THE COMMUNITY INSURANCE FRAUD INITIATIVE (CIFI) A TEN YEAR RETROSPECTIVE

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1 THE COMMUNITY INSURANCE FRAUD INITIATIVE (CIFI) A TEN YEAR RETROSPECTIVE A joint report by the Automobile Insurers Bureau of Massachusetts (AIB) and the Insurance Fraud Bureau of Massachusetts (IFB). Contact: Daniel J Johnston, President, AIB and Executive Director, IFB [email protected] INTRODUCTION In 3, the Insurance Fraud Bureau embarked on a unique program to fight back against an epidemic of insurance fraud, largely in the form of organized staged auto accidents. The program, known as the Community Insurance Fraud Initiative (CIFI), has been well documented in local and national news media and has been widely viewed as a success. Approximately five years after the effort began, we published a report chronicling the genesis of the program, and the success we witnessed. Now, almost ten years after its inception, we once again have updated that analysis. In the pages that follow, one can see the measurable impact of the program and how it influenced insurance claims and, ultimately, premiums paid. Most importantly, the evidence shows that there has not been a return of these fraud schemes to the state. Clearly this CIFI effort has been a major contributor to a healthy auto insurance climate in Massachusetts over the past decade. In addition to the continuing efforts to drive out fraud, regulators have overhauled the residual market and opened auto insurance to competitive pricing, lending to more than a 5 percent increase (from 19 to 34) in insurers now willing to write auto insurance policies in Massachusetts. The following report is a collaborative effort by staff in the Automobile Insurers Bureau of MA, and the Insurance Fraud Bureau of MA. In particular, William Scully and Edith Wendell of AIB, and Deborah Terry of IFB, made major contributions to this report. 1

2 EXECUTIVE SUMMARY In late 3, a 65 year old grandmother was killed in what eventually was proven to be a staged accident in the City of Lawrence, Massachusetts. This tragic event led to the creation of a unique and unprecedented task force dedicated to combating insurance fraud in the city, and eventually to the unraveling of a network of staged accident participants and facilitators that spanned ordinary citizens, runners, chiropractors, physical therapists and lawyers. This scheme had saddled the insurance industry, and ultimately the auto insurance buying public, with hundreds of millions of dollars of escalated costs for years. The good news is that the trend has been halted and significantly reversed. This report will demonstrate the following: Lawrence, while identified as the worst hotbed of fraudulent claims in the state, was not the only one. Now 13 communities and their surrounding areas have in place task forces, labeled Community Insurance Fraud Initiatives, or CIFI s. These task forces have been a catalyst in the steady reduction of auto insurance losses and premiums in the Commonwealth. The IFB, local police departments, District Attorneys, together with additional assistance from the Attorney General and insurance company special investigative units, have collectively found a key strategy to combat fraud networks at the local level. People who purchased auto insurance in the City of Lawrence have saved over $68 million dollars since the introduction of the CIFI program, mostly as a result of this remarkable effort. In all of the CIFI communities the total is an impressive $875 million. Professionals, including chiropractors and attorneys who participated in this cottage industry, have been prosecuted or have closed their operations. For instance, in Lawrence, larger chiropractors have decreased in both clinic counts and billings by up to 9 percent, high volume physical therapy clinics (billings exceeding $K annually) have been eliminated, and attorney involvement on PIP claims has dropped. Positive results of varying degrees have been witnessed in the other 12 CIFI communities. Detailed summary statistics are shown for each CIFI community in Exhibits 1 of this report. Staged accident activity in Massachusetts has been reduced dramatically as people around the state, who used to be involved in fraudulent activities, have taken notice of the crackdown and altered their activities. The ongoing efforts of the CIFI task forces, in conjunction with the IFB and the valuable data provided by the Detail Claim Database (DCD), exert a continuing deterrent effect on fraudulent behavior in the Commonwealth, ultimately providing a significant savings to both insurers and policyholders. 2

