2015 Star Ratings. Critical Illness Cover. Discussion paper
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1 2015 Star Ratings Critical Illness Cover Discussion paper Defaqto Limited All rights reserved. No parts of this publication may be reproduced in any form by any means, whether electronic, mechanical, optical or any other or be stored in a retrieval system without the express written permission of the publisher. The publisher has taken all reasonable measures to ensure the accuracy of the information and Ratings in this document and cannot accept responsibility or liability for errors in or omission from any information given 1 and for any consequences arising.
2 About this document This document outlines the key developments and trends that will inform the criteria we use for the 2015 Star Ratings for Critical Illness Cover covering Standalone Critical Illness, Level Term Critical Illness and Decreasing Term Critical Illness and, based on these, sets out the areas where we would like to consult the industry as part of ensuring that our Ratings process remains robust and transparent. 2
3 Key developments and trends The market Swiss Re s Term & Health Watch 2014 reports that sales of individual critical illness fell by 20.5% in All the major life and protection products experienced a similar drop in sales volumes which infers that this is part of a general downturn rather than dissatisfaction with critical illness specifically. Indeed, critical illness cover continues to have the second highest sales volumes after individual term assurance and there are five times more policies sold than income protection insurance. Mortgage Market Review will challenge critical illness sales over the next 12 months Product development is now focusing on the quality of the cover rather than simply the number of critical conditions Legislation and regulation Mortgage Market Review (MMR) The MMR set out the case for reforming the mortgage market to ensure it is sustainable and works better for consumers. In essence, its provisions, which came into effect in April, are designed to prevent people borrowing more than they can pay back. Whilst this is desirable, there are two implications for protection sales. First, the greater scrutiny of applicants means a more time-consuming process for advisers and therefore less time to consider the client s protection needs. Second, a more rigorous assessment of affordability taking into account insurance outgoings, which may mean people with protection insurances will not pass the affordability test. Given that much critical illness cover is arranged to protect mortgage debt, MMR looks to present an additional challenge to sales of the product in future. Statement of Best Practice for Critical Illness Cover The Association of British Insurers (ABI) is updating its Statement of Best Practice for Critical Illness Cover. The 2014 statement will update 11 definitions to improve clarity and/or take account of advances in medical science, and deals with partial payments and the use of the ABI+ label. Partial payments are typically associated with the provision of severity-based critical illness. The new statement makes the distinction between partial payments and additional payments. Members will be obliged to describe payments that reduce the sum assured then remaining by the amount of the payment as partial. Payments that do not reduce the sum assured are to be described as additional payments. ABI+ is the term used by insurers in their marketing to describe a definition that is more generous than the model wording. Hitherto it has not been defined by the ABI. In this statement, the ABI includes two pieces of guidance. First, in order for insurers to claim that a definition exceeds the model wording, it must both provide additional cover and result in additional claims. The ABI gives the example that removal of an exclusion from a model wording would not be deemed to provide additional cover if you could claim under another definition in the policy. Second, where the model wording includes optional provisions [shown in square brackets], the omission or inclusion of these provisions cannot be claimed for ABI+. 3
4 HMT Simple Products Initiative In December 2010, a consultation set out the government s initial suggestions for how a range of simple products could be developed. The aims for simple products are: To help consumers benchmark and compare products on the market To be understandable and accessible to the mass market Not to be tailored to meet individual needs, but provide consumers with confidence that a simple product will meet their basic needs and offer them a fair deal To be a viable commercial proposition for providers Templates for simple savings accounts and a simple term assurance product have been agreed and work is progressing on a group income replacement product. Critical illness was ruled out of the initiative at an early stage on the grounds that it was too complex. However, we anticipate that quite apart from the accredited simple products, which will compete primarily on price and service, there is an appetite for providers to market simpler products (critical illness included) direct to consumers via strategic partners and using digital marketing techniques. 4
