The Actuary and Enterprise Data Strategies CAS MAY 2006 Part II: How Do We Get There? Agenda Data Management Best Practices and Guidelines Standards Straight-Through-Processing Information Quality and Assurance Sarbanes-Oxley and other Regulations Questions and Commentary 2 Panelists Pete Marotta, ISO Gary Knoble, USABFS Bruce Tollefson, MN WC Rating Bureau Christine Siekierski, WI Comp. Rating Bureau Art Cadorine, ISO Data Management Best Practices and Guidelines 4 Data Management Best Practices Data Stewardship – establish a corporate data steward Data and Data Quality Standards – foster the development and adoption of data and data quality standards Organizational Issues – structure organization to promote good data management and data quality 5 Data Management Best Practices Operations and Processes – establish processes to maximize data quality and utility Data Element Development and Specification – design and maintain data, systems and reporting mechanisms in a manner that promotes good data management and data quality 6 10 Guidelines of Data Management 1. 2. Data must be fit for the intended business use. Data should be obtained from the authoritative and appropriate source. 7 10 Guidelines of Data Management 3. 4. Data should be input only once and edited, validated, and corrected at the point of entry. Data should be captured and stored as informational values, not codes. 8 10 Guidelines of Data Management 5. 6. Data should have a different steward responsible for defining the data, identifying and enforcing the business rules, reconciling the data to the benchmark source, assuring completeness, and managing data quality. Common data elements must have a single documented definition and be supported by documented business rules. 9 10 Guidelines of Data Management 7. 8. Metadata must be readily available to all authorized users of the data Industry standards must be consulted and reviewed before a new data element is created 10 10 Guidelines of Data Management 9. 10. Data must be readily available to all appropriate users and protected against inappropriate access and use Data users will use agreed upon common tools and platforms throughout the enterprise 11 Standards 12 What are Standards? Definition: Standard (n.) “Anything recognized as correct by common consent, by approved custom, or by those most competent to decide; a model; a criterion.” -- Webster’s New Universal Dictionary 13 Types of Standards Business Models – Identify All the Major Processes and Relationships Common Insurance Terminology Coverage and Forms Process Standards – Application Forms, Report of Injury or Claim, Licensing, etc. 14 Types of Standards (Continued) Other – Solvency Standards – Financial Information Exchange Standards – Market Conduct Information Standards – Ratemaking Standards – Operating Data Standards – Data Exchange/Reporting Standards – Data Quality Standards – Data Element and Code List Definitions At one time actuaries drove many of these standards. 15 Business Process A business process is a collection of related structural activities that produce something of value to the organization, its stake holders or its customers. It is, for example, the process through which an organization realizes its services to its customers. 16 Business Rules Business rules describe the operations, definitions and constraints that apply to an organization in achieving its goals. For example a business rule might state that no credit check is to be performed on return customers. 17 Need for Industry Collaboration Submission Insurance Carriers Broker/Insurer Regulatory Compliance Ins/Reinsurer Claims Regulatory Authorities Reinsurer Claims Management Applications Auditing Insurance Agency Premium transactions Payment transactions Service Providers Agent/ Producer 18 Benefits of Industry Data Standards Submission Insurance Carriers Regulatory Compliance Broker/Insurer Ins/Reinsurer Reinsurer Claims Management Applications Insurance Agency Claims Regulatory Authorities STANDARDS & IMPLEMENTATION Premium transactions Payment transactions Auditing Service Providers Agent/ Producer 19 Straight-ThroughProcessing 20 New Processes: The Goal – Single Entry A Real Time data entry B Download Solution Carrier Provider/Vendor B – Carrier processes data, synchronizes with agency data base through download Producer/ agent/ Broker A – Form/Msg from Producer (agent/broker) to Carrier Producer either waits for download, or does data entry to process binder, ID cards, certificates. Re-use of data “enabler” Service Provide r Reinsurer C D D – Data may continue along the process to be used by Reinsurers, etc. C – Messages from Carrier to Service Providers (CLUE, MVR) 21 Straight Through Processing (STP) The use of common, industry standard data elements, throughout all interactions of all parties, in all insurance transactions or processes. STP allows data to flow effortlessly through the industry without redefinition, mappings or translations. 22 STP Value Improves data quality, utility – better benchmarking Lessens data translations, eliminates return transactions for clarification Reduces friction in insurance processes Allows companies to differentiate on value added Facilitates “plug and play” solutions 23 STP Benefits Improved Customer Relationship – Less Time Processing Ease of Doing Business Retention and Growth Profitability 24 Information Quality and Assurance 25 Data Quality Data Quality is defined as the process for ensuring that data are fit for the use intended by measuring and improving its key characteristics. 