims. That’s why the company takes so long to actually pay.

How long does an insurance company have to give you a copy of the IME report?

Actually, disability insurers do not have to give you, or your doctor, a copy of the IME report at all while the claim is paid. ERISA requires full disclosure after claims are terminated, but while claims are paid, there is no law or requirement forcing insurers to provide copies of IME reports. My experience though is that most insurers are very cooperative in providing IME reports to treating physicians because they want doctors to “buy-in” to the opinions of the IMEs. Most insureds can obtain copies of IME reports through their physicians.

Technically for DI claimants, insurers aren’t required to provide copies of claim files after denial, and “claim appeals” really do not exist. One of the best things about ERISA is that statutes give claimants rights to full disclosure, but not so for DI insureds. Berkshire/Guardian, for example, refuses to provide copies of claim files, and admits there are no appeal rights to DI claim denials. The company’s letters inform insureds that if they have additional information it will be considered, but forget appeal rights – for Berkshire/Guardian there are none.

Ohio National is another company refusing DI insureds any rights of appeal. Once claims are denied, it’s either sue, or go away. It is unfortunate that so many insureds and claimants still think they have so many rights when in reality they do not.

What is the practice of “doctor shopping?”

“Doctor shopping” is the practice of seeking multiple medical opinions from different or selective physicians in order to obtain medical opinions either in support of disability, or in support of claim denials. Doctor shopping can be engaged in by both insureds and insurance companies.

Some insureds find it necessary to continuously search out physicians who agree with them as to what they think the nature of their disability really is. Insureds and claimants are so absolutely convinced they are ill they seek medical consultation from multiple physicians until they finally find one that agrees with them. As a consultant I find this in cases where insureds find information on the Internet or on WebMD and come to believe they have, let’s say Lyme Disease even when Western Blot and CD-57 tests are negative. Convincing physicians you have what you say you have is hard work, and it takes quite a few consultations before finding a physician who will agree.

Insureds who “doctor shop” do not allow physicians to make their own diagnosis, but instead insist that they be treated for what they “think they have.”  Doctors who refuse to accept patients’ self-diagnoses are viewed as uncooperative and insureds move on to the next physician and the process starts over again. Doctor shopping is immediately identified by disability insurers and eventually claims are denied for lack of supporting treating physicians.

Insurance companies such as Unum and Prudential also engage in “doctor shopping” as part of their internal medical review process. Unum’s hierarchy of medical review is “doctor shopping” to obtain additional internal opinions in support of claim denials. Insurers who keep going back to IME physicians with addendum questions is a form of “doctor shopping” as is requiring multiple IMEs if reports keep coming back in favor of insureds.

Both insurers and insureds can engage in “doctor shopping” for their own self-interest. In either case, the practice, although common, is inappropriate and unacceptable.

SSDI benefitsCurrent file evidence and correspondence suggests Unum Group is using requests for SSDI files to identify Mental and Nervous claims so that the company can abuse contract provisions limiting benefits to 24 months. Multiple posts have been made on Lindanee’s Blog exposing Unum’s real motives and intent in demanding insureds release SSDI files, but M&N denials are on the rise citing SSDI awards based on mental issues as the cause.

To be clear, it is quite common for insureds and claimants to file private disability claims due to a physical disability, and be awarded SSDI for mental illness. In those SSDI cases where identification with specific SSA listings is impossible, it is likely SSDI could be awarded based on a likely alternative diagnosis in the DSM-V.

Although individuals allow SSA to award SSDI on the basis of mental illness just to get approved, it isn’t a good thing when claimants also have private disability claims. Companies such as Unum Group have closed in on the opportunity to also classify causes of disability as mental and nervous even when claimants do not file claims for that reason.

In the past, Unum was/is quick to say, “Social Security is very different from our policy contract definitions and therefore we must adjudicate our own policy.” For years, Unum Life Insurance and UnumProvident explained away claim terminations in conflict with SSDI decisions as the company’s “responsibility to stockholders to adjudicate their own policy provisions and not using SSDI as a reason to pay claims.” Once again, Unum appears to be talking out of both sides of its mouth especially since claimants and insureds would have no way of identifying the hypocrisy.

When DCS calls Unum’s requests for SSDI files a scam it refers to the company’s untruthful statements, such as “we want to give your claim every possible benefit” as untruthful and misrepresented. Unum doesn’t give claims “every possible consideration”, but rather actively works to “risk manage” and deny as many claims as possible. In most instances after arguing with claimants to “give up” SSDI files, Unum disagrees with SSDI award decisions and denies claims anyway regardless of whether SSA pays benefits or not. You have to ask yourself what the point was of obtaining SSDI files just to disagree with its decisions.

More accurately said, SSA’s requirement contained within it’s 5-step review process requires meeting criteria of a particular medical “listing”. Mental and Nervous disorders can be approved for SSDI benefits even though a physical disability exists that may qualify for private disability, but not meet a specific SSA listing.

