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1 INSURANCE IRELAND Understanding the True Impact of Fraud FRAUD Row Left to Right - Sinead Nolan (RSA), Colm Featherstone (AXA), Francis McDonnell (AXA), Andrew Buck (Liberty), Danny Boles (VHI), Joan Dixon (FBD) Back Row Left to Right - Michael Curtin (Insurance Ireland), West Thornton (Insurance Ireland), Audrey Purcell (Aviva), John McGrath (Allianz), David Donegan (AIG), David Snow (Zurich), Dean Dowling (Liberty), Tony Stewart (Travelers), Tom O Brien (Liberty), David Downey (Zurich), Michael Horan (Insurance Ireland), Jim Loughran (IPB), Christine Waters (IPB), Emma Gallagher (Aviva Health) Welcome from the Chairman Chairman s Introduction The Anti-Fraud Forum is a group that focuses on dealing with fraud in the insurance industry. It operates under the auspices of Insurance Ireland and has played a key role in addressing fraud within the insurance industry. The group fosters an industry approach to dealing with fraud though the facilitation of meetings, networking and fraud training events. The group includes special investigations unit (SIU) staff from all the major non-life and health insurers. Over the last two years, the level of involvement and co-operation between Tom O Brien, Liberty Insurance Chairman, Insurance Ireland Anti-Fraud Forum companies in dealing with fraud has The Anti-Fraud Forum has achieved a number of successes in recent years as follows: Provided a central forum to discuss new and existing fraud issues within the insurance industry. Developed a trusted network and comprehensive contact list of SIU staff at insurers. Expanded the group to include Sales and Underwriting fraud in mid While the group was originally Newsletter March 2015 focused on claims fraud, application fraud including the misrepresentation of policy information and payments fraud is also important as we need a more holistic approach to dealing with insurance fraud. Expanded the group further to include Health Insurers in mid This has brought a new dynamic to the group as it encompasses different areas of fraud within the insurance industry. Organised CPD accredited fraud training events for SIU staff in October, 2012, April 2013 and April These events help develop the knowledge and professionalism of staff that are involved in SIU activities. The events also foster networking and a sense of common purpose for staff that deal with fraud. Building on these successes, the group Ireland Fraud Conference in November, 2013 and again in November, Speakers from Europe, the UK and Ireland shared their expertise and knowledge in the areas of fraud prevention, deterrence and detection. These events help develop thought leadership and best practice in relation to dealing with insurance fraud. The conference in 2013 was very well supported with over 150 attendees and this was surpassed in 2014 with over 200 delegates. We hope to run another conference in the last quarter of In the next twelve months, we hope to increase the level of interaction between the insurance industry and the Gardaí. We would like to look at opportunities to adopt a similar model to that used by the

2 Association of British Insurers (ABI) and the Police in dealing with fraud in the UK. specialist Insurance Fraud Enforcement Department (IFED) within the Police. David Wood, Chief Inspector at IFED was very informative at the recent fraud conference and demonstrated how this initiative is working very well in the UK. Going forward, the Anti-Fraud Forum will continue to be at the forefront in encouraging best practice when dealing with issues related to fraud in the insurance industry. The prevention and detection of fraud is at the top of our agenda as is complying with the Code of Practice on Data Protection for the Insurance Sector. Finally, I would like to thank my colleagues on the Anti-Fraud Forum for all their help and assistance in the past twelve months. I would also like to thank Insurance Ireland for facilitating the group and hosting our meetings and events. The Ryder Cup of Insurance Fraud Training David Snow, Head of Special Investigations Unit Zurich Insurance I was delighted to attend The International Association of Special Investigation Units (IASIU) Europe conference, which was held in Dresden, Germany, from June 16th -18th, There are other insurance fraud events in Europe, but in my view what differentiates IASIU from all others is the friendship and open sharing of knowledge and stories among attendees and speakers. It is important to recognize that IASIU made are used for the development and management of IASIU s other trainings and conferences. The speakers this year once again were of an extremely high caliber. Looking on from the audience, I felt as if I was witnessing an insurance fraud training competition equivalent to professional golf s Ryder Cup. We were treated to excellent speakers from both sides of the Atlantic, which commenced following the introduction