Chapter 9

Administration of Laws

And Enforcement

 

 

  Most agents are honest, hard working people.  Unfortunately they must jump through some legal hoops as a result of those who are not.

 

California Regulations

 

  As types of care change, so may regulations.  Regulations change for a variety of reasons, but as they relate to insurance, the fair treatment of consumers is usually the primary reason.

 

Authority To Bring Actions and Access Penalties

 

  The California Commissioner, in addition to all other powers and remedies available to him, has the administrative authority to assess the penalties for violation of any provision committed in California by insurers, brokers, agents, and other entities, which have been determined by the Commissioner to be engaged in the business of insurance.  10234.2 (a)

 

  A court may also assess penalties prescribed by law for any violation in any civil action. The court may award reasonable attorneys fees and costs to a prevailing plaintiff who establishes a violation.  10234.2 (b)

 

  Actions for injunctive relief, penalties prescribed by California law, damages, restitution, and all other remedies in law or equity may be brought in superior court by the Attorney General, a district attorney, or city attorney on behalf of the people of the California for violation of any legal provision.  Reasonable attorney fees and court costs may be awarded to the prevailing plaintiff.  10234.2 (c)

 

Penalties

 Penalties

The Agent

  The Insurance Commissioner will determine fines.  They are levied against any broker, agent or other entity that engages in the business of insurance.  Fines are levied in the following amounts:

 

1.    Not less than $250, for an agents first violation;

2.    Not less than $1,000, but not more than $25,000 for an agents subsequent or knowing violation;

3.    Not more than $5,000 per violation for inappropriate replacement.

 

The Insurer

  Fines may also be levied against an insurer by the Commissioner in the following amounts:

1.    Not less than $5,000, for an insurers first violation;

2.    Not less than $10,000, for an insurers subsequent or knowing violation;

3.    Not less than $10,000, but not more than $500,000 for an insurers general practice.

 

  Penalties will be paid into the Insurance Fund.  10234.3 (a)(b)(c)

 

Non-Penalty Actions

  The Commissioner may elect to take other measures following the determination that a violation has occurred, including:

1.    Suspend or revoke the agents insurance license.

2.    Suspend the insurers Certificate of Authority, which allows them to transact disability insurance.

3.    Order any broker, agent, insurer, or other entity engaged in the business of insurance to cease marketing a particular policy form of long-term care insurance in that is not in compliance with Californias requirements.  10234.4 (a)(b)(c)

 

Due Process Is Required

  When a person or company has been charged with a violation by the California Insurance Department they must be afforded due process through proper notice and public hearing, if requested, before the penalty is actually assessed.  10234.5 (a)

 

Requirement For Written Notice

  The written notice of the violation must be sent by registered mail and must include:

1.    of the facts establishing reasonable cause that a violation has happened.

2.    A citation of the code section or other standard allegedly violated.

3.    A statement of the Commissioners intent to assess a penalty, which must include the amount of the penalty, or his intent to seek another remedy.

4.    A statement of the respondents right to elect any of the following:

        Acceptance of the penalty or other remedy as stated in the notice.

        Respond to the charge in writing, after which the Commissioner will issue a final order or set a hearing.

        Request a public hearing within 10 days of receipt of the notice. 

10234.5 (b)

 

 

Public Hearing Within 30 Days

  A public hearing, if requested within the required time, must be held before the Administrative Law bureau of the department within 30 days after the notice is served.  Within 20 days after the hearing, the administrative law judge must issue findings of fact and a proposed order.  Unless reconsideration is given for good cause by the administrative law judge, either the proposed order or an order issued by the Commissioner must become the final order within 30 working days following the hearing.  10234.5 (c)

 

  If a penalty of $100,000 or more is imposed, and the respondent has timely requested, the hearing must be conducted in accordance with the Government Code and the commissioner has all the powers granted therein.  The actual amount of the penalty is not limited to the amount stated in the notice to the respondent.  It could be more.  The Commissioner could also, in addition to penalties, suspend an insurers certificate of authority if the Commissioner finds, after proper notice and hearing, that the insurer has violated regulations or laws or that the insurer knowingly permitted any person or entity of theirs to do so.

 

  Section 704 of the Insurance Code states that the Commissioner may suspend the certificate of authority for one year or less (following a proper hearing notice) if it is determined that the insurer engaged in any of the following:

        Fraudulently conducting their business

        Not carrying out their contracts in good faith

        Habitually, as an ordinary practice or custom, compelled their claimants under their policies, or liability judgment creditors of the insured, to either accept less than the amount due under the terms of the policies or resorted to litigation against the insurer in order to secure payment of the amount due.

 

  In any proceeding brought under Section 704 of the Insurance Code for violations cited in that section the Commissioner may permit an insurer to pay a fine (not to exceed $55,000) as an alternative to the suspension of the insurers certificate of authority.

 

Consumer Rate Guide

 

  By June first of each year, the commissioners office must design the format and content of a consumer rate guide for long-term care insurance with a working group that include representatives of the Health Insurance Counseling and Advocacy Program (HICAP), the insurance industry, and insurance agents.  The commissioner must prepare this rate guide each year for the long-term care industry.

 

  The guide will contain several things:

        A comparison of the different types of long-term care insurance and coverage available in California.

        A premium history of each insurer that writes long-term care contracts for all the types available with each insurer.  10234.6 (a)

 

  There will be two parts to the Consumer Rate Guide: a history of the rates for all policies issued in the US on or after January 1, 1990, and a comparison of the policies, benefits, and sample premiums for all those issued in California.

 

Annual Report to the Legislature

  The California Commissioner prepares an annual report to the Legislature, which must be compiled in consultation with a task force selected by the Commissioner for this purpose.  This task force must include insurance industry representatives, other individuals deemed appropriate and one or more representatives from each of the following:

1.    The Health Insurance Counseling and Advocacy Program, and

2.    The California Health Policy and Data Advisory Commission.  10234.7

 

End of Chapter Nine