Employee Leasing/ PEO Policy Rules and Reporting Requirements. Presented by: Julie Gonzalez and Shani Oulton. Objectives
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1 Employee Leasing/ PEO Policy Rules and Reporting Requirements Presented by: Julie Gonzalez and Shani Oulton Copyright 2015 National Council on on Compensation Insurance, Inc. Inc. All All Rights Reserved. 1 Objectives By the end of this session, you will be familiar with general Professional Employer Organization (PEO) policy structures and their Proof of Coverage and experience rating requirements by state. 2 1
2 Agenda Underwriting Terms and Rules Policy and POC Reporting Requirements Bringing It Together Policy Issuance Policy Changes and Experience Rating Bringing It Together Subsequent Changes Regulatory Focus Industry Resources State-Specific Requirements 3 Underwriting Terms and Rules Copyright 2015 National Council on on Compensation Insurance, Inc. Inc. All All Rights Reserved. 4 2
3 Professional Employer Organization A business entity that enters into agreements with other businesses, whether under a formal contract or otherwise Regardless of the terminology used by the parties to describe the relationship NAIC Definition Under which the PEO assumes or shares employment responsibilities for all or a significant number of work-site employees of the other business Does not include a business entity that recruits and hires its own employees; assigns them on a temporary basis; and customarily attempts to reassign when finishing an assignment 5 Professional Employer Organization 6 3
4 Contractual Agreement 7 Client Company An entity that obtains all or part of its workforce for a fee, pursuant to an agreement, from another entity (PEO arrangement) Also referred to as: Work-Site Employer Lessee 8 4
5 Leased Worker Leased Worker Client Company PEO 9 Direct Workers Leased Worker Client Company PEO Nonleased Workers Administrative Staff 10 5
6 Common Policy Types Multiple Coordinated Policies Multiple PEO Policies Master Policy Client Direct Purchase 11 Multiple Coordinated Policies (MCP) Insurer PEO Separate policy issued for each client company Policy issued to PEO company (umbrella) Billing/notification sent to PEO Each client mod applied Common policy expiration date ABC Client DEF Client XYZ Client 12 6
7 Multiple PEO Policies Separate policy issued for each client company May have naming convention (e.g. LCF = Labor Contractor For) Billing/notification sent to PEO Each client mod applied Insurer PEO LCF ABC Client PEO LCF DEF Client PEO LCF XYZ Client 13 Master Policy Model Insurer PEO ABC Client DEF Client XYZ Client 14 7
8 Client Direct Purchase Model Insurer ABC Client 15 NCCI Underwriting Manuals Basic Manual for Workers Compensation and Employers Liability Insurance Rule 3-D for Voluntary Market State Specific Rule 4-B for Residual Market Forms Manual of Workers Compensation and Employers Liability Insurance Applicable Endorsements 16 8
9 Policy Endorsements There are various endorsements that may be utilized when writing a PEO: Residual market-specific State-specific Policy type-specific (MCP, Multiple PEO Policies, and Master) Leased or nonleased workers (direct workers) 17 Manuals Library on ncci.com 18 9
10 Manuals Library on ncci.com ncci.com 19 ncci.com 20 10
11 ncci.com 21 PEO State-Specific Guide 22 11
12 ncci.com 23 NCCI s Basic Manual Rule 1-D-3-f Employee Leasing, Labor Contractors, and Temporary Labor Services Workers assigned to clients must be classified the same as direct employees of the client performing the same or similar duties If the client has no direct employees performing the same or similar duties, leased employees are classified as if they were direct employees of the client entity 24 12
13 Underwriting Take-Aways NCCI s Basic Manual Rule 3-D or 4-B Standard Policy Issuance (e.g., Rule 1 for classification) NCCI s Forms Manual State Specific National NCCI s Guide to State Specific Requirements Policy Types Forms 25 Policy Types Quiz What PEO arrangement involves multiple policies in the names and FEINs of the clients, common expiration dates, and are coordinated to the PEO by endorsement? 26 13
14 Policy Types Quiz What PEO arrangement consists of a single policy with the PEO as the primary insured, it covers the PEO and all of its clients, and aggregated data is reported? 27 Policy Types Quiz This PEO arrangement involves separate policies for each client, but they are each issued in the name of the PEO with a reference to the client name. They also can have different insurers and expiration dates