But Unum is actively “hunting and pecking” for mere mentions of mental disorder in SSDI files so that the company can misrepresent any physical disability as mental in origin. Unum’s denial letters limiting benefits to 24-months state “…we reviewed your SSDI file and discovered SSA’s conclusions concerning your bipolar disorder is no different from ours.” (This claimant actually filed a Unum claim for ovarian cancer.)

Claimants should always obtain copies of their own SSDI files to determine if there are mentions of mental and nervous disorders, particularly when decisions are made by Administrative Law Judges. Attorney representatives for SSDI need to be made aware that there is also a claim for private disability that could be impacted by a favorable decision for mental illness. Unum’s obsession with obtaining SSA-831s as part of the SSI file further indicates the company is after listing codes and other identifiers used by SSA to classify specific causes of disability on which approval decisions are based.

To be clear, Unum is demanding copies of SSDI files in order to reduce its financial liability by denying more claims using SSDI decisions as back-up. Claimants should consider very carefully whether releasing SSDI files (which is not a specific requirement in LTD policies) is a good idea. The issue itself is yet another estoppel nightmare that should be challenged in court by clever attorneys, wherever they are these days.

SSDI files released to Unum can come back to bite you. Remember, this company doesn’t do anything unless it’s to pad its own pockets, not yours.

DCS Sticky Note

Post it noteFor those who may have been wondering, the “Group” identified in the name “Unum Group” refers to the company’s subsidiaries listed below. Those of you who are Unum insureds may recall that all mail is sent to Unum’s communication center in Columbia SC which is the same location as Colonial Life and Accident Company. Paul Revere and the Provident Companies were acquired by Unum Life Insurance Company of America in June 1999, and the company was renamed UnumProvident.

Tim Arnold, the former VP of claims for UnumProvident is now Senior Vice President of Sales and Marketing for Colonial Life and Accident Company. Ann Houser another VP from UnumProvident is President of US Human Resource Operations for Unum and Colonial Life. You can easily see the close connection between Unum Group, and Colonial Life and Accident Insurance Company.

The bad news is, of course, that one claims process permeates through all companies including for insureds who hold products purchased from Colonial Life.  Buying Colonial Life insurance products won’t save you from Unum’s unfair claims practices.

Colonial Life and Accident Insurance Company
The Paul Revere Life Insurance Company
Provident Life and Accident Insurance Company
Provident Life and Casualty Insurance Company
First Unum Life Insurance Company
Unum Life Insurance Company of America
Unum Limited (UK and Europe)

Unum isn’t just one company, but a collection of operating subsidiaries. In the past Unum Life Insurance Company of America also owned Duncanson & Holt, Unum America, Unum Enterprise, and for a brief time Unum Japan. These companies went by the wayside after the 1999 merger, but Unum still owns the seven subsidiaries listed above.

DSM VClearly, disability insurers have bought into the controversy of renaming the DSM-IV “Somatoform Disorder” (300.81) to “Somatic Symptom Disorder” or SSD. Under the old DSM-IV Somatoform Disorder was defined as “a preoccupation with physical symptoms that suggest general medical conditions not fully explained by medical science.” (The word “somatoform” generally refers to imagined or “all in one’s head.)

However, in the new DSM-V SSD is defined as:

  1. Disproportionate thoughts about the seriousness of symptoms lasting at least 6 months;
  2. A high level of anxiety about symptoms and health;
  3. Devoting excessive time and energy to their symptoms or health concerns.

However, under the DSM-V criteria 1 in 6 cancer and CAD patients meet the definition of Somatic Symptom Disorder and has psychiatrists wondering if we really want to burden and stigmatize seriously ill people with an added diagnosis of mental illness.

“That’s OK with us”, claims the insurance industry that has its eyes on unimaginable profits from denying claims after 24 months. The DSM-V simply defines SSD as “excessive preoccupation with thoughts about bodily symptoms and functions in combination with high levels of anxiety about health.” Who doesn’t worry about their health these days?  Are we all mentally ill?

The new criteria of the DSM-V comes after nearly a decade of cultural, governmental, media and social awareness of “better health for America.” Populations today are much better informed about “living healthier and longer”; perhaps more attention is paid today on “wellness” than at any time in our history.  Worry and concern about “eating right” and “getting up on that treadmill” has become an American obsession but has not ever been defined as a “mental disorder.”

Will there ever be a “normal concern” over one’s health allowed without being classified as “somatic” or “it’s all in  your head?” As with many other things, once the line is crossed with hypocrisy, it’s hard to take it back.

Impairments redefined by the DSM-V as Somatic Symptom Disease include CFS, FMS, IBS, chronic Lyme disease (late stage), Interstitial Cystitis, Gulf War Syndrome or PTSD, and Chemical Sensitivity. These medical illnesses will become misdiagnosed as mental disorders because of the criteria listed in the DSM-V.