3 THE ORIGINS OF THE CIFI S The staged accident that kicked off this effort occurred on September 4, 3, and immediately hit the front page of the Lawrence Eagle Tribune. Leaders of the IFB and the Lawrence Police Department (LPD) reacted quickly, and by October, a full task force was in place, housed in Lawrence, and included two IFB senior investigators, two detectives from the LPD, and dedicated prosecutors from the Essex County District Attorney s office. Armed with data garnered by the IFB, and referrals from the insurance industry, the task force went about identifying possible other staged accidents in the city. At the same time, the task force reached out to the community through billboard advertising and newspaper ads highlighting a reward program. Soon, community meetings took place, spearheaded by a local state senator. These actions all produced quick results. By the end of the year, after only three months, 17 people were charged with insurance fraud, largely due to staged accidents. The Division of Professional Licensure took note, and invited ALL of the state s licensed chiropractors to Lawrence for a summit on the problem. In Lawrence, it seemed that most of the staged accidents had roots in runners working directly for local chiropractors who were feeding off the extra patients the accidents brought in. To this day, the task force is active, working through an inventory of possible staged accident cases that have come to light. EXPANSION EFFORTS The AIB played a key role in assisting the IFB in determining how to use what was done in Lawrence so successfully, and to identify an expansion plan for the program. In evaluating what was unique statistically about Lawrence, it was discovered that leading up to 3, Lawrence had developed the highest measurable statistic in a newly developed metric, the injurytoaccident ratio. Actually, prior to 3, Lawrence stood out has having 141 reported injuries for every accidents, far above any other community, and nearly four times the statewide average of 38 injuries per accidents. The only plausible cause for this high number seemed to be the inordinate number of highoccupant, multicar, injuryrelated accidents that were synonymous with staged accidents. When accidents were staged in Lawrence, they typically involved two cars, each with a large number of occupants (presumably to maximize the payback). This drove the injuries to accident ratio statistic through the roof. Using this statistic as a guide to detect areas of unusual and potentially fraudulent activity in the state, the AIB identified other cities that could benefit from similar CIFI task force efforts. Armed with this information, the IFB then set out to reach out to police departments and District Attorneys in the 12 nexthighest communities based on injuries per accidents. Here is the data as it existed in 3: 3

4 RESULTS The results of these efforts can be measured in several ways: 1) the number of people charged with insurance fraud as a result of the effort is an indicator that indeed these crimes were being committed; 2) the improvement in the injurytoaccident ratio after the effort began; 3) the change in the billing practices of high volume providers in these communities; 4) the change in percentage of PIP claims with attorney involvement; and 5) the dollar reduction of claims and premiums in these communities vs. the state as a whole. We examine each of these measures below: (1) Number of People Charged with Insurance Fraud As the task forces were created in each community, word went out to the local public that law enforcement officials and the insurance industry were intent on ridding their communities of fraud. Billboard advertisements spotted the landscape. Televised press conferences and editorial board meetings provided other ways of keeping the story in the news. Insurance companies were instrumental in referring suspected fraudulent claims to the task forces. In short order, scams were uncovered in each of the communities, and individuals were charged with criminal violations. Each time, efforts were made to have the local newspaper carry the story, and reemphasize the local efforts to rid the system of fraud. Ultimately, this approach contributed to a deterrent effect as fewer staged accidents were coming into the system. Here are the tallies of individuals charged with insurance fraud and related crimes in each CIFI community. Those charged included ordinary citizens, runners, chiropractors, and attorneys. Many have since been convicted. Others are still awaiting their day in court as their cases wind through the judicial system. 4

5 CIFI Community People Charged Boston 488 Lawrence 484 Brockton 295 Springfield/Holyoke 177 Lynn 133 Fall River/New Bedford 95 Randolph 76 Lowell 64 Chelsea/Revere 59 Worcester 46 Statewide 1,917 (2) Improvement to InjurytoAccident Ratios While the precifi statistics of injuries per accidents gave the best clue as to where to set up task force efforts, an obvious way to determine success was to measure whether there was any improvement in that statistic over time. In every CIFI community there has been a reduction in this statistic since introduction of the CIFI programs, a sure sign of the programs effectiveness. Because public awareness is part of each CIFI campaign, and because many of the fraud perpetrators may operate in multiple communities, there has been a halo effect resulting in improvements to the statewide (noncifi community) measure as well, dropping from 29 injuries per accidents in 3 to 23 injuries per accidents in 8. Since 8 the deterrent effect of the ongoing CIFI task forces has kept the injurytoaccident ratios at these low levels. The charts below show the measurable effects the CIFI programs have had on CIFI and non CIFI industry claims. (Detailed statistics for each individual CIFI community are shown in Appendix Exhibits 1.) CIFI Towns vs. Rest of Industry Total CIFI Statewide excifi 5

