Professional Employer Organizations (PEO) and Workers Compensation. Implications for Ratemaking



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Professional Employer Organizations (PEO) and Workers Compensation Implications for Ratemaking Harry Shuford Practice Leader & Chief Economist, NCCI Use of Workers Compensation Data for Workplace Safety and Health Washington, DC June 19-20, 2012

Today s Presentation Background on PEOs and the Labor Market PEO Services State Regulation of PEOs Background on PEOs and Workers Compensation Regulation of PEOs in Workers Compensation Objectives of Actuarial Ratemaking Comparing WC Claims Experience PEOs and All Other 2004-2009 Broken down by industry group in policy year 2007 Preliminary Observations 1

Background on PEOs PEO services employee benefits payroll workers compensation risk management recruiting training and development Employer of record for the leased workers from a PEO client company 2

PEOs in Workers Compensation a Good Thing? NAPEO Contends that PEOs Create Safer Work Environments -Effective safety practices such as: pre-employment drug tests, loss control and safety procedures, claims management of injuries, safety training, employee assistance plans, back-to-work programs, and drug-free workplace programs - According to NAPEO many of these safety practices are new to the typical PEO client-a small to mid-sized business without the time, expertise, or resources to cater to worker safety concerns Source: National Association of Professional Employer Organizations (NAPEO) NAPEO 2012. Used with permission. 3

Licensing The Number of States Requiring Licensing of PEOs Has Grown Steadily: 4

Licensing States Map 1991 & 1995 Added in 1995 Source: National Association of Professional Employer Organizations (NAPEO) NAPEO 2012. Used with permission. 5

Licensing States Map 2000 & 2005 Added in 2000 Added in 2005 Source: National Association of Professional Employer Organizations (NAPEO) NAPEO 2012. Used with permission. 6

Licensing States List 2012 Added in 2012 Current Status AL, AZ, AR, CO, CT, FL, HI, ID, IL, IN, KY, LA, ME, MI, MN, MT, NE, NV, NH, NJ, NM, NY, NC, ND, OH, OK, OR, RI, SC, TN, TX, UT, VT, VA, WV, WI CA, PA Source: National Association of Professional Employer Organizations (NAPEO) NAPEO 2012. Used with permission. 7

One to Two Percent of Insured Payroll in Voluntary Market Is from PEOs Residual Market Share Has Been Approximately Four Percent There Was a Marked Decline over the Great Recession 8.0% 7.0% 6.7% Voluntary Market PEO Payroll Share in 37 NCCI Ratemaking States Residual Market PEO Payroll Share in 25 NCCI Ratemaking States Voluntary Market PEO Payroll Share in 25 NCCI Ratemaking States PEO Payroll Share 6.0% 5.0% 4.0% 3.0% 2.0% 1.7% 3.7% 2.0% 4.3% 2.1% 4.9% 4.2% 2.0% 1.9% 2.3% 1.8% 1.0% 0.0% 1.5% 1.0% 1.2% 1.1% 1.1% 1.1% 2004 2005 2006 2007 2008 2009 Policy Year CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 8

Workers Compensation Data Indicate that The Role of PEOs Varies Greatly Across States and Between the Voluntary and Residual Markets 10

PEOs Payroll Share in Voluntary Market Policy Year 2009, 37 States MT ME OR NV ID UT CO SD NE KS IA MO IL IN KY WV VA VT NH RI CT DC MD AZ NM OK AR TN SC MS AL GA AK TX LA FL HI Share 0.01 to 0.5% 0.5 to 1% 1 to 2% 2 to 3% 3 to 5% over 5% CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 11

PEOs Payroll Share in Residual Market Policy Year 2009, 25 States OR ID SD VT NH NV NE KS IA MO IL IN WV VA DC CT AZ NM AR TN SC MS AL GA AK Share 0.01 to 0.5% 0.5 to 1% 1 to 2% 2 to 3% 3 to 5% over 5% CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 13