by the IASIU European President Oliver Lindsiepe. The first speaker was Joe Wehrle, president and CEO of the National Insurance Crime Bureau (NICB), and he set a very high bar for the following speakers. Wehrle gave an interesting presentation on the NICB s activities in the U.S. while driving home his view that Europe needs to have a central European database for claims, similar to ISO in North America. As we know, it is nearly impossible to compare Europe to the U.S., as individual European countries have many different customs, laws, and languages. However, we should remember that together we stand stronger under the European IASIU banner in the fight against insurance fraud. Criminals will exploit our differences, such as sharing of information, for their gain. We currently are prevented from sharing suspect intelligence on a cross-border basis; however, Wehrle is correct in saying that we have to start the process of changing laws. Nothing is impossible; perhaps we should take inspiration from the words of President Obama: Yes we can! which we in Ireland have translated to our national language, Is Féidir Linn. IASIU Europe can facilitate discussion and open communication between members. We can place the foundation stone for the future success of a true combined and united European effort to combat insurance fraud. The insurance fraudster does not recognize borders. Just like the world of the cybercriminal, country borders do not stop them; in fact, the criminal will use them to their advantage. We need to take a stand for the combined betterment of all Europeans. IASIU President Wade Wickre provided insights into the origin of IASIU back in It is an excellent achievement from the founding members to see 30 years later that IASIU is not just an American association, but now is a global community and world leader in uniting insurance fraud investigators in combating fraud. Dennis Jay, executive director of the Coalition Against Insurance Fraud, also gave an interesting presentation. The European speakers refused to be outdone by the Americans, delivering a fascinating presentation by my friend and colleague Roland Woerner, global head of fraud at Zurich. This was followed by an equally educational presentation by Dr. Jochen Tenbieg, head of global claims for Allianz SE Germany. Ted Doyle, vice president of health care markets for Performant Financial Corporation, travelled from California and provided excellent insights into his company s activities on preventing health care fraud. Katten Muchin Rosenman LLP s Ross O. Silverman also gave an interesting presentation on the fundamental components of a special investigations unit. As an SIU manager, I can see commonalities between a European and U.S. special investigations team. The European speakers continued to rise to the challenge of the U.S. with

3 further presentations from fellow Irishmen Leonard Brimson, regional head EMEA for AIG Global Investigative Services, and Ciaran McGaley, CEO of Risk Intelligence Ireland. This was complemented by Detective Chief Inspector David Wood of the Insurance Fraud Enforcement Department in the UK. Summing up, the education learned, experience gained, and friendships made are a testament to the vision and goal of the founders of IASIU. I look forward to the next IASIU European conference and say, Happy 30th birthday! to the truly International Association of Special Investigation Units. Contrived accident Sinead Nolan, Liability Claims Team Manager RSA Insurance Have you been involved in a Staged Car Accident? The Policy Holder allegedly came from a side road and collided with a Third Party vehicle on the main road in Longford. No Gardaí or emergency services were called to the scene. Personal injury claims were subsequently received from the driver of the 3rd Party vehicle and his three passengers. No claim was received from the insured for his vehicle damage. All claimants were from the UK and they nominated Solicitors in Northern Ireland to deal with their claims. They also attended medicals in Northern Ireland. A request was made to inspect the 3rd party vehicle, however, as it was now in the UK the insurer arranged for a motor engineer to inspect the vehicle there. It was deemed to be a write off due to the damage involved. This raised questions about how did the vehicle come to be in the UK as the air bags had deployed. How did they get the vehicle back to the UK because it was unsafe to drive. The claimants could not produce any evidence of towing or tickets for the ferry back to the UK. In fact, they could not even provide evidence that they actually brought the car to Ireland in the When pressed to produce some evidence, the Solicitor involved informed the insurer that the driver had passed away and he could not obtain the necessary documentation. An investigator was subsequently appointed driver had actually passed away. Further investigation revealed that the four claimants, who