6 1 5% 5% 1 15% 2 Change in CIFI Towns vs. Rest of Industry Total CIFI Statewide excifi (3) Change in Billing Practices in CIFI Communities The AIB maintains a database, known as the Detail Claim Database, or DCD, that tracks all auto injury claims in Massachusetts since Among other information collected on each claim, the DCD captures the medical providers that were the highest billing providers on each and every claim. This database can then be mined to identify outliers from the norm, whose billing patterns suggest unusual practices, or those providers who are high volume auto accident billers (typically measured by those billing over $, per year for services). One pattern noticed in Lawrence was that there were an unusually high number of high volume chiropractors present during the period before the CIFI task force was formed. As the pattern of staged accident cases in Lawrence unfolded, and it became evident that a number of chiropractors were participants in the scheme, several things occurred. Some chiropractors were charged and convicted. Some lost their licenses to practice. 6

7 Some simply closed their clinics and disappeared. In all, there were 22 highvolume chiropractors and physical therapists in Lawrence before CIFI, and now only seven remain. And their collective billing plummeted by over 9 percent ($8.1M). So we looked at the DCD to see the count of high volume providers, comparing 3 (before CIFI) to current, to see if there is any change in the pattern of billing from this subset of practitioners. Here s what we found for chiropractors and physical therapists: (4) Percentage of PIP Claims with Attorney Involvement When PIP claims are fraudulent they often involve claim buildup with the assistance of an attorney. The graph below shows the level of attorney involvement in PIP claims for claims associated with the same high volume providers described above. Since the introduction of the CIFI programs there has been a reduction in attorney involvement across the state. 7

8 (5) Reductions to Claims and Premiums Ultimately, the insurance buying public pays for insurance fraud in the form of higher premiums. Generally speaking, premiums have to be high enough to cover the expense of paying claims. If claims are high, or overly inflated, premiums are driven up. If claims go down, so can premiums. In the CIFI communities, as fraudulent claims were taken out of the system by the CIFI effort, premiums started to fall dramatically. The graphic below shows that for accident year 11 losses (claims dollars for all coverages) are at a level that is $266 million lower than in the period preceding the introduction of the CIFI program in each community. In the following table the impact of these loss savings is reflected in the total cumulative premium savings accrued across the years since the introduction of the CIFI programs. On a per policy basis, each policyholder in a CIFI community has been enjoying an 8

9 annual savings of $185 in premium (on average) since the years of higher fraud activity and the resulting higher premiums that went along with that activity. During the same period there has also been an average annual policy premium savings of $139 realized in the noncifi communities. While these savings cannot be wholly attributed to the CIFI programs, given the observed reductions in fraudulent activity as measured by the improvements observed in the accidenttoinjury ratios described above, it is certain that the ongoing efforts of the CIFI programs have been a major contributing factor. Their continuing efforts provide fraud deterring effects that will serve to keep future losses and premiums down, providing ongoing savings to both insurance companies and policyholders. ESTIMATED POLICY PREMIUM SAVINGS SINCE CIFI INTRODUCTION (THROUGH 11) CIFI Community Year CIFI Introduced Cumulative Premium Savings Average Annual Savings per Vehicle Boston 4 $346,892,292 $227 Brockton 4 49,557, Chelsea/Revere 5 32,427, Fall River/New Bedford 6 38,361,9 79 Holyoke/Springfield 4 98,714, Lawrence 3 68,439, Lowell 4 73,558, Lynn 4 56,832, Randolph 5 31,664, Worcester 6 78,441,71 18 Total CIFI 874,889, Industry excifi 3,317,731, TOTAL Industry $4,192,621,211 $148 Cumulative premium savings is estimated for each community by comparing the difference between the precifi average policy premium and the average policy premium for each subsequent year applied to the total vehicles in each community. Average annual savings is the cumulative premium savings divided by the number of years of savings and the current number of vehicles in each community. Premiums represent all coverages written. o Industry total written premium from 311 was $36.1B. o Cumulative premium savings since CIFI introduction represents 11.6% of industry premium. 9