Workers Compensation Data Suggest that the PEO Market is Highly Concentrated 14

National PEOs Account for the Majority PEO Activity 800.0 700.0 693.4 600.0 500.0 400.0 Number Workers per PEO Master Policy Number of Workers per PEO Client 300.0 200.0 222.9 Number of Clients per PEO 100.0 0.0 9.7 22.9 8.6 PEOs National PEOs 79.2 Master PEO policy data is used National PEOs list was based on membership list at napeo.org in April, 2012 Source: NCCI, National Association of Professional Employer Organizations (NAPEO) NAPEO 2012. Used with permission. 15

15 Largest PEO Companies Comprise Approximately Two Thirds Market; National PEOs Members Make up Majority of PEO Industry Policy Year 2009 Data Top 5 48.8% Next 5 Next 5 Other 2.6% 8.5% PEO policy models Master policy, MCP policies, Multiple PEO policies, and PEO direct employee policies are included National PEOs list was based on membership list at napeo.org in April, 2012 MCP policies may not have PEO information as named insured; NCCI 37 ratemaking states only Source: NCCI, National Association of Professional Employer Organizations (NAPEO) NAPEO 2012. Used with permission. 16

Background on PEOs and Workers Compensation 17

PEO State Regulation of PEOs: Workers Compensation In 1992, NCCI filed Item B-1276 Employee Leasing Arrangements to provide rules and policy forms for employee arrangements in workers compensation markets. Most states implemented, some states passed modified versions, and some states have yet to implement. In July 2005, NCCI filed Item RM-W-8027 for residual market requiring MCP* PEO policy model when underwriting PEO policy. Most states have implemented. Overall, there is no national NCCI rule for underwriting policies of PEO arrangements in the voluntary market. MCP refers to multiple coordinated policy form; the MCP is described on the next slide 18

PEO Policy Models Master Policy A single policy that covers the leased workers of a PEO s client companies with the PEO as the primary insured; the client companies may be attached to the policy by endorsement; may also cover PEO direct employees Multiple Coordinated Client Policies (MCP) A separate policy to cover the leased workers of single PEO client company with the client as the primary insured Multiple PEO Policies A separate policy to cover the leased workers of single PEO client company with the PEO as the primary insured making reference to the client company 19

Recent Trends in the Voluntary Market: Multiple PEO Policy Has Been Substituting MCP for Client Policies 100.0% 99.5% 99.0% 98.5% 98.0% Multiple PEO Policy MCP Policy Master Policy PEO Direct Employee Policy Client Direct Purchase Policy Non-Leased Workers Client Policy Non-PEO Policy 97.5% 97.0% 96.5% 2004 2005 2006 2007 2008 2009 20

Recent Trends in the Residual Market: Master Policy Share Has Declined Since 2005 100.0% 98.0% 96.0% 94.0% 92.0% Multiple PEO Policy MCP Policy Master Policy PEO Direct Employee Policy Client Direct Purchase Policy Non-Leased Workers Client Policy Non-PEO Policy 90.0% 88.0% 2004 2005 2006 2007 2008 2009 21

Comparing PEO WC Policies In All Cases PEO Clients Appear to be Small Businesses 250.0 222.9 200.0 Average # Workers per Policy Average # of Workers per Client 150.0 Average # of Clients per PEO 100.0 50.0 0.0 22.9 19.4 9.7 6.7 9.2 Master PEO Policy MCP Client Policy Multiple PEO Policy Non-PEO Policies 22

In the Voluntary Market in 2009 Most PEO Leased Workers Are Covered Under Master Policies 37 NCCI Ratemaking States PEO Direct Employee Policy 1.5% MCP Client Policy 4.0% Multiple PEO Policy 13.7% Master PEO Policy 80.7% 23

In the Residual Market in 2009 Many More Workers Are Covered Under MCP or Multiple PEO Policies 25 NCCI Ratemaking States PEO Direct Employee Policy 3.5% MCP Client Policy 28.2% Master PEO Policy 49.7% Multiple PEO Policy 18.7% 25

Wide Variation Across States in the Voluntary Market PEO Payroll Share by Policy Type 2009 Policy Year PEO Direct Employee Policy Master Policy MCP Client Policy Multiple PEO Policy 7.0% 6.0% 5.0% 4.0% 3.0% 2.0% VOL 1.0% 0.0% 09 FL 42 TX 02 AZ 05 CO 52 HI 10 VOL 27 GA NV 43 UT 35 OK 06 CT 28 NH 47 WV 12 IL 01 AL 41 TN 39 SC 24 MO 45 VA 03 AR 08 DC 25 MT 19 MD 54 AK 30 NM 15 KS 36 OR 17 LA 11 ID 13 IN 14 IA 26 NE 18 ME 16 KY 38 RI 23 MS 40 SD 44 VT 26