allegedly lived together at the same address, did not exist at the address they provided. The Policy Holder also proved elusive. It was discovered that he had misrepresented his information at policy inception and did not inform the insurer about a previous conviction. He also disappeared after the accident and his vehicle could not be inspected. actually occurred. The information uncovered about the Policy Holder and the claimants together with the implausible assertions about the a fraudulent claim. This evidence was put to the Solicitor and he subsequently advised that the claimants would not be pursuing their claims. This was an excellent result and demonstrated that perseverance and good investigation by the SIU team saved the company close to 100K on this claim. Insurance Ireland estimates that fraud costs Insurance Companies in Ireland about 200m a year, so if you have been involved in a recent motor accident there is a possibility that you have been the victim of a staged or fraudulent accident. Most victims involved in staged accidents be opportunists or career criminals. They are looking for someone who is less likely to be confrontational in an accident so may pick a woman driving alone, a young and inexperienced driver or an vehicles as they know that the vehicle will be insured with the driver less likely to ask too many questions as they do not own the vehicle. The vehicle used by the fraudsters will normally be old and will contain a number of passengers who will all pursue injury claims, most likely for whiplash-type injuries. So how do you know if you have been involved in a staged accident? There are different types of staged accidents you should be aware of. 1) The Wave or Flash for Cash

4 happens where the fraudster sees you are trying to switch lanes or pull out from a side road or parking place and waves soon as you do, they crash into you and then claim that you pulled out without seeing them and caused the accident that they were there. You should never signal inviting you to proceed. 2) The T-Bone Accident occurs when a fraudster sees you waiting to proceed through an intersection and then deliberately accelerates and hits your car, claiming that you did not stop at the Stop sign. 3) The Swoop and Stop occurs when two vehicles work together to set you up. One car pulls in front of you and jams on the brakes whilst another car simultaneously pulls up alongside you preventing you from swerving and so you crash into the rear of the car in front. 4) Braking for no apparent reason occurs when the fraudster sees you are distracted and brakes suddenly and unexpectedly, causing you to crash into them. What do you do if you think you are involved in a staged accident? think clearly so it s a good idea to keep an accident checklist in your car. It s very important that you get as much information as possible including the number of occupants in the vehicle. If you have a mobile phone/camera, you should take photos of the damage to all vehicles and send all this information to your Insurance company so they can investigate the matter. How can you avoid being involved in a staged accident? that you never tailgate. You should always leave plenty of space between your vehicle and the vehicle directly in front so that you have enough distance to stop if the vehicle in front brakes suddenly. Also, be careful if someone proceed - they may be setting you up. Finally, avoid being distracted when driving. For example, someone who is on the phone is a perfect victim for these opportunists. At our recent Counter Fraud Conference, Kevin Thompson of Insurance Ireland advised that fraudulent claims in Ireland could be adding as much as 50 extra to every insurance policy. So we all have a part to play to vigilant to avoid fraud and fraudsters. Successful Insurance Confidential Referral John McGrath Head of Claims Relationship Management Allianz Insurance A third party claimant that was injured in a motor accident submitted a personal injury claim that he was suffering from stiffness in his neck and lower back, The Injuries Board made an assessment in the sum of 22,300 which was accepted by the insurer, however the claimant didn t accept the award. The claimant later submitted a claim for dental damage and hearing loss related to the motor accident. Subsequently, a caller to the Insurance claimant had pre-existing problems with his hearing prior to the accident and, most importantly, they named his treating doctor in the clinic that he was attending. The insurer subpoenaed the doctor to that he had treated the claimant for profound work induced (kango hammer) deafness in the 12 months prior to the motor accident. The insurer advised the claimant s legal team that they would submit an application under Section 26 of the Civil Liability and Courts Act, 2004, to dismiss the claim if the court case proceeded. The claim was subsequently withdrawn prior to being called on for hearing in the High Court.