15 Policy and POC Reporting Requirements Copyright 2015 National Council on on Compensation Insurance, Inc. Inc. All All Rights Reserved. 29 Policy Reporting Questions Is it a Nonemployee Leasing or Employee Leasing Policy? Who is the First Named Insured, the PEO or Client Company? What types of employees/workers are covered? Leased, Nonleased, Direct? If leased, are there leased workers of multiple client companies being covered? 30 15
16 Employee Leasing Policy Type Code WCPOLS Header Record Code Description 1 Nonemployee Leasing Policy 2 Employee Leasing Policy For Leased Workers of Multiple Client Companies 3 Employee Leasing Policy For Nonleased Workers of Employee Leasing Company 4 Employee Leasing Policy Client Company Policy for Leased Workers of Client Company 5 Employee Leasing Policy For Leased Workers of a Single Client Company 6 Client Company Policy For Nonleased Workers of Client Company 7 Client Company Policy For Leased and Nonleased Workers of Client Company 8 Employee Leasing Policy For Leased Workers of Multiple Client Companies 31 Employee Leasing Policy Type Code 1 Non- Employee Leasing Policy Employers covered under this policy are not part of an employee leasing arrangement 32 16
17 Employee Leasing Policy Type Code 2 Employee Leasing Policy For Leased Workers of Multiple Client Companies PEO is first named insured Leased workers of multiple client companies May include PEO s administrative staff (direct workers) Master Policy 33 Employee Leasing Policy Type Code 3 Employee Leasing Policy For Nonleased Workers of Employee Leasing Company PEO is first named insured PEO s administrative staff (direct workers) only Multiple Coordinated Policies Multiple PEO Policies 34 17
18 Employee Leasing Policy Type Code 4 Employee Leasing Policy Client Company Policy for Leased Workers of Client Company Client company is first named insured Leased workers of single client company Multiple Coordinated Policies 35 Employee Leasing Policy Type Code 5 Employee Leasing Policy For Leased Workers of a Single Client Company PEO is first named insured Leased workers of single client company Multiple PEO Policies May have LCF naming convention 36 18
19 Employee Leasing Policy Type Code 6 Client Company Policy For Nonleased Workers of Client Company Client company is first named insured Client company s nonleased workers (direct workers) Multiple Coordinated Policies Multiple PEO Policies 37 Employee Leasing Policy Type Code 7 Client Company Policy For Leased and Nonleased Workers of Client Company Client company is first named insured Client company s leased and nonleased workers Client Direct Purchase 38 19
20 Employee Leasing Policy Type Code 8 Employee Leasing Policy For Leased Workers of Multiple Client Companies PEO is first named insured Leased workers of multiple client companies Does not include PEO s administrative staff (direct workers) Master Policy 39 PEO or Client Company Code WCPOLS Name Record For Employee Leasing Policy Type Codes 2 8 P Professional Employer Organization Company Name C Client Company Name For Employee Leasing Policy Type Code 1 Leave blank 40 20
21 Name and Address Linking Employer record is created by linking a legal name to its legal address or job location Ensures that each POC state receives POC data for only those employers to be reported to the state Names and addresses that are not linked or are linked improperly will generate a Data Grade 7 error A Data Grade 7 error could result in the data not being sent or being rejected by the state 41 Name Link Identifier WCPOLS Name Record Three-digit code assigned to each employer covered on the policy Primary insured name on the Information Page is always Name Link Identifier 001 For each additional employer, increase the Name Link Identifier by 1 (e.g., 002, 003, 004, etc.) Same Name Link Identifier is assigned to multiple names of the same employer operating at the same address (e.g., d/b/a, t/a, etc.) 42 21
22 Continuation Sequence Number Same Name Link Identifier is assigned to multiple names of the same employer operating at the same address (e.g., d/b/a, t/a, etc.) WCPOLS Name Record Three-digit code assigned to each name of the same employer Considered a record count of each name with the same Name Link Identifier 43 Example Julie PEO Company Inc. d/b/a PEO Resources USA Julie PEO Company Inc Name Link Identifier 001 Continuation Sequence Number 001 PEO Resources USA Name Link Identifier 001 Continuation Sequence Number