5 Providers Provider Underwriter SA CIC LTA CIC DTA CIC AA Legal & General AEGON Own Ageas Protect Own AIG Direct Own Aviva Life & Pensions UK Limited Own BHSF Own Barclays Legal & General Beagle Street Own Bright Grey Own Connells Friends Life ESMI Own Forester Life Own Friends Life Individual Protection Own HSBC Life Own Legal & General Own LV= Own MetLife Own Nationwide Building Society Legal & General NatWest Aviva NFU Mutual Own PruProtect Own Royal Bank of Scotland Aviva Sainsbury's Bank Legal & General Santander Aviva Scottish Provident Own Scottish Widows Own Skandia Own Skipton Building Society Legal & General Smart Insurance Own Tesco Bank Aviva The Co-operative Bank Friends Life Zurich Assurance Ltd Own 5
6 Products/propositions We classify critical illness in three categories: standalone cover accelerated critical illness with level term assurance and accelerated benefit with decreasing term. There are currently 22 providers offering standalone cover through 38 different products including three intended for business protection purposes. However, it is estimated that only 5% of critical illness cover is written on a standalone basis, so most interest in product development is around life assurance with an accelerated critical illness benefit. There are 51 level term with critical illness products from 28 providers including white labelled products and 42 decreasing term products with critical illness from 26 providers, including eight products intended specifically for business protection purposes. Approximately half of products are menu plans, where critical illness is available as one of a number of benefits within one proposition; the other half are plans where critical illness is an add-on option to a life assurance product. A small number of products come as a package where critical illness cover is automatically included. Since May 2013 almost all the main brands have enhanced their critical illness offerings. There is a continuing trend to add new critical conditions, although this is less marked than in previous years. The emphasis is now much more on enhancing existing definitions and, most recently, attention has turned to improving still further the important covers like cancer and heart attack. 6
7 Key implications for the 2015 Ratings process No changes are proposed to the database or the Star Rating criteria as a result of these developments this year. The database has to reflect the changes in the market on the one hand without endorsing or encouraging developments that add little value on the other. To this end we currently only score seven critical conditions individually; the remainder are scored on an aggregated basis and some conditions receive no scores at all. This is because seven conditions account for 94% of all critical illness claims and two, cancer and heart attack, account for 73% of claims. Cancer (60%) Heart Attack (13%) Stroke (6%) Others (6%) Multiple Sclerosis (5%) Terminal Illness (5%) Benign Brain Tumour (2%) Coronary Artery Bypass (2%) Heart Valve Replacement (1%) In recent months we have undertaken to add columns for all new critical conditions brought to market so that our users can see at a glance which providers offer what cover, but these new columns do not attract additional DNA points. In addition to the critical illnesses covered, the Rating takes into account features relating to the flexibility of the contract both in terms of the options available at the acquisition stage and those that enable the plan to accommodate changes in client circumstances. Finally, credit is given for ancillary benefits which provide ongoing help and support to clients, whether or not they need to claim. The following tables set out the criteria for critical illness cover arranged thematically, demonstrating the weighting between the various criteria types. 4 and 5 Star rated products will necessarily have to score DNA points in each of these sections in order to achieve the aggregated score high enough to exceed the 4 and 5 Star benchmark. Additionally, certain core criteria are in place where a particular feature or benefit is mandatory for a 4 or 5 Star Rating. 7