5 Vhi Healthcare recovers 47 million since 2009 Danny Boles Head of Special Investigation Unit Vhi Healthcare Health Claims Vhi Healthcare s dedicated Special Investigations Unit (SIU) is an expert in fraud prevention, writes Danny Boles, Head of SIU at Vhi Healthcare. Our dedicated team has achieved 2009 with recoveries of over 47 million as a result of investigations of incorrect or inappropriate billing, and fraud. In 2014 the SIU recovered and prevented almost 20 million as a result of inappropriate billing. However, it should be noted that the vast majority of claims submitted for payment are genuine and are paid accordingly. A further 23 million has been recovered in respect of third party injury claims. The SIU has evolved over recent years and has become more focused and strategically organised to identify, investigate and recover monies paid out due to fraudulent practices or incorrect or inappropriate invoicing of claims by healthcare providers. The methods used to identify these monies include stringent billing audits, thorough follow up on customer queries and other targeted initiatives. Closer Claims Scrutiny Vhi Healthcare adopts a proactive approach to ensure that submitted claims are robustly scrutinised at every step of the claims process to minimise and prevent inappropriate payments. The ultimate aim is to change behaviours to such an extent that only valid claims instance. While achieving this will be challenging, we have already noticed that the level of inappropriate billing has fallen in subsequent years in areas where we focused attention on recovering monies that were claimed inappropriately. Unlike general insurance claims (e.g. motor insurance), the majority of private medical claims (97%) are paid directly to hospitals and medical practitioners on behalf of customers, which makes the private medical insurance claims process different and distinct in comparison. Risk, Opportunity and Reward The key questions is: how does the SIU operate to protect the interests of Vhi Healthcare and our customers? Vhi Healthcare s SIU targets and goals cover a broad remit but the main objective is to recover and prevent inappropriate payments and this is achieved by focusing on Risk, Opportunity and Reward and maintaining a fraud model to highlight areas with the greatest return. Vhi Healthcare has measures in place to reduce the level of risk to the business. In instances of fraud there must be a deterrent factor to any action that may be taken. For example, rather than just recover the money it is now considered appropriate to also include penalties (fines), interest and investigation to the offender which sends a strong message that there are consequences to fraudulent action and activity. The SIU has the capacity to investigate all types of inappropriate billing cases including fraud, abuse, waste and error (see footnote) and in 2014 alone our SIU reviewed 60,000 claims. Where cases of fraud are detected, they are referred to An Garda Síochána for further investigation and where criminal Healthcare adopts a zero tolerance approach at all times. Use of data analytics to spot trends The SIU works closely with our Data fraudulent claim trends and abnormalities. The use of the data analytical process is a core function to support our SIU in continuing to maximise our recoveries and minimising the risk to the business and further investment in data analytics is planned for Health Anti Fraud Forum Vhi Healthcare is an active participant in the Health Anti-Fraud Forum and by sharing and working together with other health insurers, we can all have an impact on preventing and reducing fraud. Vhi Healthcare recovers 47 million since 2009 Error - Submitting erroneous claims for procedures that may have been cancelled or charges that were incorrect Fraud - Obtaining or attempting to obtain healthcare services or payments by dishonest means, with knowledge, willingness or intent

6 Insurance Ireland Fraud conference 13-Nov-2014 Tom O Brien Liberty Insurance Chairman, Insurance Ireland Anti-Fraud Forum The annual Insurance Ireland Fraud conference took place in the Conference Suite at the Aviva Stadium on 13th November, The setting for the conference was excellent and this was borne out by the attendance of over 200 participants at the event. The event was opened by Kevin Thompson, CEO of Insurance Ireland, who welcomed the speakers and participants. He outlined the background to the event and the importance of fraud awareness within the industry. He highlighted the size of the attendance as an indicator of the interest in this area. Kevin spoke about the cost of fraud which can add up to 50 to the price of an insurance policy. He also spoke about the importance of other stakeholders in dealing with fraud and the need to build awareness in the media about fraud. The event was hosted by Tom O Brien, Chairman of the Anti-Fraud Forum who introduced the speakers and facilitated a Q&A session afterwards. Tom will summarise the presentations and distil some of the learning points from the