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James L. Moody J. Harold Chandler Thomas R. Watjen

Burton E. Sorensen Elaine D. Rosen F. Dean Copeland


The Company has established procedures to handle complaints received from insureds, insurance departments and other entities. How a complaint is handled depends on the type of complaint received.

During the exam period, complaints received on individual policies were routed to the Compliance & Legislative Information Center (CLICK). CLICK has responsibility for coordination of complaint handling but the research, resolution and response is done by the department whose activities are the subject of the complaint.

If a complaint concerns a group policy, the complaint is sent to a special unit in the Group Claims Department. For group policy complaints, the responsibility of researching and responding to complaints rests with the Complaint unit. The complaint is not routed to the unit that paid the claim. The reason for this is that there are six (6) claims offices located throughout the United States. In order to maintain control over the responses, they are handled by a single unit located in the Home Office.

Subsequent Event: Complaint handling procedures have been changed so that all complaints are routed to CLICK where they reviewed, then sent to the responsible department for response.

Per Company records, UNUM received 38 complaints on Individual Disability and Group Long Term Disability policies from Washington policyholders during the examination period. Of these, five (5) complaints were raised to the Appeal level. Four (4) appeals were upheld (denials), and one (1) was overturned (claim was paid).

During the examination, OIC complaint records were reviewed for compliance with WAC 284-30-650 which states that it is an unfair practice for an insurer to fail to respond to any inquiry from the insurance commissioner within 15 business days from receipt of the inquiry. When reviewing complaint records, the examiner used the date the complaint was actually received at UNUM until the actual response date as recorded by UNUM.

There were 28 complaints received by the OIC during the examination period. Of these, one was still open as of the examination date and one was rescinded prior to response from the Company. There were a total of 26 complaints reviewed as part of this examination.

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