23 Name Link Identifier WCPOLS Address Record Three-digit code assigned to address/location that corresponds to the name doing business at that address/location Name Link Identifier on Address Record must match Name Link Identifier on corresponding Name Record Same Name Link Identifier is assigned for all locations associated to the same name For multiple employers (different Name Link Identifier) operating at same address, that address is reported multiple times 45 Name Link Counter Identifier 1,000+ Unique Employers (e.g., Master Policy) Two-byte field located on Name Record and Address Record Report 00 or 01 for first 999 names Increase by 1 for next set of 999 names May be zero-filled (00) or left blank if 999 or fewer names Name Link Counter Identifier on Name Record must match Name Link Counter Identifier on corresponding Address Record 46 23
24 Naming Standardization Name Standardization Names split after: INC, Corp, LLC, LLP, CO, LTD, ASSOC, etc. Acronyms always moved to the end: DBA, AKA, ATA, FKA, TA, etc. LWF (Lease Workers For) LCF (Labor Contractor For) Drops: (And other brackets), Attention:, etc. 47 Naming Convention Multiple PEO Policies Each separate policy is issued in the name and FEIN of the PEO, making reference to the client name Example: ABC PEO, for leased workers to XYZ Client Name Standardization splits single reported Name Record into two same Name Link Identifier, FEIN, PEO/Client Company Code 48 24
25 Name Standardization Example Name: Julie PEO Company Inc. LCF Truckers Are Us Inc. FEIN: PEO/Client Company Code: P Name Link Identifier: 001 Continuation Sequence Number: 001 Julie PEO Company Inc PEO/Client Company Code: P FEIN: Name Link Identifier: 001 Continuation Sequence Number: 001 Truckers Are Us Inc LCF PEO/Client Company Code: P FEIN: Name Link Identifier: 001 Continuation Sequence Number: Policy Endorsement Reporting No specific PEO endorsement records Endorsement numbers are reported on Record Type 7 Endorsement Identification Any proof of coverage information (e.g., employers names and addresses) must be reported on their appropriate records 50 25
26 Multiple Coordinated Policies Client Policy Coverage for Leased Workers Employee Leasing 4 Policy Type Code Name Link Code 001 PEO/Client Company Code Primary FEIN Mailing Address (Address Type 1) Location of Operation (Address Type 2) Client Company Name C Client Company FEIN Client Company Mailing Address Client Company Location if different from mailing address PEO Policy Coverage for PEO s Direct Workers Employee Leasing 3 Policy Type Code Name Link Code 001 PEO Name PEO/Client Company Code Primary FEIN Mailing Address (Address Type 1) P PEO FEIN PEO Mailing Address 51 Multiple PEO Policies PEO Policy Coverage for Leased Workers Employee Leasing Policy Type Code 5 Name Link Code 001 PEO/Client Company Code Primary FEIN Mailing Address (Address Type 1) Name Link Code 002 PEO/Client Company Code Additional FEIN Location of Operation (Address Type 2) PEO Name P PEO FEIN PEO Mailing Address Client Company Name C Client Company FEIN Client Company Job Location 52 26
27 Master Policy PEO Policy Coverage for Leased Workers of Multiple Client Companies Employee Leasing Policy Type Code 2 Name Link Code 001 PEO Name PEO/Client Company Code P Primary FEIN PEO FEIN Mailing Address (Address Type 1) PEO Mailing Address Name Link Code 002 Client Company 1 Name PEO/Client Company Code C Additional FEIN Client Company 1 FEIN Location of Operation (Address Type 2) Client Company 1 Job Location Name Link Code 003 Client Company 2 Name PEO/Client Company Code C Additional FEIN Client Company 2 FEIN Location of Operation (Address Type 2) Client Company 2 Job Location 53 Client Direct Purchase Client Policy Coverage for Leased and Nonleased Workers Employee Leasing Policy Type Code 7 Name Link Code 001 PEO/Client Company Code Primary FEIN Mailing Address (Address Type 1) Location of Operation (Address Type 2) Client Company Name C Client Company FEIN Client Company Mailing Address Client Company Location if different from mailing address 54 27
28 Reporting Manuals Policy and POC Reporting Guidebook Part 7 PEO Policy Overview and Models Rules and Code Requirements PEO State Matrix WCIO Website (WCIO.org) Professional Employer Organization (PEO) Applicable Code Chart by State 55 Manuals Library on ncci.com ncci.com 56 28
29 Manuals Library on ncci.com 57 Policy and POC Reporting Guidebook 58 29
30 Policy and POC Reporting Guidebook 59 WCIO PEO Applicable Code Chart 60 30
31 Select the Answer Questions A single policy for PEO and clients Policy Reporting Rules Employee Leasing Policy Type Code 4 Same Name Link Identifier Endorsement numbers reported Answers MCP Record Type 7 Employee Leasing Policy Type Code 2 Policy and Proof of Coverage Reporting Guidebook Linked name and address 61 Bringing It Together Policy Issuance Copyright 2015 National Council on on Compensation Insurance, Inc. Inc. All All Rights Reserved