10 CONCLUSION The CIFI effort continues in Massachusetts. Several of our CIFI offices have been invited by neighboring communities to assist them in dealing with fraud in their cities, an approach the IFB has embraced enthusiastically. Local law enforcement, seeing the positive results, have asked IFB investigators to participate in training sessions on identifying and investigating insurance fraud for their personnel. Many of the charges brought against individuals take years to be resolved in the court system, and our investigators remain engaged for the long haul to assist prosecutors during this phase of the process. While our work is not done, the auto insurance climate in Massachusetts has no doubt improved as a result of this effective program. Its continued operation provides a valuable ongoing deterrent effect across the entire state. See more at

11 Billings in 's Exhibit 1 Community Insurance Fraud Initiative (CIFI) A Ten Year Retrospective CIFI Unit: Boston Introduced: 4 Total Average Injury Cumulative Accident Written Written Written Claims Premium Year Premium Exposures Premium Change Ratio Change Savings 3 $333,838, ,799 $1, $ 4 $344,332,78 8,335 $1, % % $ 5 $336,957,976 6,413 $1, % % ($4,413,635) 6 $3,851,443 7,386 $1, % % ($26,84,465) 7 $297,829, ,51 $1, % % ($78,586,12) 8 $27,4,952 5,814 $1, % ($149,557,573) 9 $25,,1 195,5 $1, % % ($223,248,659) $286,456, ,895 $1, % % ($293,223,332) 11 $38,9, ,74 $1, % ($346,892,292) Change in Boston Total CIFI Statewide excifi Boston Total CIFI Statewide excifi 5, 4, 3,,, High Volume Provider Billings (Annual Billings Exceeding $K) Total Reduction: $22,44K Chiropractor Physical Therapist Number of High Volume Providers Chiro Phys 7 35 Total ,8 1, 1,4 1, 8 4 Average Written Premium Boston Total CIFI Statewide excifi BI Claims With Attorney Involvement PIP/MedPay Claims With Attorney Involvement % 91.3% 92% 9.8% 88% 84.5% Boston Total CIFI Statewide excifi % 65.9% 66.9% 63.3% 41.4% 35.1% Boston Total CIFI Statewide excifi Automobile Insurers Bureau of Massachusetts (13)

12 Billings in 's Exhibit 2 Community Insurance Fraud Initiative (CIFI) A Ten Year Retrospective CIFI Unit: Brockton Introduced: 4 Total Average Injury Cumulative Accident Written Written Written Claims Premium Year Premium Exposures Premium Change Ratio Change Savings 3 $72,421,545 49,521 $1, $ 4 $75,84,36 48,774 $1, % % $ 5 $74,781,849 48,296 $1,548.4% % ($279,427) 6 $72,67,293 47,916 $1, % ($2,79,33) 7 $67,417,221 47,677 $1, %.7.8% ($8,7,67) 8 $,58,745 46,14 $1, % % ($19,962,639) 9 $54,89,924 42,692 $1, % % ($32,224,472) $62,1,657 46,91 $1, % % ($42,956,616) 11 $66,411,772 46,978 $1, % % ($49,557,834) Change in Brockton Total CIFI Statewide excifi Brockton Total CIFI Statewide excifi, 8, 6, 4, 2, High Volume Provider Billings (Annual Billings Exceeding $K) Total Reduction: $3,58K Chiropractor Physical Therapist Number of High Volume Providers Chiro Phys Total ,8 1, 1,4 1, 8 4 Average Written Premium Brockton Total CIFI Statewide excifi BI Claims With Attorney Involvement PIP/MedPay Claims With Attorney Involvement % 91.8% 92% 9.8% 88% 84.5% Brockton Total CIFI Statewide excifi % 66.9% 63.3% 59.2% 41.4% 35.1% Brockton Total CIFI Statewide excifi Automobile Insurers Bureau of Massachusetts (13)

