WCIS eNews No. 51
December 29, 2005
WCIS reporting problems
The purpose of this eNews is to inform DWC's trading partners about data
reporting problems in connection with DWC's Workers' Compensation Information
System, and to elicit suggestions and support for rectifying these problems.
DWC's WCIS has been collecting FROI and SROI claims data from California
claims administrators using national reporting standards developed by the
IAIABC since 2000. Currently, WCIS has FROI reports for more than 4.6 million
claims. Meanwhile, DWC has some SROI information for about 850,000 claims,
or only half of the expected number of indemnity claims.
DWC staff has been monitoring and analyzing trading partner compliance with
WCIS reporting requirements since the inception of the system. In 2002, a
thorough comparative analysis of reported claim information to the WCIS and
DWC's Audit Unit (via its Annual Report of Inventory) was performed. Unfortunately,
that analysis supported accumulating anecdotal information and conclusions
drawn from prior examinations of data submitted to the WCIS, which indicated
that there was a serious compliance problem with TP data reporting.
On the basis of the 2002 analysis, the EDI Unit contacted about two-dozen
major companies/entities that were not reporting FROI and/or SROI information
to the WCIS on a timely, complete and accurate basis. The objective was to
work with these trading partners to get them "on track".
Currently, DWC is completing a similar analysis to that performed in 2002,
as well as making a systematic comparison of the reporting compliance among
trading partners' submissions of annual (AN) and final (FN) data transactions
to the WCIS.
Here are the major conclusions from DWC's recent analyses of trading partners'
WCIS data reporting performance:
There are some TPs who are doing an outstanding job
with respect to reporting data accurately and on a timely and complete basis
The small list of fully complying TPs includes both
claims administrators with a large number of annual claims handled and those
with only a few.
A significant majority of reporters are not reporting
SROI data, in particular, according to DWC's standards as stated in the
California Implementation Guide for FROI and SROI Reporting.
Naturally, the question arises--why is the reporting problem so significant,
particularly for incomplete and inaccurate reporting of SROI data? There are
several candidate hypotheses and reasons for discrepancies:
FROI reporting is relatively simple compared to SROI
Prior to WCIS, TPs were required to submit FROI in
paper form, and could simply and inexpensively use a vendor to report electronically
when electronic reporting became mandatory
For SROI data, TPs have had to invest in computer
systems and claim administrator training to submit data that are subject
to sequencing rules, generating significant additional costs for complying
with reporting requirements (An overwhelmingly high cost of compliance appears,
however, not to be the major factor since both small and large companies
comply/do not comply, and there appear to be a variety of vendors offering
a menu of service choices at competitive prices.)
A lack of knowledge about what to send and actually
having the information to send even though (a) the information required
to be sent to the WCIS is part of the claim file, (b) the WCIS data program
requirements have been in place since 2000, and (c) a significant amount
of training has been offered
A Cost-to-Benefit determination as TPs see little
or no benefit from complying with reporting regulations, and there is no
cost (such as a penalty) for not complying
High turnover of claim administrators and clerical
reporting support, and little or no training and support to replacement
personnel to enable them to provide the required data on a timely, complete
and accurate basis
Lack of sense of urgency since there are no deadlines
Some TP's stop sending data because they are in the
middle of switching or upgrading their systems
Scope of Authority Issues-ability of line level staff
to improve reporting practices or obtain needed resources
Given the above list of candidate reasons for under-reporting, or not reporting
accurately or at all to the WCIS, what are some potential ways of addressing
these issues to improve reporting performance? The following is a list of
suggested ways to improve TP reporting compliance:
Training--offer additional training and educational
programs to TPs on California-specific data submission protocols
Best Practices--obtain system profiles from the exemplary
organizations, and share that information with other TPs as "system
templates of what works"
Penalties--increase the cost of TP non-compliance
with statutory penalties
Survey of TPs--find out why various TPs are out of
compliance with WC regulations, and solicit/implement TP suggestions for
solving observed problems
User Groups--create electronic forums to address TP
and DWC concerns and to share solutions to problems
Address the cost issue--simplify the WCIS and have
DWC offer a host FTP option to lower the cost of data transmissions
All of the solutions listed above are intermediate or long-term solutions.
Meanwhile, given the strong likelihood that some TPs will not be able to send
accurate AN transmissions in January, DWC is considering the temporary use
of the UR MTC. However, this option needs to be carefully planned and implemented
so as to avoid abuse.
In order to address the concerns listed in this eNews, as well as others that
TPs may have in mind, DWC earnestly requests that the TP community respond
to this email by sending feedback and ideas for making improvements to the
system to the EDI liaison team. Thank you in advance for your participation.
If you have any questions or comments, please contact your Trading Partner
contact, listed below.
Trading Partner Letters C, G, H, M, P-R
Trading Partner Letters B, D-F, N, O, W-Y
Trading Partner Letters A, I-L, S-V, Z
Contents of this bulletin do not change existing regulatory
requirements; they provide additional or revised detail about the technical
implementation of those requirements. All technical changes will subsequently
be reflected in other WCIS documentation. Any bulletin can be forwarded as
needed, but should be forwarded in its entirety and without modification.
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