Wide Variation Across States in the Residual Market PEO Payroll Share by Policy Type 2009 Policy Year PEO Direct Employee Policy Master Policy MCP Client Policy Multiple PEO Policy 30.0% 25.0% 20.0% 15.0% 10.0% 5.0% RES 0.0% 02 AZ 01 AL 27 NV 12 IL 28 NH 14 IA 36 OR 23 MS 30 NM 10 RES 13 GA IN 24 MO 45 VA 03 AR 26 NE 11 ID 39 SC 15 KS 41 TN 08 DC 40 SD 06 CT 44 VT 47 WV 54 AK 28

Implications of PEOs for Workers Compensation Ratemaking 29

Actuarial Ratemaking Premium rates should be: Neither Excessive Nor Inadequate Nor Unfairly Discriminatory 30

Actuarial Ratemaking Aggregate Ratemaking: Neither Excessive Nor Inadequate Requires Aggregated State Level Data Financial Call Data 31

Actuarial Ratemaking Class Ratemaking and Experience Rating: Nor Unfairly Discriminatory Requires Detailed Claim Data by Individual Insured Employer Unit Data 32

Potential Ratemaking Concerns Related to PEOs How These Compare with Concerns in BLS Data Incorrectly Classified Payroll [BLS inaccurate counts of employment by occupation] Underreporting of Claims [BLS SOII Underreporting of injuries] Bulk Reporting of Claim Experience [BLS SOII Inability to Estimate Injury Rates by Occupation/Industry] Difficulty in tracking the experience rating modification 33

Does PEO Claim Experience Differ Materially from Non-PEO Experience? 34

Market Segments Voluntary market analysis includes 37 NCCI ratemaking states Residual market analysis includes 25 NCCI ratemaking states: 21 NCCI Plan states IN, TN, MO, and NE where NCCI is not the Plan Administrator PEOs in our data analysis refers to workers covered in PEO: Master policy MCP policies Multiple PEO policies PEO direct employees CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 35

Workers Compensation Data at the Policy Level Policy data: Proof of Coverage (POC) compliance reports issued at policy inception Provides information on the type of policy including PEOs Unit data: Unit reports used for class ratemaking Contains detail on payroll by class (typically a blend of occupation and industry) plus detail on individual claims 36

Data Used in This Analysis NCCI policy and unit data in policy years 2004 2010 Industry group level data in policy year 2007 Losses are evaluated at 2 nd report PEO policy type is as reported in the policy data 37

PEO Loss Experience in Workers Compensation

Loss Experience for 2004-2009: PEOs versus Non-PEO Policies 38

Key Measures of Workers Compensation Loss Experience Estimated Number of Workers in Thousands Lost Time Claims Frequency Payroll AWW 52 1000 Number of Lost Time Claims Number of Workers in Thousands Lost Time Claims Severity Incurred Losses on Lost Time Claims Number of Lost Time Claims Lost Time Claims Loss Ratio Incurred Losses on Lost Time Claims Manual or Modified Premium 39

Loss Experience for 2004-2009: PEOs versus Non-PEO Policies Frequency in the Voluntary Market 40

In the Voluntary Market Frequency Is Higher for PEOs than for Non-PEOS Voluntary Market, 2004-2009, @2 nd Report 18.0 Non-PEO Large Deductible PEOs Large Deductible Non-PEO Other than Large Deductible PEOs Other than Large Deductible 16.0 Lost Time Claims Frequency per 1000 Workers 14.0 12.0 10.0 8.0 6.0 4.0 2.0 0.0 2004 2005 2006 2007 2008 2009P Policy Year 42

Loss Experience for 2004-2009: PEOs versus Non-PEO Policies Voluntary Market Large Deductible (Typically Master Policies for PEOs, Larger Employers for Non-PEOs) 43