26 PWC 2004 Study “Data quality is at the core – if you improve your data you will directly impact your overall business results.” Global Data Management Survey 2004, PriceWaterhouseCoopers 27 Managing Data & Data Quality: Guiding Principles Data is a corporate asset Data should be fit for the use intended Data should flow from underlying business processes Data quality should be managed as close to the source as possible Best Practices are ever evolving 28 Data Quality: Key Characteristics Fit for its intended use Accuracy Validity Timeliness and Other Timing Criteria Completeness or Entirety Reasonability Absence of Redundancy Accessibility, Availability and Cohesiveness Privacy 29 Data Transparency: Key Characteristics Data defined and documented Utility across time and source Supports internal controls. Clear, standardized, comparable information Facilitates assessment of the health of the systems using the data Promotes better controls Improves operational and financial performance Documents data elements, data element transformations and processes 30 PWC 2004 Study “With over half of respondents admitting they are at least ‘somewhat’ dependent on third-party data, and regulators pressing for greater reliability and integrity, the need to build greater general confidence in data quality is clear.” Global Data Management Survey 2004, PriceWaterhouseCoopers 31 ASOP #23: Data Quality Purpose is to give guidance in: – Selecting data – Reviewing data for appropriateness, reasonableness, and comprehensiveness – Making appropriate disclosures Does not recommend that actuaries audit data 32 ASOP #23: Data Quality Considerations in Selection of Data Appropriateness for intended purpose Reasonableness, comprehensiveness, and consistency Limitations of or modifications to data Cost and feasibility of alternatives Sampling methods 33 ASOP #23: Data Quality Definition of Data Numerical, census, or class information Not actuarial assumptions Not computer software Definition of comprehensive Definition of appropriate 34 ASOP #23: Data Quality Other Considerations Imperfect Data Reliance on Others Documentation/Disclosure 35 PWC 2004 Study “Only 24% of those making any use of third party data make any effort to measure the quality of that data, with most frequently cited methods including auditing/validation (25%), comparison with other known data (20%) and use of internal tools (15%).” Global Data Management Survey 2004, PriceWaterhouseCoopers 36 PWC 2004 Study Top 6 data quality initiatives: Improve data accuracy (26%) More rigorous data management (14%) System upgrade (13%) Improving security (11%) Data standardisation (10%) Improving usage/analysis of data (10%) Global Data Management Survey 2004, PriceWaterhouseCoopers 37 Sarbanes Oxley and Other Regulations 38 Accountability, Quality, Transparency Regulations Sarbanes Oxley – US law ensuring accuracy of financial data with accountability of company executives Solvency II – EU proposal similar to SOX addressing financial reporting and public disclosure Reinsurance Transparency – International Association of Insurance Supervisors working group to explore solvency of reinsurers worldwide. Differences in data definitions are presenting a challenge 39 What Is Sarbanes Oxley? “Sarbanes-Oxley Act of 2002” Also known as “Public Company Accounting and Investor Protection Act of 2002” Passed in response to notorious misstatements in financial statements (Enron, Tyco, WorldCom, etc.) Aims to correct perceived structural weaknesses in financial reporting and corporate governance leading to greater financial transparency Created new regulatory body overseeing accountants auditing public companies 40 What Does It Mean? Primarily applies to publicly traded companies Stronger, more independent Board audit committees Greater pressure on CEO’s & CFO’s to issue accurate financial reports Increased scrutiny by regulators, stockholders, rating agencies and the public Greater restrictions on activities & relationships of auditing firms More work . . . Lots more work . . . For publicly traded companies 41 “SOX 404” Requirements Management’s annual internal control report must contain: • A statement of management’s responsibility for establishing and maintaining adequate internal control over financial reporting for the company • A statement identifying the framework used by management to evaluate the effectiveness of this internal control 42 “SOX 404” Requirements (Cont.) Management’s assessment of the effectiveness of this internal control as of the end of the company’s most recent fiscal year. A statement that its auditor has issued an attestation report on management’s assessment. Do these requirements extend to processes and data under the purview of the actuary? 43 A Project Approach 1. Establish methodology, approach and scope of project 2. Document • Develop control documentation and testing plans • Facilitated sessions to perform quality review 3. Assess • Evaluate design of controls • Evaluate effectiveness of controls through testing and selfassessment • Modify/Improve controls 4. Monitor • Remediation of any “GAPS” identified • Validation performed of self assessment results • Evaluate overall effectiveness 5. Certify • Management Annual Report on internal controls. • Independent testing and attestation by External Auditor 44 Impact of “SOX” on Actuary and the Data Manager Processes and controls – Data control and reconciliation – Systems testing – Testing and assessment Data Quality and Data Transparency are key Documentation 45 Impact of “SOX” on Actuary and the Data Manager Strategic Planning – Ensure that proper controls and framework are built into long range strategies – The use of industry standards encourages the use of consistent methodologies across the enterprise – Good long range strategies result on better data quality and data transparency 46 Impact of “SOX” on Actuary and the Data Manager Compliance –Ongoing efforts to meet compliance requirements results in higher confidence that proper controls are in place –Meeting compliance requirements results in better data quality 47 Impact of “SOX” on Actuary and the Data Manager The importance and visibility of Data Management among senior executives and regulators has increased. The importance of Data as an important corporate resources has increased. The contribution of Data Management to proper data and process control is more widely recognized. The demand for data quality has increased. 48 References, Resources & Studies Celent “ACORD XML Standards in US Insurance”: www.celent.com or www.acord.org IDMA: www.idma.org PWC “Global Data Management Survey 2004” and “Global Data Management Survey 2001” : www.pwcglobal.com Gartner Research: www4.gartner.com TDWI “Data Quality and the Bottom Line”: www.dw-institute.com CIO Magazine: “Wash Me: Dirty Data …” 2-1501 edition, www.cio.com 49 PWC 2004 Study “It is one thing to address mounting privacy and regulatory requirements with a tactical update to control processes – it is quite another to step out ahead of the industry and gain competitive advantage… The key is to understand the impact data is having on your business and do something about it.” Global Data Management Survey 2004, PriceWaterhouseCoopers 50 Questions and Commentary 51