speakers in the following sections. David Wood focused on the close working relationship between the Association of British Insurers (ABI) and the UK Police on insurance fraud. within the Police that focuses on insurance fraud. This group is called the Insurance Fraud Enforcement Department and operates under the economic crime section of the City of London Police. IFED was set up to provide more focus Insurance Industry Support for Specialist Police Group in the UK David Wood Chief Inspector, City of London Police Insurance Fraud Enforcement Department (IFED), on insurance fraud and to change the public perception that fraud is a victimless crime that has little criminal consequences. While the IFED group is supported financially by the ABI, it maintains strict operational independence as it s important that the Police are seen to be impartial when it comes to dealing with cases that are referred to them. The ABI provided 3m in financial years of its existence. This agreement with the Police was extended for another three years from January, 2015 with a small increase in the level of funding provided by the ABI. 10 support staff. To date, it has made 549 arrests, achieved 109 convictions with the Courts imposing custodial sentences totalling 542 months on individuals. It has also carried out 317 interviews and issued 163 cautions to people. Insurance companies refer cases to IFED and they take in about new cases per year (60% acceptance rate) for further investigation. In addition to their primary role in Policing, IFED also plays an important role with the media in promoting the message that there are consequences

7 to committing insurance fraud. IFED actively highlights its counter fraud activities through the media. They also worked with the BBC to create a series of forty (half hour) programs that focused on various aspects of their work in the last three years. These TV programs are entitled Claimed and Shamed as they highlight the consequences for people who have made fraudulent insurance claims. David Wood s presentation will help open a discussion on the possibility of developing a similar arrangement in Ireland between the Gardaí and the Insurance Industry under the auspices of Insurance Ireland. This will require a support this initiative and a willingness by the Gardaí to consider setting up such a group. The overall objective in doing so is to help us to better co-ordinate the Perspectives on Employer & Public Liability Claims and Commercial Underwriting Due Diligence Wayne Kennedy, Commercial Claims Manager Liberty Insurance Wayne Kennedy focused on commercial claims fraud and the importance of doing appropriate due diligence when writing commercial insurance policies. Wayne spoke about the importance of good underwriting practices that will help minimise insurance risk and the prevalence of fraud. This includes doing checks, property surveys and searching other information sources, when assessing risk exposure. He also pointed to surveys as a good way to assess management practice in the areas of record keeping, cleaning schedules, health and safety awareness, use of video recording and staff awareness of fraud risks. In relation to claims, Wayne focused on employer and public liability (EL/ PL) claims in particular. There are a wide variety of claims that fall into these categories, including:- Slips, trips and falls Assaults on staff or by staff on members of the public Defamation Defective products Property damage Workplace injuries Disease claims, repetitive stress injuries, industrial deafness, etc. Some of these claims can be very also depend on good record keeping by policy holders, so it s important to encourage good management practice by policy holders when we write the business. Staff training is also critical to minimising certain types of claims such as defamation claims, as staff should be very careful in how they behave towards members of the public. Wayne pointed to the importance of doing proper investigations at the outset of a claim. We need to gather all relevant information in a timely manner and try to establish indemnity and liability as soon as possible. Early decisions can help reduce costs and will help to get the claimant onside if the claim is genuine. Delays can lead to loss of critical information, the unavailability of witnesses and the loss of video evidence. Delays may also lead to a greater risk of litigation if the insurer drags its heals. Wayne summarised the key steps in dealing with these types of claims as follows: Firstly, ensure that you gather all the relevant information, witness statements, pictures, CCTV and any other information that may be available; Secondly, analyse the information in a critical manner to ensure understanding of the circumstances of the claim and any issues that may arise; Thirdly, draw your conclusions as quickly as possible so that decisions can be made in a timely manner about the claim. Once you have executed these steps, you can then move on to deal with the claim and settle or defend it, as appropriate.