In the Voluntary Market Frequency Has Declined But PEOs Higher than Non-PEOs Large Deductible Policies (Typically Master Policies for PEOs; Larger Employers for Non-PEOs) 2004-2009, @2 nd Report Lost Time Claims Frequency per 1000 Workers Non-PEOs PEOs 18.0 16.0 16.3 15.7 14.1 Lost Time Claims Frequency per 1000 Workers 14.0 12.0 10.0 8.0 6.0 4.0 10.3 9.7 9.2 11.1 8.9 10.4 8.1 9.2 7.8 2.0 0.0 2004 2005 2006 2007 2008 2009P Policy Year 44

In the Voluntary Market Severity Trends for PEOs and Non-PEOs Are Comparable Large Deductible Policies (Typically Master Policies for PEOs; Larger Employers for Non-PEOs) 2004-2009, @2 nd Report Lost Time Claims Severity in Thousands Non-PEOs PEOs 40.0 Lost Time Claims Severity in Thousands 35.0 30.0 25.0 20.0 15.0 10.0 27.2 27.6 23.0 26.9 29.1 27.5 34.2 31.3 35.4 34.1 32.0 30.7 5.0 0.0 2004 2005 2006 2007 2008 2009P Policy Year 45

In the Voluntary Market Manual Premium Loss Ratios for PEOs Have Increased Relative to Non-PEOs Large Deductible Policies (Typically Master Policies for PEOs; Larger Employers for Non-PEOs) 2004-2009, @2 nd Report Lost Time Claims Loss Ratio Manual Premium Non-PEOs PEOs 0.45 0.41 0.40 0.37 Lost Time Claims Loss Ratio by Manual Premium 0.35 0.30 0.25 0.20 0.15 0.10 0.30 0.24 0.28 0.29 0.28 0.28 0.31 0.30 0.32 0.32 0.05 0.00 2004 2005 2006 2007 2008 2009P Policy Year 46

In the Voluntary Market Modified Premium Loss Ratios for PEOs Have Been Lower than for Non-PEOs Large Deductible Policies (Typically Master Policies for PEOs; Larger Employers for Non-PEOs) 2004-2009, @2 nd Report Lost Time Claims Loss Ratio Modified Premium Non-PEOs PEOs 0.45 0.43 0.39 0.40 Lost Time Claims Loss Ratio by Modified Premium 0.35 0.30 0.25 0.20 0.15 0.10 0.33 0.25 0.32 0.27 0.33 0.29 0.36 0.34 0.39 0.38 0.05 0.00 2004 2005 2006 2007 2008 2009P Policy Year 47

Loss Experience for 2004-2009: PEOs versus Standard Policies Voluntary Market Other than Large Deductible Policies Typically Smaller Employers 48

In the Voluntary Market Frequency Has Declined But Higher for PEOs than Non-PEOs Other than Large Deductible Policies (Typically Smaller Employers) 2004-2009, @2 nd Report Lost Time Claims Frequency per 1000 Workers Non-PEOs PEOs 16.0 14.0 13.8 13.6 14.1 Lost Time Claims Frequency per 1000 Workers 12.0 10.0 8.0 6.0 4.0 11.3 10.9 10.7 11.7 10.4 11.3 11.2 9.6 9.1 2.0 0.0 2004 2005 2006 2007 2008 2009P Policy Year 49

In the Voluntary Market Severity Trends Are Comparable But Severity Lower for PEOs than Non-PEOs Other than Large Deductible Policies (Typically Smaller Employers) 2004-2009, @2 nd Report Lost Time Claims Severity in Thousands Non-PEOs PEOs Lost Time Claims Severity in Thousands 40.0 35.0 30.0 25.0 20.0 15.0 10.0 29.4 26.2 30.7 29.4 32.5 30.4 34.3 28.1 37.2 32.5 36.2 33.4 5.0 0.0 2004 2005 2006 2007 2008 2009P Policy Year 50

In the Voluntary Market Manual Premium Loss Ratio Trends Are Comparable for PEOs and Non-PEOs Other than Large Deductible Policies (Typically Smaller Employers) 2004-2009, @2 nd Report Lost Time Claims Loss Ratio Manual Premium Non-PEOs PEOs 0.50 0.45 0.42 Lost Time Claims Loss Ratio by Manual Premium 0.40 0.35 0.30 0.25 0.20 0.15 0.10 0.34 0.32 0.34 0.35 0.33 0.34 0.36 0.29 0.39 0.36 0.39 0.05 0.00 2004 2005 2006 2007 2008 2009P Policy Year 51