32 PEO and Two Client Companies Alpha Professional Leasing, 456 Log Cabin Rd., Springfield, IL, Two Client Companies: Beta Consultants, 14 Main St., Tampico, IL Class Code 8810 Data Benefits, 123 Mutual Dr., Washington, DC Class Code 8832 Renewal Master PEO Policy, effective 10/1/14 63 PEO Data View 64 32
33 PEO Data View 65 Active PEO & Client View 66 33
34 Policy Changes and Experience Rating Copyright 2015 National Council on on Compensation Insurance, Inc. Inc. All All Rights Reserved. 67 Adding Client Employers Coverage added as of a specific date: Full Policy Replacement Transaction Code 14 Name and Address Records: Report add date in Policy Change Effective Date Equates to Policy Effective Date for the new client 68 34
35 Deleting Client Employers Coverage deleted as of a specific date: Full Policy Replacement Transaction Code 14 Name and Address Records of deleted client: Report terminated date in: Policy Change Effective Date Policy Change Expiration Date Equates to Policy Expiration Date for the terminated client 69 Unit Reporting Master Policy Master Unit Report PEO Mod MCP Policies Separate Unit Reports Individual Mods 70 35
36 Experience Rating Rules Experience Rating Plan Manual for Workers Compensation and Employers Liability Insurance Rule 5-A Experience Rating Plan Manual User s Guide Examples for Rule 5-A 71 When a Client Leaves an Arrangement Master Policy Client Termination NC2745 Form Client Mod 72 36
37 NC NC
38 Experience Rating Calculation Current PEO policy 1/1/14 to 1/1/15 Client terminates on 2/1/14 Former client was covered under PEO policies 1/1/07 1/31/14 NC2745 Forms Submitted Rating Effective Date 1/1/14 1/1/10 1/1/11 1/1/12 3rd Report 2nd Report 1st Report Latest loss values as of that report level (including corrections) For renewal ratings, open claims must be reported on subsequent NC2745 Forms (up to the 3rd report level) 75 Bringing It Together Subsequent Changes Copyright 2015 National Council on on Compensation Insurance, Inc. Inc. All All Rights Reserved
39 Alpha Professional Leasing Master PEO Policy, effective 10/1/14 Client Company Changes: Newly added client as of 10/21/14 Capture Investing, 111 Richmond Way, Arlington, VA, Class Code 8832 Terminated client as of 10/22/14 Data Benefits, 123 Mutual Dr., Washington, DC Class Code PEO Data View With Added Client 78 39
40 Added Client View 79 Deleted Client View 80 40
41 Deleted Client View 81 PEO Regulator View 82 41
42 PEO Regulator View 83 PEO Regulator View 84 42
43 PEO Regulator View 85 PEO Regulator View 86 43
44 PEO Regulator View 87 PEO Regulator View 88 44
45 PEO Regulator View 89 PEO Regulator View 90 45
46 PEO Coverage Verification Service 91 PEO Coverage Verification Service 92 46
47 PEO Coverage Verification Service 93 PEO Coverage Verification Service 94 47
48 PEO Coverage Verification Service 95 PEO Coverage Verification Service 96 48
49 NC NC
50 Experience Rating Calculation Renewal Master PEO policy 10/1/14 to 10/1/15 Data Benefits terminated on 10/21/14 Former client was covered under PEO policies for five years NC2745 Forms Submitted Rating Effective Date 10/1/14 10/1/10 10/1/11 10/1/12 3rd Report 2nd Report 1st Report Latest loss values as of that report level (including corrections) 99 Regulatory Focus Copyright 2015 National Council on on Compensation Insurance, Inc. Inc. All All Rights Reserved
51 Department of Insurance NCCI Insurer Employer Dept of Labor Verifies insurer solvency Ensures loss costs and rates are adequate Monitors market structure Regulates market conduct Approves filed manuals Dept of Insurance 101 Workers Compensation Division NCCI Insurer Employer Dept of Labor Monitors prompt delivery of benefits Adjudicates disputes Administers self-insurance Monitors compliance of insurance coverage Dept of Insurance
52 POC Considerations Addition/cancellation/termination of client employers Notification of cancellation/termination to PEO and client employer Association of PEO and client employers 103 Current State of PEOs Mona Carter NCCI Senior Division Executive National Policy Development
53 Video Mona Carter on PEOs 105 Future PEO State-Specific Guide
54 Industry Resources Copyright 2015 National Council on on Compensation Insurance, Inc. Inc. All All Rights Reserved. 107 National Activities National Association of Insurance Commissioners (NAIC) PEO Model Law Requires client-level experience rating Components (such as regulatory authority, definitions, and policy issuance) National Conference of Insurance Legislators (NCOIL) Open for commenting Requires registration of PEOs Regulates use of experience rating