In other words, if you have cancer, diabetes, heart disease or kidney failure and your worries and concerns about your illness are (in a psychiatrist’s opinion) chronic and excessive, then you will be diagnosed with a mental illness. For private disability, the DSM-V opens the door to even more abuse of the Mental and Nervous 24-month limitation in LTD policies.

After all, according to the insurance industry, it is a widely accepted fact that some people do indeed worry to a considerable degree about illnesses they believe they have, even though repeated examinations by physicians produce no evidence of illness. Individuals are in effect worrying about non-existent conditions. For nearly 10 years the American Psychological Association has label these people as mentally ill, why not redefine “imaginary illness” for what it is?

Redefine indeed since the DSM-V goes so far as to include parents and other family members into its diagnostic criteria. Parents with terminally ill children who obsessively worry about losing their children can now be classified as mentally ill.

As a 20-year veteran consultant it is my opinion that recent changes in the DSM-V should come as no great surprise. Disability insurance lobbyists and renowned research physicians in America and the UK have long been searching for ways to eliminate CFS and FMS from permanent causes of disability. Unable to convince the CDC to officially defined CFS as a mental disorder, changes in the DSM-V are more underhanded and less visible to those who apply for disability insurance.

It is also clear disability insurers can now classify nearly any diagnosis as mental illness if patient notes and other medical records show evidences of “excessive thought” or worry about symptoms that cannot be proven to exist by medical examination or science.” The implication here is that if upon examination, physician’s can’t find anything wrong with you, you’re not sick; if you keep worrying about it, you’re mentally ill.

The ultimate consequences to those who file private disability claims could be astounding because of the increased numbers of disability claims that potentially could be denied, or limited to 24-months of paid benefits. The logic contained within the new Somatic Symptom Disorder diagnostic criteria is missing. How does a heart transplant or cancer insured NOT excessively worry about his/her health?

Clearly, disability insurers will have a financial vested interest in taking advantage of the DSM-V and its redefinition of what constitutes a “somatic disorder.”

ShreddingReliable sources informed DCS this week there is a distinct possibility that The Standard is sanitizing claim files and shredding claim file information prior to releasing copies of files outside the company. Sources currently in litigation against The Standard told DCS that “they had evidences of shredding going on at the company.” This is a very serious breach of ERISA disclosure statutes as well as deceptive claims practices intended to shield not only The Standard’s internal claims process but prevent attorneys in litigation from using file documents against the company.

A copy of The Standard’s Claims Manual used to train employee’s “reads like an SS guidebook” sources said.  While The Standard has never been recognized as either a good or bad insurance company, evidences of shredding isn’t a good thing.

In 2004 Unum was also accused of sanitizing claim documents and shredding memos and other reports after the NBC Dateline and 60 Minutes TV exposes. Although I can’t honestly say I witnessed the shredding of actual documents, I was told by my administrative assistant that he saw managers shredding documents. This one piece of information told to me by someone I trusted caused me a great deal of grief when I protected him from identification during a deposition. Many attorneys after my testimony felt compelled to pooh-pooh later statements I gave because I wouldn’t give him up.

Tom Benvie, an elderly administrative assistant died not too long ago, but he did communicate to me evidences of managerial shredding at that time. On the other hand, “sanitizing” claim files was a common occurrence at Unum and was actually part of my training as a Unum Disability Benefit Specialist. At the time, I was taught by Unum to remove certain documents such as internal blue memos, primary direction descriptions, internal reviews, and any other derogatory information contained within claim files even when subpoenas were received.

UnumProvident took quite a slap from regulators for sanitizing claim files which is why I’m surprised other insurers like The Standard continue the practice. Perhaps the company was/is arrogant enough to think it would never get caught. Whatever the reason, shredding key documents and sanitizing files (removing documents) is bad faith, if not illegal. If claim files are reviewed by The Standard in good faith in a fair and equitable manner why is the company shredding documents? Good question.

Internally, disability insurers often conduct reviews wherein discussions and documentation of those discussions takes place. In order to move files through the process and allow subsequent reviewers the benefit of prior reviews and team meetings, documentation is maintained whether the claim file is in paper or electronic format. My suspicion is that surveillance documentation might be over the line of legality at times and is removed from files as well.

Untrained claims handlers can also document claim files with inappropriate comments such as “this claimant is crazy”, or “claimant is weird, I’m going to deny the claim.” There used to be a saying at Unum, “If it isn’t in the claim file, it didn’t happen.” If negative information wound up in the claim file by mistake, UnumProvident’s claims handlers could take care of that soon enough by removing and destroying the information.

This new tip about The Standard should remind all of us that insurers may not have learned from Unum’s mistakes and continue to engage in claims practices that harm insureds by preventing full disclosure of internal reviews and standards.

If the information communicated to DCS is accurate, The Standard may not be the only insurer removing documents and shredding them.

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