In the Voluntary Market Modified Premium Loss Ratio Trends Are Comparable for PEOs and Non-PEOs Other than Large Deductible Policies (Typically Smaller Employers) 2004-2009, @2 nd Report Lost Time Claims Loss Ratio Modified Premium Non-PEO PEOs 0.50 0.45 0.41 0.43 Lost Time Claims Loss Ratio by Modified Premium 0.40 0.35 0.30 0.25 0.20 0.15 0.10 0.36 0.32 0.36 0.36 0.35 0.35 0.38 0.31 0.38 0.41 0.05 0.00 2004 2005 2006 2007 2008 2009P Policy Year 52

Loss Experience for 2004-2009: PEOs versus Standard Policies Residual Market 53

In the Residual Market Frequency Has Been Higher for PEOs than for Non-PEOs Both Exhibit Slight Downtrends 2004-2009, @2 nd Report Lost Time Claims Frequency per 1000 Workers Non-PEOs PEOs Lost Time Claims Frequency per 1000 Workers 35.0 30.0 25.0 20.0 15.0 10.0 5.0 30.5 29.0 28.0 26.7 22.3 21.9 21.9 21.6 25.7 27.0 20.0 20.1 0.0 2004 2005 2006 2007 2008 2009P Policy Year 54

In the Residual Market Severity Has Been Higher for Non-PEOs than for PEOs Both Exhibit a Marked Uptrend * 2004-2009, @2 nd Report Lost Time Claims Severity in Thousands Non-PEOs PEOs 60.0 56.0 52.8 Lost Time Claims Severity in Thousands 50.0 40.0 30.0 20.0 36.1 23.7 40.8 44.8 27.8 27.9 29.2 42.7 46.1 34.7 10.0 0.0 2004 2005 2006 2007 2008 2009P Policy Year The data for 2009 is preliminary and reflects the impact of the recession on the results of that policy year 55

In the Residual Market Manual Premium Loss Ratios Often Have Been Lower for PEOs than for Non-PEOs 2004-2009, @2 nd Report Lost Time Claims Loss Ratio Manual Premium Non-PEOs PEOs 0.80 0.74 Lost Time Claims Loss Ratio by Manual Premium 0.70 0.60 0.50 0.40 0.30 0.20 0.55 0.52 0.56 0.57 0.49 0.50 0.66 0.54 0.68 0.63 0.60 0.10 0.00 2004 2005 2006 2007 2008 2009P Policy Year 56

In the Residual Market Modified Premium Loss Ratios Often Have Been Lower for PEOs than for Non-PEOs 2004-2009, @2 nd Report Lost Time Claims Loss Ratio Modified Premium Non-PEO PEOs 0.80 0.69 Lost Time Claims Loss Ratio by Modified Premium 0.70 0.60 0.50 0.40 0.30 0.20 0.52 0.49 0.53 0.55 0.47 0.48 0.64 0.50 0.66 0.59 0.58 0.10 0.00 2004 2005 2006 2007 2008 2009P Policy Year 57

Loss Experience for 2007 by Industry Group: PEO versus Non-PEO Policies Voluntary Market 58

In the Voluntary Market in 2007 Most PEO Leased Workers Were Covered Under Master Policies MCP Client Policy 12.4% PEO Direct Employee Policy 0.7% Multiple PEO Policy 11.6% Master PEO Policy 75.3% CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 59

In the Voluntary Market PEO Mix of Clients Comparable to Non-PEO Mix Share of Insured Payroll by Industry Group Voluntary Market, Policy Year 2007, @2 nd Report PEOs Non-PEOs 70.0% 60.0% 50.0% Share of Payroll 40.0% 30.0% 20.0% 10.0% 0.0% Manufacturing Contracting Office & Clerical Goods & Services Miscellaneous CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 60