55 State-Specific Requirements Copyright 2015 National Council on on Compensation Insurance, Inc. Inc. All All Rights Reserved. 109 Policy Structure by State (Voluntary Market) Policy Requirements Master, MCP, or Client Direct Purchase Master, MCP, or Multiple PEO Policies Master, MCP, Multiple PEO Policies, or Client Direct Purchase Master or MCP Master Master or Client Direct Purchase MCP or Client Direct Purchase Multiple PEO Policies Master or Multiple PEO Policies No PEO Rules State(s) AL, AR, CO, FL, IA, IN, MD, MS, NC, NH, NM, RI, SC, TN, VT KS NE, NV WV KY, TX CT, DC, ME, IL, MO, OR, UT, VA LA, SD AZ MT AK, GA, HI, ID, OK
56 Policy Structure by State (Residual Market NCCI Plan-Administered States) Policy Requirements MCP Master or Client Direct Purchase MCP or Client Direct Purchase Client Direct Purchase Multiple PEO Policies No PEO Rules State(s) AL, AR, DC, IA, ID, IN, KS, MS, NH, NV, NM, SC, SD, VT, WV IL, OR NC CT, VA AZ AK, GA 111 Florida Department of Business and Professional Regulation maintains a list of valid Florida PEO companies Checks if PEO policy is on list Checks if non-peo policy is not on list Discrepancies may cause rejects for invalid PEO Policy Type Codes PEO Policy Type 5 will reject for being statutorily unacceptable PEO Policy Type 8 currently rejects; however, will be accepted when IAIABC 3.0 POC is implemented (estimated for 2nd or 3rd Qtr. 2015)
57 Florida Multiple Coordinated Policy Client policy covers leased and nonleased employees 113 Georgia Current: GA Employee Leasing Endorsement Complies with Rule 126 Name Link Identifier, Client Name, Address, and FEIN (hard copy reporting) Items to Consider for Future Proposal: MCP, Multiple PEO Policies, or Master Policy for the voluntary market MCP only for residual market Cancellation notice sent to PEO and client Master Policy: Must complete NC2745 Form upon client termination of PEO agreement Experience stays with PEO and goes with client upon termination of PEO arrangement
58 Illinois PEO must be registered prior to obtaining workers compensation Master Policy Illinois Employee Leasing Endorsement Each client must be reported as an additional name with job location and client s FEIN Notice of changes sent to PEO and its clients within 30 days of the coverage being affected or changed PEOs must notify terminations of an employee leasing arrangement 30 days prior to the effective date of termination Statistical Code 9775 Employee Leasing Rating Adjustment 115 Kansas Policy types Multiple Coordinated Policy or Master Policy (if approved by commissioner) Endorsements and Experience Rating Master Policy Exposure and losses must be reported separately per client
59 Kentucky Master PEO Policy must be endorsed with each client's name, address, and FEIN Exposure and experience of each lessee must be used in determining the premium If a lessee has an experience modification factor, the factor must be used to calculate the premium charged for the leased workers provided to the lessee 117 Louisiana Multiple Coordinated Policy Client policy covers leased and nonleased employees
60 Maine Policy Type Code 5 will reject for being statutorily unacceptable According to Maine Rule 560, MCP is required for residual market 119 Montana Multiple PEO Policies Master Policy Exposure and losses must be reported separately per client
61 Nebraska Responsibility to obtain WC for leased employees must be spelled out in PEO agreement Policy types Master Policy, Multiple Coordinated Policy, or Client Direct Purchase Cancellation sent to client by insurer under Master or Multiple Coordinated Policy Endorsements and Experience Rating 121 Nevada Experience mod for Master Policy and for each client upon request Cancellation notices to both PEO and client under Master Policy or Multiple Coordinated Policy Master Policy Exposure and losses must be reported separately per client
62 Nevada 123 Nevada Reporting Flow for Master Policy Unit Report and NV-361 Forms 1st Report (required) Unit Report Master Policy Experience for PEO and multiple client companies Key fields: Master Policy #WC123, Policy Effective Date, Exposure State, Carrier Code Exposure data by class code combined for PEO and client companies Claim data for PEO and client companies Original NV-361 Form (required at same time as 1st Report) + Original NV-361 Form Per Client Company Experience for individual client company Same key fields as 1st Report Client Company Coverage Effective Date and Expiration Date Exposure data by class code for single client company Key claim fields for single client company: Claim #, Accident Date, Class Code Subsequent Reports (as required) Exposure Correction Reports (as needed) Unit Report Master Policy Open, new, or revised claims Updated claim data for PEO and client companies Unit Report Master Policy Revised exposure data by class code Replacement NV-361 Form (as needed) Replacement NV-361 Form Per Client Company Required for changes to: Originally reported client payroll New claim(s) arising after initial reporting of NV-361 Form Claim originally reported to one client must be assigned to a different client All exposure and claim data must be rereported, as a full replacement