13 Billings in 's Exhibit 3 Community Insurance Fraud Initiative (CIFI) A Ten Year Retrospective CIFI Unit: Chelsea/Revere Introduced: 6 Total Average Injury Cumulative Accident Written Written Written Claims Premium Year Premium Exposures Premium Change Ratio Change Savings 3 $55,823,298 36,124 $1, $ 4 $58,39,323 35,518 $1, % % $ 5 $56,674,475 35,116 $1, % % $ 6 $54,275,225 34,813 $1, % % ($1,126,938) 7 $51,,624 34,825 $1, % ($5,525,571) 8 $46,6,965 34,153 $1, % % ($13,361,845) 9 $43,317,162 32,294 $1, % % ($21,561,338) $49,743,491 35,53 $1,4 4.4% ($28,513,786) 11 $53,48,184 35,69 $1, % % ($32,427,54) Change in Chelsea/Revere Total CIFI Statewide excifi Chelsea/Revere Total CIFI Statewide excifi 7, 6, 5, 4, 3, 2, High Volume Provider Billings (Annual Billings Exceeding $K) Total Reduction: $3,832K Chiropractor Physical Therapist Number of High Volume Providers Chiro 2 Phys 9 6 Total ,8 1, 1,4 1, 8 4 Average Written Premium Chelsea/Revere Total CIFI Statewide excifi BI Claims With Attorney Involvement PIP/MedPay Claims With Attorney Involvement % 92% 88.6% 9.8% 88% 84.5% Chelsea/Revere Total CIFI Statewide excifi % 63.2% 66.9% 63.3% 41.4% 35.1% Chelsea/Revere Total CIFI Statewide excifi Automobile Insurers Bureau of Massachusetts (13)

14 Billings in 's Exhibit 4 Community Insurance Fraud Initiative (CIFI) A Ten Year Retrospective CIFI Unit: Fall River/New Bedford Introduced: 6 Total Average Injury Cumulative Accident Written Written Written Claims Premium Year Premium Exposures Premium Change Ratio Change Savings 3 $114,771,638 1,829 $1, $ 4 $1,48,46 1,73 $1, % % $ 5 $125,83,564,943 $1, % % $ 6 $115,974,316,29 $1, % % $ 7 $113,49,49 99,249 $1, % ($2,19,189) 8 $3,727,432 96,486 $1,75 5.6% % ($,152,57) 9 $94,36,852 92,489 $1,17 5.4% % ($23,338,117) $1,429,696 96,653 $1,49 3.2% % ($33,956,686) 11 $7,976,284 96,942 $1, % % ($38,361,9) Change in Fall River/New Bedford Total CIFI Statewide excifi Fall River/New Bedford Total CIFI Statewide excifi 4, 4,4 4, 4, 3,8 3, 3,4 High Volume Provider Billings (Annual Billings Exceeding $K) Total Reduction: $278K Chiropractor Physical Therapist Number of High Volume Providers Chiro Phys 3 1 Total , 1,4 1, 8 4 Average Written Premium Fall River/New Bedford Total CIFI Statewide excifi BI Claims With Attorney Involvement PIP/MedPay Claims With Attorney Involvement % 92% 88.3% 9.8% 88% 84.5% Fall River/New Bedford Total CIFI Statewide excifi % 63.3% 55.3% 56.6% 41.4% 35.1% Fall River/New Bedford Total CIFI Statewide excifi Automobile Insurers Bureau of Massachusetts (13)

15 Billings in 's Exhibit 5 Community Insurance Fraud Initiative (CIFI) A Ten Year Retrospective CIFI Unit: Holyoke/Springfield Introduced: 4 Total Average Injury Cumulative Accident Written Written Written Claims Premium Year Premium Exposures Premium Change Ratio Change Savings 3 $115,213,562 87,672 $1, $ 4 $121,337,925 87,58 $1, % % $ 5 $1,473,498 86,815 $1,388.1% % $115,542 6 $117,33,239 86,59 $1, % % ($2,78,711) 7 $7,517,116 86,973 $1, % % ($15,826,28) 8 $96,654,521 85,221 $1, % % ($37,267,97) 9 $88,98,43 8,899 $1,99 3.1%.4 4.7% ($,399,81) $98,681,281 86,99 $1, % % ($82,17,581) 11 $4,612,8 87,48 $1, % % ($98,714,368) Change in Holyoke/Springfield Total CIFI Statewide excifi Holyoke/Springfield Total CIFI Statewide excifi 16, 14, 12,, 8, 6, 4, 2, High Volume Provider Billings (Annual Billings Exceeding $K) Total Reduction: $7,627K Chiropractor Physical Therapist Number of High Volume Providers Chiro Phys Total , 1,4 1, 8 4 Average Written Premium Holyoke/Springfield Total CIFI Statewide excifi BI Claims With Attorney Involvement PIP/MedPay Claims With Attorney Involvement % 92.9% 92% 9.8% 88% 84.5% Holyoke/Springfield Total CIFI Statewide excifi % 67.9% 66.9% 63.3% 41.4% 35.1% Holyoke/Springfield Total CIFI Statewide excifi Automobile Insurers Bureau of Massachusetts (13)