In the Voluntary Market Lost-Time Claims Frequency by Industry Group PEO Frequency Higher for Most Industry Groups Voluntary Market, Policy Year 2007, @2 nd Report PEOs Non-PEOs 40.0 35.0 Lost Time Claims Frequency per 1000 Workers 30.0 25.0 20.0 15.0 10.0 5.0 0.0 Manufacturing Contracting Office & Clerical Goods & Services Miscellaneous CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 61

In the Voluntary Market Lost-Time Claims Severity by Industry Group PEO Severity Higher for Miscellaneous Voluntary Market, Policy Year 2007, @2 nd Report PEOs Non-PEOs 60.0 50.0 Lost Time Claims Severity in Thousands 40.0 30.0 20.0 10.0 0.0 Manufacturing Contracting Office & Clerical Goods & Services Miscellaneous CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 62

In the Voluntary Market Lost-Time Claims Loss Ratio Manual Premium PEOs Higher than Non-PEOs for Miscellaneous Voluntary Market, Policy Year 2007, @2nd Report PEOs Non-PEOs 0.50 0.45 Lost Time Claims Loss Ratio by Manual Premium 0.40 0.35 0.30 0.25 0.20 0.15 0.10 0.05 0.00 Manufacturing Contracting Office & Clerical Goods & Services Miscellaneous CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 63

In the Voluntary Market Lost-Time Claims Loss Ratio Modified Premium PEOs Higher than Non-PEOs for Miscellaneous Voluntary Market, Policy Year 2007, @2nd Report PEOs Non-PEO 0.50 0.45 Lost Time Claims Loss Ratio by Modified Premium 0.40 0.35 0.30 0.25 0.20 0.15 0.10 0.05 0.00 Manufacturing Contracting Office & Clerical Goods & Services Miscellaneous CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 64

PEO Lost-Time Claims Indemnity Severity by Industry Group Voluntary Market, Policy Year 2007, @2 nd Report PEOs Non-PEO 60.0 Lost Time Claims Indemnity Severity in Thousands 50.0 40.0 30.0 20.0 10.0 0.0 Manufacturing Contracting Office & Clerical Goods & Services Miscellaneous CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 65

PEO Lost-Time Claims Medical Severity by Industry Group Voluntary Market, Policy Year 2007, @2 nd Report PEOs Non-PEO 60.0 Lost Time Claims Medical Severity in Thousands 50.0 40.0 30.0 20.0 10.0 0.0 Manufacturing Contracting Office & Clerical Goods & Services Miscellaneous CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 66

Loss Experience for 2007 by Industry Group: PEO versus Non-PEO Policies Residual Market 67

In the Residual Market in 2007 Most Leased Workers Were Still Covered Under Master Policies PEO Direct Employee Policy 4.4% MCP Client Policy 17.8% Master PEO Policy 70.4% Multiple PEO Policy 7.3% CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 68

In the Residual Market PEOs Are Especially Prominent in Manufacturing Share of Payroll Policy Year 2007, @2nd Report PEOs Non-PEOs 60.0% 50.0% Share of Payroll 40.0% 30.0% 20.0% 10.0% 0.0% Manufacturing Contracting Office & Clerical Goods & Services Miscellaneous CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 69

In the Residual Market PEO Frequency Higher than for Non-PEOs Policy Year 2007, @2 nd Report PEOs Non-PEOs 80.0 70.0 Lost Time Claims Frequency per 1000 Workers 60.0 50.0 40.0 30.0 20.0 10.0 0.0 Manufacturing Contracting Office & Clerical Goods & Services Miscellaneous CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 70

In the Residual Market Severity Was Lower for PEOs in All But Miscellaneous Policy Year 2007, @2 nd Report PEOs Non-PEOs 90.0 80.0 Lost Time Claims Severity in Thousands 70.0 60.0 50.0 40.0 30.0 20.0 10.0 0.0 Manufacturing Contracting Office & Clerical Goods & Services Miscellaneous CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 71

In the Residual Market Manual Premium Loss Ratios Lower for PEOs In All but Miscellaneous Policy Year 2007, @2nd Report PEOs Non-PEOs 1.20 Lost Time Claims Loss Ratio by Manual Premium 1.00 0.80 0.60 0.40 0.20 0.00 Manufacturing Contracting Office & Clerical Goods & Services Miscellaneous CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 72