63 Oregon Circular OR PEO or client can obtain coverage for leased and nonleased workers 125 Oregon Coverage obtained by PEO: Master policy for PEO s direct employees, and clients leased workers and subject workers separate policies are not issued to each client Premium for each client s exposure must be based on each client experience modification or merit rating factor Insurer must report separate Unit Statistical data Reporting of separate client Policy data is for the reporting of separate unit reports For an assigned risk master policy, reporting of separate client Policy data will include same binder number
64 Oregon Coverage obtained by PEO: PEO is required to file Proof of Coverage for each client directly to the Oregon Workers Compensation Division (WCD) PEO Policy data is used for POC Employee Leasing Policy Type Code 2 or 3 Client company policy data is used by Oregon WCD for verification purposes only Employee Leasing Policy Type Codes 4 or 5 acceptable for each client Policy data 127 Oregon Coverage obtained by Client Company: Client Direct Purchase Client s leased workers and subject workers Client Policy data is used for POC Employee Leasing Policy Type Code
65 Oregon Employee Leasing Policy Type Code 6 not applicable in Oregon Employee Leasing Policy Type Code 8 is statutorily unacceptable FYI Plus published FYI-POC-OR South Dakota Policy Type Code 2 will reject for being statutorily unacceptable Refer to South Dakota Statute
66 Current: Basic Manual Master Policy Texas Experience Rating Plan Manual Modification of new client applied for first two years After two years with the same PEO, the PEO s modification is applied 131 Texas Current: Statistical Plan Part 3 Exposure (TX Exception) Professional Employer Organizations Exposure for each client covered under a professional employer organization s policy must be reported separately. Part 6 Coding Values Employee Leasing Code E Report E for each PEO client
67 Proposed: Texas Basic Manual Provides rules and definitions under which policies involving PEO services agreements are written PEO Policy Basis Client Policy Basis Treatment of Executive Employees Experience Rating Plan Manual Modification of new client applied for first two years After two years, the PEO s modification is applied 133 Utah Master Policy Exposure and losses must be reported separately per client Client Direct Purchase Separate policies for leased versus nonleased exposures but must be same insurer
68 Virginia PEO must be registered with Virginia Workers Compensation Commission prior to obtaining workers compensation 135 It s Showtime! Copyright 2015 National Council on on Compensation Insurance, Inc. Inc. All All Rights Reserved
69 Supplemental Information
70
71 Presenter Biographies Julie Gonzalez, AIDM, has been employed at NCCI since As a data consultant and project manager in the Data Services Department, her main responsibilities include managing NCCI s Data Educational Program, overseeing major compliance projects, developing new data reporting requirements, and enhancing NCCI s external training programs and data tools. In addition, Julie actively participates on industry committees and association forums to provide industry relationships and subject matter expertise. Prior to joining Data Services, Julie was a senior underwriting analyst, responsible for filing workers compensation rules and programs and managing the appeals board mechanism for several NCCI states. Julie has earned both her Associate in Commercial Underwriting (AU) and Associate Insurance Data Manager (AIDM) designations. Shani Oulton has worked at NCCI for 11 years in the Regulatory Services Division, currently in the National Policy Development area. She is primarily responsible for monitoring workers compensation industry trends across states, with a strong focus on Professional Employer Organizations. Shani holds a bachelor of science degree from the University of Florida.
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