On March 1, 2024, the National Council on Compensation Insurance (NCCI) announced that it is reducing the participation eligibility threshold for reporting both the Medical Data Call (“MDC”) and Indemnity Data Call (“IDC”).[1] NCCI announced this change via circulars FYI-MED-2024 and FYI-IDC-2024-01, respectively, both dated March 1, 2024. As discussed below, this expansion becomes effective starting 4th Quarter 2024 for the IDC and 4th Quarter 2025 for the MDC. Overall, NCCI’s lowering of the eligibility threshold for IDC and MDC reporting means that more carriers will now be required to report under both data calls.
The following provides an overview of NCCI’s upcoming data call expansion, claims impact, and how Verisk can help:
NCCI lowers eligibility threshold for MDC and IDC reporting
Currently, NCCI’s MDC and IDC reporting requirements apply to member groups with a premium market share of at least 1.0% in any one applicable state over the most recent three years.[2] Per NCCI’s new release, this threshold amount is being reduced to at least .5%. Specifically, NCCI states as follows: “NCCI is updating the participation eligibility percent threshold for the Indemnity Data Call [and Medical Data Call] reporting from at least 1% market share in any one applicable state over the most recent three years (overall average equals 1% or more) to at least .5% market share in any one applicable state over the most recent three years (overall average equals .5% or more).”[3] NCCI further states that “[o]nce an affiliate group meets the eligibility criteria, the affiliate group is required to report for all applicable states in which it writes, even if an individual state’s market share is below the threshold.”[4]
NCCI’s Implementation and timelines
NCCI’s planned MDC and IDC reporting expansion becomes effective starting 4th Quarter 2024 for the Indemnity Data Call and 4th Quarter 2025 for the Medical Data Call.
NCCI will implement its MDC and IDC reporting expansion in two phases as follows:
Phase 1 IDC: Those carries that now fall within the 0.5% threshold are required to begin reporting to the NCCI with all indemnity data occurring in Q4 2024 which is due by March 31. 2025.[5] The NCCI will contact all newly eligible carriers who are now required to report due to the change in participation threshold.
Phase 2 MDC: Those carriers that now fall within the 0.5% threshold are required to begin reporting the NCCI with all medical data occurring in Q4 2025 due by March 31, 2026.[6] The NCCI will contact all newly eligible carriers who are now required to report due to the change in participation threshold.
NCCI signals additional IDC and MDC expansion in the future
It is important to note that NCCI’s new circulars also indicate that additional data call expansions are planned. Specifically, NCCI indicates that it “expects to continue expansion” of IDC and MDC reporting “regardless of market share” in the future.[7] NCCI has provided no further details or projected timelines at this point. Thus, it will be important to continue to monitor NCCI for any future updates on this front.
Time to get ready – how Verisk can help!
NCCI’s forthcoming expansion of the MDC and IDC data calls is significant in that reporting will now impact a larger segment of the industry as more carriers will now need to report. As many will recall, last year New York removed their eligibility reporting thresholds altogether. It now appears that NCCI may also be heading in this direction with its newly announced threshold reduction outlined above, and its noted plans for additional IDC and MDC reporting expansion in the future. Against this backdrop, it will be interesting to see if other Data Collection Organizations will also follow suit.
Now is the time for insurers to start making the applicable preparations to comply with NCCI’s new requirements. The good news is that Verisk can help! If you are currently reporting IDC and/or MDC via our wcPrism solution for states other than NCCI we can help you comply with this new requirement. If you are not currently reporting through wcPrism, we would certainly look forward to setting up a call to discuss our solution and help you with all your state workers’ compensation reporting!
Please contact me at Nicholas.guarda@verisk.com or 732.887.7556 for questions or to set up a call to discuss how Verisk can help you address these forthcoming changes.
[1] Regarding the Medical Data Call (MDC), NCCI began collecting medical transactional data via the MDC in 2010 with all medical transactions occurring in Q3 2010 due by December 31, 2010. NCCI Circular DR-2008-01 “Data Reporting – New Medical Data Call – Effective 3rd Quarter 2010” (Page 1 of 2). NCCI established the Medical Data Call in efforts to help state regulators and legislators “support in the analysis and pricing of their medical cost containment solutions.” Id. Upon adopting the MDC, the NCCI established that “participation will be limited to affiliate groups with at least 1% market share in any one NCCI state over the most recent three years (overall average= 1% or more).” NCCI Circular DR-2008-01 “Data Reporting – New Medical Data Call – Effective 3rd Quarter 2010” Attachment A.
Regarding the Indemnity Data Call (IDC), NCCI began collecting indemnity transactional data via the IDC in 2020 with all indemnity transactions occurring in Q2 2020 due by September 30, 2020. NCCI Circular IND-2018-01 “Indemnity Data Call – New Indemnity Data Call Effective Second Quarter 2020”. (Page 1 of 3). The NCCI notes that the IDC “is intended to provide the source data that would primarily be used for legislative pricing related to indemnity benefits.” Id. Upon adopting the IDC, the NCCI established that “participation will be based on affiliate groups that have at least 1% market share in any one applicable NCCI state over the most recent three years (overall average equals 1% or more).” Id.
[2] NCCI Circular IND-2018-01 “Indemnity Data Call – New Indemnity Data Call Effective Second Quarter 2020”. NCCI Circular DR-2008-01 “Data Reporting – New Medical Data Call – Effective 3rd Quarter 2010.”
[3] NCCI Circular MED-2024-01 “Expansion of Medical Data Call Participation” and NCCI Circular IND-2024-01 “Expansion of Indemnity Data Call Participation.”
[4] Id.
[5] NCCI Circular IND-2018-01 “Indemnity Data Call – New Indemnity Data Call Effective Second Quarter 2020.”
[6] NCCI Circular MED-2024-01 “Expansion of Medical Data Call Participation.”
[7] On this point, regarding the MDC, NCCI states that “[i]n the future NCCI expects to continue expansion for participation in the Indemnity Data Call requiring all affiliate groups, regardless of market share, to report Medical data. NCCI Circular MED-2024-01 “Expansion of Medical Data Call Participation.” Similarly, the NCCI indicates future IDC expansion stating that “[i]n the future NCCI expects to continue expansion for participation in the Medical Data Call requiring all affiliate groups, regardless of market share, to report Indemnity data.” NCCI Circular IND-2024-01 “Expansion of Indemnity Data Call Participation.”