8 Features relating to the acquisitions process (14% of criteria) POS Decision Given Underwriting Process Discount For Exclusions Reviewable Rates Guaranteed Rates Features matching benefits to needs (17% of criteria) CIC as a % of Life Cover Not Standalone Critical Illness Maximum Age at Expiry Sum Assured Indexation Not Decreasing Critical Illness Indexation Costing Basis Not Decreasing Critical Illness Maximum Interest Rate Decreasing Critical Illness Only Mortgage Guarantee Decreasing Critical Illness Only Features to help cope with changing circumstances (20% of criteria) Option to Vary Sum Assured Option to Vary Term Critical Illness Buy-Back Life Buy-Back Not Standalone Critical Illness Insurance Guaranteed Insurability GIO - Maximum Age Waiver of Premium Features relating to critical illness cover (34% of criteria) Cancer Core Criterion Heart Attack Core Criterion Stroke Core Criterion Multiple Sclerosis Core Criterion Coronary Artery Bypass Core Criterion Heart Valve Replacement Core Criterion Benign Brain Tumour Core criterion Terminal Illness Time Limit TPD Own Occupation Critical Illness Score Core Criterion Children s CI Benefit Core Criterion 8
9 Severity Based CIC Non-insured benefits (9% of criteria) Second Medical Opinion Health and Wellbeing Services Claims Support Services Features relating to claims (6% of criteria) No. of Exclusions - CIC Claims Stats Published 9
10 Areas for discussion Based on the material in the preceding sections, the following will form the basis of our discussion at the forthcoming Roundtable event. Are the current criteria still relevant to the product and the Star Rating? Specifically, is there a case for stripping out criteria that relate to the proposition to advisers and retain just those that are relevant to the end consumer? Are there any features and benefits of critical illness cover, which are not currently covered within the existing criteria set, that should form part of it going forward? Specifically, is there a case for making the Ratings more focussed on the customer journey with measures for efficiency in dealing with product changes and efficient handling of claims in addition to the ease of acquisition, which is covered to a certain extent by some existing criteria? Should the method of scoring the critical illnesses be updated in the light of greater numbers of critical conditions and more favourable definitions or should it continue to favour the core illnesses, which account for most claims? What are the prospects for critical illness cover in the D2C market? Does it remain a preserve of the advised route? 10
11 Appendix: Proposed 2015 criteria Based on the above analysis, we propose including the following criteria in our assessment process for the 2015 Ratings (core criteria are in bold text). Proposed criteria Standalone Critical Illness Underwriting Process Employed Health and Wellbeing Services Included POS Decision Given Severity Based Critical Illness Premium Discounted when Elements of Cover Excluded Cancer Maximum Age at Expiry Heart Attack Critical Illness Rates Guaranteed Benign Brain Tumour Reviewable Rates Coronary Artery Bypass Grafts Sum Assured Indexation Heart Valve Replacement or Repair Indexation Costing Basis Multiple Sclerosis Waiver of Premium Stroke Critical Illness Buy-Back Terminal Illness Time Limit (Months) Option to Vary Term Critical Illness Score Option to Vary Sum Assured Children s CI Benefit Guaranteed Insurability TPD Own Occupation GIO Maximum Age Claims Stats Published Second Medical Opinion Service Number of Exclusions CIC Claims Support Services Included 11
12 Proposed criteria Level Term Critical Illness Underwriting Process Claims Support Services Included POS Decision Given Health and Wellbeing Services Included Premium Discounted when Elements of Cover Excluded Maximum Age at Expiry Accelerated CI Cancer CIC of Life Cover (%) Heart Attack Severity Based Critical Illness Guaranteed Rates for Accelerated CIC Benign Brain Tumour Reviewable Premium Rates Coronary Artery Bypass Grafts Sum Assured Indexation Heart Valve Replacement or Repair Indexation Costing Basis Multiple Sclerosis Waiver of Premium Stroke Life Buy-Back Terminal Illness Time Limit (Months) Critical Illness Buy-Back Critical Illness Score Option to Vary Term Children s CI Benefit Option to Vary Sum Assured TPD Own Occupation Guaranteed Insurability Claims Stats Published GIO Maximum Age Number of Exclusions CIC Second Medical Opinion Service 12
13 Proposed criteria Decreasing Term Critical Illness Underwriting Process Claims Support Service Included POS Decision Given Health and Wellbeing Services Included Premium Discounted when Elements of Cover Excluded Maximum Age at Expiry Accelerated CI Cancer CIC of Life Cover (%) Heart Attack Severity Based Critical Illness Maximum Interest Rate Benign Brain Tumour Mortgage Guarantee Coronary Artery Bypass Grafts Guaranteed Rates for Accelerated CIC Heart Valve Replacement or Repair Reviewable Premium Rates Multiple Sclerosis Waiver of Premium Stroke Life Buy-Back Terminal Illness Time Limit (Months) Critical Illness Buy-Back Critical Illness Score Option to Vary Term Children s CI Benefit Option to Vary Sum Assured TPD Own Occupation Guaranteed Insurability Claims Stats Published GIO Maximum Age Number of Exclusions CIC Second Medical Opinion Service 13
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