The Louisiana Insurance Department (“Department”) recently revised and reissued Bulletin 07-01 to make all insurers, Health Maintenance Organizations (“HMO’s”) and Third Party Administrators (“TPA”) and provided updated requirements for catastrophe response plans. Specifically, effective January 1, 2023, all insurers, HMO’s and TPAs, are required to maintain a catastrophe response plan that describes how the insurer, HMO or TPA will respond to a catastrophe affecting policyholders in Louisiana. Catastrophe response plans must be submitted to the Department no later than June 1, 2023 through the Department’s online portal. Additionally, the catastrophe response plans will be considered confidential and proprietary information subject to the protections of the Louisiana Uniform Trade Secrets Act and shall not be subject to public records disclosure or made public by the Department.
The catastrophe response plans should include the following information:
- Emergency contact information of key or essential personnel.
- Alternative office locations or work sites likely to be used in the event of a catastrophe
- Procedures to address the following:
- The backup, storage, retrieval and security of records and data are used to adjust claims.
- The handling and processing of claims, whether prior to or subsequent to the catastrophe.
- Relevant training of staff.
- Communication with agents, policyholders, and subscribers, in the event of mail delivery or other communication system disruption. Such communication shall address, at a minimum, the process for filing a claim and the method whereby an agent, policyholder, or subscriber can obtain information concerning a claim.
- The distribution of catastrophe claims information to policyholders or subscribers.
- Considering the scale of the catastrophe and the number of policies issued in the affected area, the methodology for determining the following:
- The approximate number of field adjusters, desk adjusters, and other administrative personnel necessary to respond to the catastrophe.
- The process through which the insurer will provide claims and administrative personnel to service policyholder and subscriber needs in a timely manner.
The process through which the insurer will provide logistical support for claims and administrative personnel in the area affected by the catastrophe.