16 Billings in 's Exhibit 6 Community Insurance Fraud Initiative (CIFI) A Ten Year Retrospective CIFI Unit: Lawrence Introduced: 4 Total Average Injury Cumulative Accident Written Written Written Claims Premium Year Premium Exposures Premium Change Ratio Change Savings 3 $43,54, 26,694 $1, $ 4 $43,526,741 25,943 $1, % $ 5 $41,181,873 25,537 $1, % % ($1,663,825) 6 $39,14,368 25,882 $1,57 6.5% % ($6,74,413) 7 $34,93,331 26,644 $1, % ($15,847,93) 8 $32,4,124 26,763 $1, % % ($28,745,357) 9 $29,3,28 25,597 $1, % ($42,331,555) $33,991,836 28,559 $1,19 3.8% % ($56,254,857) 11 $36,724,39 29,151 $1,2 5.8% % ($68,439,496) Change in 5.. Lawrence Total CIFI Statewide excifi Lawrence Total CIFI Statewide excifi, 8, 6, 4, 2, High Volume Provider Billings (Annual Billings Exceeding $K) Total Reduction: $8,111K Chiropractor Physical Therapist Number of High Volume Providers Chiro 16 7 Phys 6 Total ,8 1, 1,4 1, 8 4 Average Written Premium Lawrence Total CIFI Statewide excifi BI Claims With Attorney Involvement PIP/MedPay Claims With Attorney Involvement % 91.4% 92% 9.8% 88% 84.5% Lawrence Total CIFI Statewide excifi % 61.7% 66.9% 63.3% 41.4% 35.1% Lawrence Total CIFI Statewide excifi Automobile Insurers Bureau of Massachusetts (13)

17 Billings in 's Exhibit 7 Community Insurance Fraud Initiative (CIFI) A Ten Year Retrospective CIFI Unit: Lowell Introduced: 4 Total Average Injury Cumulative Accident Written Written Written Claims Premium Year Premium Exposures Premium Change Ratio Change Savings 3 $7,142,549 53,361 $1, $ 4 $73,98,741 52,694 $1, % % $ 5 $72,899,721 52,555 $1, % ($5,618) 6 $68,1,88 52,816 $1, % ($5,163,5) 7 $63,26,626 53,113 $1, % ($15,815,486) 8 $58,322,589 52,673 $1,7 6.7% % ($3,562,391) 9 $54,2,623 5,86 $1,65 3.8% % ($46,938,856) $59,436,45 53,638 $1,8 4.1% ($61,9,164) 11 $63,123,361 53,91 $1, % % ($73,558,881) Change in Lowell Total CIFI Statewide excifi Lowell Total CIFI Statewide excifi 7, 6, 5, 4, 3, 2, High Volume Provider Billings (Annual Billings Exceeding $K) Total Reduction: $3,622K Chiropractor Physical Therapist Number of High Volume Providers Chiro Phys 6 3 Total , 1,4 1, 8 4 Average Written Premium Lowell Total CIFI Statewide excifi BI Claims With Attorney Involvement PIP/MedPay Claims With Attorney Involvement % 9.9% 92% 9.8% 88% 84.5% Lowell Total CIFI Statewide excifi % 59.9% 66.9% 63.3% 41.4% 35.1% Lowell Total CIFI Statewide excifi Automobile Insurers Bureau of Massachusetts (13)