In the Residual Market Modified Premium Loss Ratios Lower for PEOs In All but Miscellaneous Policy Year 2007, @2nd Report PEOs Non-PEO 1.20 Lost Time Claims Loss Ratio by Modified Premium 1.00 0.80 0.60 0.40 0.20 0.00 Manufacturing Contracting Office & Clerical Goods & Services Miscellaneous CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 73

PEO Lost-Time Claims Indemnity Severity by Industry Group Residual Market, Policy Year 2007, @2 nd Report PEOs Non-PEO 90.0 Lost Time Claims Indemnity Severity in Thousands 80.0 70.0 60.0 50.0 40.0 30.0 20.0 10.0 0.0 Manufacturing Contracting Office & Clerical Goods & Services Miscellaneous CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 74

PEO Lost-Time Claims Medical Severity by Industry Group Residual Market, Policy Year 2007, @2 nd Report PEOs Non-PEO 90.0 Lost Time Claims Medical Severity in Thousands 80.0 70.0 60.0 50.0 40.0 30.0 20.0 10.0 0.0 Manufacturing Contracting Office & Clerical Goods & Services Miscellaneous CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 75

Adverse PEO Experience in Miscellaneous Group May Reflect Classes Of Employers Insured 76

High Risk Classes Are Prominent PEO Miscellaneous Clients Industry Group Top Governing Class Code by Number of Unit Reports Description Manufacturing 3632 MACHINE SHOP NOC 9521 HOUSE FURNISHINGS INSTALLATION NOC & UPHOLSTERING 4299 PRINTING 4484 PLASTICS MANUFACTURING: MOLDED PRODUCTS NOC 3681 TELEVISION, RADIO, TELEPHONE OR TELECOMMUNICATION DEVICE MFG. NOC Contracting 5190 ELECTRICAL WIRING-WITHIN BUILDINGS & DRIVERS 3724 MACHINERY OR EQUIPMENT ERECTION OR REPAIR NOC & DRIVERS 5606 CONTRACTOR-EXECUTIVE SUPERVISOR OR CONSTRUCTION SUPERINTENDENT 1 5183 PLUMBING NOC & DRIVERS 5645 CARPENTRY-DETACHED ONE OR TWO FAMILY DWELLINGS Office and Clerical 8810 CLERICAL OFFICE EMPLOYEES NOC 8742 SALESPERSONS, COLLECTORS OR MESSENGERS-OUTSIDE 8832 PHYSICIAN & CLERICAL 8833 HOSPITAL: PROFESSIONAL EMPLOYEES 8601 ARCHITECT OR ENGINEER- CONSULTING Goods and Services 8017 STORE: RETAIL NOC 9015 BUILDINGS-OPERATION BY OWNER OR LESSEE 9014 BUILDINGS-OPERATION BY CONTRACTORS 8018 STORE: WHOLESALE NOC 9082 RESTAURANT NOC/CATERER Miscellaneous 7229 TRUCKING-LONG DISTANCE HAULING-& DRIVERS 7228 TRUCKING-LOCAL HAULING ONLY-& DRIVERS 9102 PARK NOC-ALL EMPLOYEES & DRIVERS 7219 TRUCKING: NOC-ALL EMPLOYEES & DRIVERS 7720 POLICE OFFICERS & DRIVERS F-Class 6824 BOAT BUILDING OR REPAIR & DRIVERS 6826 MARINA & DRIVERS 6872 SHIP REPAIR CONVERSION-ALL OPERATIONS & DRIVERS 8709 STEVEDORING: TALLIERS AND CHECKING CLERKS ENGAGED IN CONNECTION WITH STEVE- DORE WORK 6843 SHIP BUILDING-IRON OR STEEL-NOC & DRIVERS CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded Policy years 2004-2010 77