8 Health Insurance, Service Provider Investigations Paul Francis Provider Investigations Manager AXA PPP Healthcare (UK) Paul Francis focused on fraud related to service providers in the health insurance industry. He highlighted exaggeration and misrepresentation as two key issues in the health insurance industry. Paul highlighted the main sources of fraud as being clients (policy holders), service providers and the sales channel. In his view, the biggest opportunity for fraud relates to service providers such as medical specialists and health care providers. Health care specialists and service providers may unbundle procedures to attract higher fees, up code treatments to bill for more expensive procedures, present duplicate billings, include phantom treatments and recommend unnecessary specialist reports when treating patients. In order to counter these issues, Paul recommends doing tight reviews of all claims, ensuring proper triage of claims to identify exaggeration & fraud and observing tight controls on coding for treatments by service providers. He also pointed out that insurers should carry out appropriate checks and due diligence on all service providers before making payments. This should include checking their registration and practitioners may have been struck off the register. Paul Gillen s presentation was very impactful as it highlighted the many ways that our lives can be compromised by malevolent individuals that are intent on collecting and misusing our personal data. Paul is based at Europol which is a co-ordinating agency for Police forces across Europe. Europol focuses on the following areas:- Crimes committed against organisations Crimes that cause serious harm to individuals Cybercrime attacks on business systems and critical infrastructure Impact of Cyber Crime on Business Paul Gillen Head of Operations European Cybercrime Centre, Europol years. He highlighted the increasing inter-connectedness of the world we live in and the development of the internet of things where there will be more things than people connected to the internet. While there may be big advantages for companies and individuals to have individual pieces of equipment, such as fridges and cookers, connected to the internet, the security of those connections will cause issues as people will be more open than ever to cybercrime attacks. The recent cyber attack on Sony s infrastructure and the fears about further attacks, illustrates the vulnerability of organisations and individuals to cybercrime. to operate within national borders with assistance from cross border organisations such as Europol. Criminals, however, are not impeded by national borders. Crimes committed via the prosecute due to the broad territorial reach of the actors involved. This is the dark (TOR) internet where criminals can operate with virtual impunity by hiding behind multiple levels of hardware and encryption. For insurance companies, cybercrime presents multiple challenges as they have to protect their own systems and data, while they are also exposed to risk and losses at client companies if their clients experience cyber attacks. Insurance claims for cyber attacks are relatively low at the moment, but judging from Paul s presentation, this is an area that insurers need to understand better in order to manage the risks involved. Paul s team deals with Cybercrime which has grown exponentially in the last few Paul highlighted the borderless internet as a big issue as police forces have

9 Accenture Insurance Fraud Consumer Sentiment Research Gearóid Madden Senior Manager, Accenture Analytics from recent research by Accenture on sentiments and attitudes to insurance fraud in Ireland. very useful in identifying Irish attitudes to insurance fraud. The survey was based on interviews of 1,000 people that were selected by a market research company to represent a cross section of Irish people. The survey asked a wide variety of questions that were designed to assess sentiments and behaviours towards insurance fraud. Gearóid presented a summary of the results and also provided an infographic that was distributed to participants at the conference. The results provided some interesting learning points, such as only 1 in 4 Irish people would report insurance fraud, despite the vast majority deeming it unacceptable. The survey also found that there is a catch me if you can attitude to committing insurance fraud which illustrates the perceived low risk nature of getting caught. the majority of people feel that it is the responsibility of insurers to combat fraud and they believe that insurers should share more information to be effective in combating fraud. Gearóid also presented a short video that involved interviews with people working in SIU. These interviews focused on questions highlighted in the survey and offered the opportunity for industry participants to respond to the issues raised. Please see link below to view the Accenture presentation, video, and Infographic. insight-accenture-ireland-researchinsurance-fraud-consumer-sentimentsurvey-2014.aspx Thank-you to Gearóid and the team at Accenture for developing the survey and compiling the results which offer many useful insights about attitudes to insurance fraud in Ireland.

10 Insurance Ireland Newsletter Q&A session and closing Kevin Thompson CEO Insurance Ireland Following the presentations, there was a brief Q&A with the speakers and then the conference was closed by Kevin Thompson, who summarised the key themes and learning points. Kevin also thanked the speakers for sharing their knowledge with everyone and he thanked the participants for their enthusiastic support for the event. Sponsors / Exhibitors Cunningham & Lindsey Risk Intelligence Pictured are: Simon Powell and Michael O Donoghue, Cunningham & Lindsey Pictured are: Ruth McParland and Niall Kavanagh, Risk Intelligence Vision Net Business Forensics Pictured are: Caroline Curran and Jesse du Toit, Vision Net Pictured are: Tame Riedijk and Frank Kurstjens, Business Forensics

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