18 Billings in 's Exhibit 8 Community Insurance Fraud Initiative (CIFI) A Ten Year Retrospective CIFI Unit: Lynn Introduced: 4 Total Average Injury Cumulative Accident Written Written Written Claims Premium Year Premium Exposures Premium Change Ratio Change Savings 3 $64,883,538 44,88 $1, $ 4 $67,686,71 43,953 $1,54 6.5% % $ 5 $66,912,271 43,466 $1, % ($23,948) 6 $64,68,65 43,367 $1, % ($2,127,2) 7 $59,256,934 43,459 $1, % % ($9,796,279) 8 $52,868,4 42,297 $1,25 8.3% % ($22,64,354) 9 $48,661,8 4,296 $1,8 3.4% % ($35,457,52) $53,983,251 42,929 $1, % % ($47,584,145) 11 $57,127,328 43,2 $1, % % ($56,832,742) Change in Lynn Total CIFI Statewide excifi Lynn Total CIFI Statewide excifi 6, 5, 4, 3, 2, High Volume Provider Billings (Annual Billings Exceeding $K) Total Reduction: $1,536K Chiropractor Physical Therapist Number of High Volume Providers Chiro 14 8 Phys 7 7 Total ,8 1, 1,4 1, 8 4 Average Written Premium Lynn Total CIFI Statewide excifi BI Claims With Attorney Involvement PIP/MedPay Claims With Attorney Involvement % 91.6% 92% 9.8% 88% 84.5% Lynn Total CIFI Statewide excifi % 64.4% 66.9% 63.3% 41.4% 35.1% Lynn Total CIFI Statewide excifi Automobile Insurers Bureau of Massachusetts (13)

19 Billings in 's Exhibit 9 Community Insurance Fraud Initiative (CIFI) A Ten Year Retrospective CIFI Unit: Randolph Introduced: 5 Total Average Injury Cumulative Accident Written Written Written Claims Premium Year Premium Exposures Premium Change Ratio Change Savings 3 $29,614,486 21,5 $1, $ 4 $3,911,224,894 $1, % % $ 5 $32,48,382,417 $1, % % $ 6 $31,82,485,24 $1, % % ($71,298) 7 $27,219,471 19,95 $1, % % ($5,148,415) 8 $23,75,643 19,396 $1,225.3% ($12,184,472) 9 $21,891,917 18,415 $1, % % ($19,522,783) $24,836,552 19,96 $1, % ($26,282,449) 11 $26,623,12,163 $1,3 5.8% % ($31,664,118) Change in Randolph Total CIFI Statewide excifi Randolph Total CIFI Statewide excifi 4, 3,5 3, 2,5 2, 1,5 5 High Volume Provider Billings (Annual Billings Exceeding $K) Total Reduction: $348K Chiropractor Physical Therapist Number of High Volume Providers Chiro 7 8 Phys 6 7 Total ,8 1, 1,4 1, 8 4 Average Written Premium Randolph Total CIFI Statewide excifi BI Claims With Attorney Involvement PIP/MedPay Claims With Attorney Involvement % 93.1% 92% 9.8% 88% 84.5% Randolph Total CIFI Statewide excifi % 62.6% 66.9% 63.3% 41.4% 35.1% Randolph Total CIFI Statewide excifi Automobile Insurers Bureau of Massachusetts (13)

20 Billings in 's Exhibit Community Insurance Fraud Initiative (CIFI) A Ten Year Retrospective CIFI Unit: Worcester Introduced: 6 Total Average Injury Cumulative Accident Written Written Written Claims Premium Year Premium Exposures Premium Change Ratio Change Savings 3 $113,431,287 87,749 $1, $ 4 $117,54,33 87,388 $1, % $ 5 $124,231,78 86,121 $1, % % $ 6 $115,623,28 85,614 $1, % % $ 7 $6,98,567 86,199 $1, % % ($9,432,513) 8 $96,681,64 84,3 $1, % % ($26,599,547) 9 $86,783,432 79,221 $1,95 4.5% % ($46,85,515) $97,5,777 86,49 $1, % % ($65,515,353) 11 $4,773,55 87,152 $1,2 6.1% % ($78,441,71) Change in 15.. Worcester Total CIFI Statewide excifi Worcester Total CIFI Statewide excifi 5, 4, 3, High Volume Provider Billings (Annual Billings Exceeding $K) Total Reduction: $2,626K Number of High Volume Providers 1, 1,4 1, 8 Average Written Premium 2, Chiropractor Physical Therapist Chiro 9 11 Phys 6 2 Total Worcester Total CIFI Statewide excifi BI Claims With Attorney Involvement PIP/MedPay Claims With Attorney Involvement % 9.8% 86.9% 88% 82.8% 84.5% Worcester Total CIFI Statewide excifi % 63.3% 54.9% 55.5% 41.4% 35.1% Worcester Total CIFI Statewide excifi Automobile Insurers Bureau of Massachusetts (13)