Leading Class Codes for Non-PEO Policies Industry Group Top Governing Class Code by Number of Unit Reports Description Manufacturing 3632 MACHINE SHOP NOC 4299 PRINTING 4484 PLASTICS MANUFACTURING: MOLDED PRODUCTS NOC 2812 CABINET WORKS-WITH POWER MACHINERY 3681 TELEVISION, RADIO, TELEPHONE OR TELECOMMUNICATION DEVICE MFG. NOC Contracting 5606 CONTRACTOR-EXECUTIVE SUPERVISOR OR CONSTRUCTION SUPERINTENDENT 1 5190 ELECTRICAL WIRING-WITHIN BUILDINGS & DRIVERS 5183 PLUMBING NOC & DRIVERS 3724 MACHINERY OR EQUIPMENT ERECTION OR REPAIR NOC & DRIVERS 5474 PAINTING OR PAPERHANGING NOC & SHOP OPERATIONS, DRIVERS Office and Clerical 8810 CLERICAL OFFICE EMPLOYEES NOC 8742 SALESPERSONS, COLLECTORS OR MESSENGERS-OUTSIDE 8832 PHYSICIAN & CLERICAL 8868 COLLEGE: PROFESSIONAL EMPLOYEES & CLERICAL 8601 ARCHITECT OR ENGINEER- CONSULTING Goods and Services 8017 STORE: RETAIL NOC 9015 BUILDINGS-OPERATION BY OWNER OR LESSEE 9014 BUILDINGS-OPERATION BY CONTRACTORS 8018 STORE: WHOLESALE NOC 9052 HOTEL: ALL OTHER EMPLOYEES & SALESPERSONS, DRIVERS Miscellaneous 9102 PARK NOC-ALL EMPLOYEES & DRIVERS 7720 POLICE OFFICERS & DRIVERS 9402 STREET CLEANING & DRIVERS 9403 GARBAGE, ASHES OR REFUSE COLLECTION & DRIVERS 7382 BUS CO.: ALL OTHER EMPLOYEES & DRIVERS F-Class 6824 BOAT BUILDING OR REPAIR & DRIVERS 6826 MARINA & DRIVERS 8709 STEVEDORING: TALLIERS AND CHECKING CLERKS ENGAGED IN CONNECTION WITH STEVE- DORE WORK 6872 SHIP REPAIR CONVERSION-ALL OPERATIONS & DRIVERS 7317 STEVEDORING: BY HAND OR HAND TRUCKS EXCLUSIVELY CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded Policy years 2004-2010 78

Modified Loss Ratios for 2007 by Industry Group: PEO versus Non-PEO Policies Residual and Voluntary Markets Loss Ratios Higher in Residual Market: PEOs and Non-PEOs Loss Ratios Moderately Higher in Residual Market: PEOs Loss Ratios Materially Greater in Residual Market: Non-PEOs 79

In the Voluntary Market Lost-Time Claims Loss Ratio Modified Premium PEOs Higher than Non-PEOs for Miscellaneous Voluntary Market, Policy Year 2007, @2nd Report PEOs Non-PEO 1.20 Lost Time Claims Loss Ratio by Modified Premium 1.00 0.80 0.60 0.40 0.20 0.00 Manufacturing Contracting Office & Clerical Goods & Services Miscellaneous CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 80

In the Residual Market Modified Premium Loss Ratios Lower for PEOs In All but Miscellaneous Policy Year 2007, @2nd Report PEOs Non-PEO 1.20 Lost Time Claims Loss Ratio by Modified Premium 1.00 0.80 0.60 0.40 0.20 0.00 Manufacturing Contracting Office & Clerical Goods & Services Miscellaneous CA, DE, MA, MI, MN, NJ, NY, NC, ND, OH,PA, WA, WI, and WY are excluded in voluntary market analysis AK, AL, AR, AZ, CT, DC, GA, ID, IL, IN, IA, KS, MS, MO, NE, NV, NH, NM, OR, SC, SD, TN, VT, VA, and WV are included in residual market analysis NCCI is not the residual market plan administrator in IN, TN, MO, and NE 81

Observations

Observations Regulation of PEOs has increased steadily over the past 20 years Across all NCCI states in total, PEOs account for a relatively small share of all workers covered by workers compensation PEOs are responsible for a material portion of employment in some states; especially in residual markets Reported frequency is typically higher for PEO policies suggesting that there is no compelling evidence that PEOs underreport claims Comparable loss ratios for PEO and Non-PEO policies suggests that there is no compelling evidence of inappropriate reporting of payroll and premium 89

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