INVESTIGATION REPORT. Secondary Employment Policy Violation. Date: May 23, Report Number: CPIC Report Number: CPIC

Size: px

Start display at page:

Download "INVESTIGATION REPORT. Secondary Employment Policy Violation. Date: May 23, 2014. Report Number: CPIC 14-03-0002. Report Number: CPIC 14-03-0002"

Charla Thornton
8 years ago
Views:

1 INVESTIGATION REPORT Secondary Employment Policy Violation Date: May 23, 2014

2 Table of Contents: Page Report Background 1 Allegations 1 Procedures 1 Findings 2 Conclusion 2 Appendix Distribution 3 Audit Performed By 3

3 Report Background On March 27, 2014, a report was made to Citizens Ethics Hotline ( TellCitizens ) by a Citizens Claims Quality Assurance ( QA ) Supervisor advising that a Citizens Field Adjuster [Subject] may be violating the Secondary Employment Policy. Specifically, the report stated that the Subject may be involved in estimate writing for a different insurance company. The report mentions that it is uncertain if this Subject is the same individual that is currently a Field Adjuster. The report provided the name of a Property Management company that Subject is allegedly submitting estimates on for non-citizen s claims (i.e. another carrier) and also mentioned that Florida public business records (from Sunbiz.org) shows the Subject as an officer of the Property Management company. It is important to note that the Subject s first and last name are common. Allegation Subject has violated the Secondary Employment Policy. Procedures OIA performed the following procedures: 1. Reviewed documentation to identify the relationship between the Subject and Citizens Property Insurance Corporation (CPIC). 2. Reviewed web-based information on the Subject and the Property Management Company and its owners to identify if other related entities may exist and understand if any relationships are present. 3. Conducted a review of claims data extracted from Citizens Claim Tracking System (CTS) for claims assigned to the Subject to identify if the Subject had any potentially associated entities working on claims assigned to them. 4. Interviewed the Subject and Claims QA Supervisor as well as other associated individuals identified as potentially having information (based on findings throughout the investigative process) to ascertain information. Findings The procedures above resulted in the following findings: 1. Subject s Relationship with CPIC: The Subject has been employed by CPIC as a Field Adjuster since Per Human Resources no record exists of Subject requesting approval for Secondary Employment. 2. Subject s Potential Entity Associations: Review of Sunbiz.org corporation records for the Property Management Firm identified the same name as the Subject listed as President. Note: the firm is listed as inactive as of September 27, Upon enquiry the subject confirmed that there is no direct relationship with this organization. Further analysis and research of the Property Management Firm and its officers (another individual identified in public records as Vice President) identified a Restoration Firm with Page 1

The report mentions that it is uncertain if this Subject is the same individual that is currently a Field Adjuster.

4 Report the same Vice President of the Property Management Firm as the Owner of the Restoration Firm. Additionally, the two Firms have the same address. Note: Restoration Firm filed date is February 19, 2014 and Subject is not named as an officer per Sunbiz.org records. Of importance is the fact that the address of the two firms is within the general radius (i.e. less than 5 miles) of the Subject s home address. 3. Subject s Claims Data Analysis Thirty individual claims were identified as having been assigned to the Subject from April 1, 2013 through April 1, Of the thirty claim files reviewed one was identified as utilizing the Restoration Firm. Note: no claims identified the Property Management Firm. Refer to the Interview section below for our findings associated with this claim identified by speaking with the Insured and Claims QA. 4. Interviews Citizens Claims Quality Assurance ( QA ) function communicated that the Subject recommended the Restoration Firm to the Insured. Two QA Inspectors communicated that during their April 8, 2014 meeting with the Insured, at the loss location, the Insured explained to them that the field adjuster recommended this company [Restoration Firm] and wrote down the name on the back of a card. The claim identified by OIA as using the Restoration Firm (under #3 above) was the same claim identified by the QA department in the bullet above. The Insured stated that the Subject never recommended any specific firms, but rather provided the tenant and Insured with business cards for several restoration firms and that by no means of influence the Insured called and utilized the same Restoration Firm. In our interview with the Subject, the subject stated that at no time did the subject provide a recommendation for any restoration firms. Later in the interview the Subject stated that they provided the tenant with 3 to 4 business cards as the tenant was asking for help. In a subsequent follow up the Subject explained that the Insured was standing there when the Tenant asked for names of restoration firms. Both the Subject and Insured stated that the Restoration Firm in question selection was by pure chance. Note: Subject admitted that when Insured asked if the Restoration Firm in question had any issues the Subject stated they had not heard anything negative. Conclusion The results from our investigation provide us with information that leads a reasonable professional to assume that, at the very least, an appearance of a Conflict of Interest is present. Additionally, the Subject did violate Citizen s Claims Management directive 2 of not recommending any vendors, contractors, or any other type of firm to our policyholders. It is recommended that management, with the support of Human Resources, assess this instance and determine the most appropriate action given the circumstances and evidence provided in this report. 1 OIA generally utilizes the past year on allegations for analysis; this time period was later confirmed appropriate in that Restoration Firm was incorporated in February A communication was sent to all claims staff on 11/3/11 advising staff that it was not appropriate to refer contractors. It was also noted that a Claims Manager stated he advises his staff at virtually every meeting not to recommend any contractors. Page 2

Of importance is the fact that the address of the two firms is within the general radius (i.e. less than 5 miles) of the Subject s home address. 3.

5 Appendix 1 Distribution Addressees Copies Jimmy Johnson, Director - Claims Steve Sherin, Asst. Director - Claims Tom Lynch, Citizens Audit Committee Chairman Juan Cocuy, Citizens Audit Committee Member Freddie Schinz, Citizens Audit Committee Member Barry Gilway, President/CEO/Executive Director Dan Sumner, General Counsel & Chief Legal Officer John Rollins, Chief Risk Officer James Adams, VP Claims Lori Andrade Dillingham, Director - HR Business Partner Mgt Christine Turner Ashburn, VP Communications, Legislative & External Affairs Debby Kearney, Ethics and Compliance Officer Bruce Meeks, Inspector General Johnson Lambert, LLP (External Auditors) Following Audit Committee Distribution The Honorable Rick Scott, Governor The Honorable Jeff Atwater, Chief Financial Officer The Honorable Pam Bondi, Attorney General The Honorable Adam Putnam, Commissioner of Agriculture The Honorable Don Gaetz, President of the Senate The Honorable Will Weatherford, Speaker of the House of Representatives Investigation Performed By Auditor in Charge Billie Sue Hamrick Audit Director Under the Direction of Josh Shilts Joe Martins Chief of Internal Audit Page 3

Director Dan Sumner, General Counsel & Chief Legal Officer John Rollins, Chief Risk Officer James Adams, VP Claims Lori Andrade Dillingham, Director - HR Business Partner Mgt Christine Turner

AUDIT REPORT. Corporate Access and Identity Management Project Audit Opinion: Satisfactory. July 31, 2015

AUDIT REPORT. Corporate Access and Identity Management Project Audit Opinion: Satisfactory. July 31, 2015 AUDIT REPORT Corporate Access and Identity Management Project Audit Opinion: Satisfactory July 31, 2015 Report Number: 2015-IT-02 Corporate Access and Identity Management Project Table of Contents: Page