- Getting Ready to Review COIs for Compliance with Customer Notes
- Reviewing Basic Details of COIs for Compliance
- Section by Section COI Review for Compliance
- What About the Description of Operations and Endorsements?
- Communicating Gaps to Customers
- Comparing Our Review Standards to Competitors
- Putting Jones Insurance Experts Like Jessica to Work for You
Note: interested in exploring how Jones can help you automate your compliance management end-to-end and de-risk your building? Talk to our team of experts today!
Today we follow Jessica Lopes, Senior Auditing Operations Manager, as she audits a COI.
Getting Ready to Review Certificates of Insurance for Compliance with Customer Notes
During our auditing standards review call Jones works with customers to create specific instructions on stringency of certificate of insurance review standards, requirement sets, how to handle gaps, and more. These notes are all available to auditors in the backend of our system and are the first thing Jessica reads when she goes to review a COI for a customer. From these she’ll immediately know key details for auditing the company’s COIs, such as whether or not to accept blanket Additional Insured, whether there are requirements that do not need to be enforced, and if any alternative Certificate Holders can be accepted, for example.
Next, Jessica will check the totality of insurance documents in the COI upload. Sometimes customers upload multiple COIs at once, old and new COIs at the same time, secondary policies, endorsements, or a variety of different Acord forms. Jessica will go to work reconciling all these different documents, determining the importance of each and how it fits into the larger insurance risk strategy of the organization. Jones has policies in place to group files depending on expiration and relevance, which sets the stage for the audit Jessica is about to conduct.
Reviewing Basic Details of Certificates of Insurance for Compliance
Jessica starts her certificate of insurance review by knocking out a few key components of the COI: Insured Name, Issue Date, Certificate Holder, and Additional Insured.
⏳ 30 seconds
For Insured Name, Jessica will be relatively lenient when it comes to marking gaps here, unless otherwise specified by a customer. Why? Some organizations will be insured under a different name, potentially operating their business under what is called a “Doing Business As” name or being included under the insurance policies of their parent organization.
This example is pretty straightforward, so Jessie marks it compliant.
⏳ 10 seconds
One of the easiest parts of the process to check for compliance, the Issue Date is easily locatable in the top right corner of the COI and is entered into the system by our auditors. As in the prior example, Jessica will go ahead and mark this compliant.
⏳ 1 Minute
Jones is very strict when it comes to matching Certificate Holder to customer requirements, so Jessica will approach this one with a fine toothed comb. Any slight variation or misspelling of the required Certificate Holder will be flagged as a gap in our system. We are open to customers requesting Jones to broaden what should be considered compliant. In the following example Jessica marks Certificate Holder noncompliant unless otherwise instructed by the customer during the auditing standards review call due to the discrepancy in names.
⏳ 2 Minutes
Jones is equally stringent when it comes to specificity of Additional Insured. As a standard practice, Jones only checks the Additional Insured status to be conferred in regard to the General Liability policy. Why? It is not a standard practice to have Additional Insured coverage added to Automobile and Umbrella Liability, or Property Insurance. It’s also not allowed to add Additional Insured coverage to Employer’s Liability or Workers’ Compensation policies. If a customer wants us to track Additional Insured status on other policies Jessica would consider either checkboxes on the ACORD 25 or the coverage detail listed in the Description of Operations box to be sufficient for that conclusion.
Blanket Additional Insured is another matter entirely. As this verbiage enables a policyholder to extend coverage to multiple third parties without having to specifically name or request such status for each entity on the COI it’s crucial that any gaps are flagged. When it comes to Blanket Additional Insured Jessica cannot determine whether this is acceptable or not in lieu of having the Additional Insured entities’ names listed on the COI. If our customer does wish for Jones to accept Blanket Additional Insured language they must also clarify if it must be evidenced in the verbiage in the Description of Operations box of a COI, the verbiage of an Additional Insured endorsement, or both.
In the following example, the Additional Insured listed in the Description of Operations exactly matches the required name, so Jessica marks it as compliant.
Section by Section Certificate of Insurance Review for Compliance
After knocking out Insured Name, Issue Date, Certificate Holder, and Additional Insured Jessica will continue her audit moving down the COI section by section. First stop, General Liability.
⏳ 1 Minute
Commercial General Liability (GL) is the most common policy we see on COIs. The first requirement Jessica will have to examine is whether or not coverage exists in the following GL section.
This is a breeze for her, as all she needs to confirm the policy exists is examine if the GL row of the policy table is filled in with data, like a policy number and expiration date.
Next, Jessica will move on to checking the limits for the GL policy. This COI evidences policies with higher limits than the required 1 million USD each occurance and 2 million USD general aggregate, so Jessica will mark those as compliant in the system as well.
Had the each occurrence or general aggregate limits been below the required amounts Jessica would have looked to the umbrella liability row to supplement the existing limits. However, that was not required here, so she can move on to the next section- automobile liability.
⏳ 1 Minute
While Jessica will implement a similar approach to checking automobile liability by comparing the evidenced limits to requirements, there are a few additional wrinkles. The primary one is categories of automobiles, with 5 boxes to check: Any Auto, Owned Autos Only, Hired Autos Only, Scheduled Autos, and Non-Owned Autos Only.
For this COI, Jessica has to check for a combined single limit of 1 million USD and all owned autos. Is it compliant?
The limit exceeds the requirement, but Jessica catches a gap- the policy only covers hired and non-owned autos, whereas all owned autos is required.
The property management team for our customer will see this highlighted gap and be given the option to waive the gap, accept the gap, or send gaps back to the vendor.
One edge case Jessica keeps her eye out for is auto coverage hiding in the General Liability section, like in the below example. In this case, she’d mark the GL policy number and expiration date in our internal auditor for the Auto Liability dates.
⏳ 3 Minutes
Jessica will check for each occurrence and aggregate limits that, as a standard in Jones, are used to supplement General Liability, Auto Liability, and Employer’s Liability limits. Umbrella Liability can occasionally supplement policies like Pollution, Professional, and Crime, for example, but only if it is explicitly stated in the COI. We consider these requirements met if the underlying policies contain the required provision and we find evidence that the umbrella follows form. Additionally, Umbrella Liability endorsements are rarely attached to COIs, so our team will use wording and checkboxes present on the COI to confirm coverage evidence.
For the following COI, Jessica is checking for occurrence basis and a 5 million USD limit in both aggregate and each occurrence. The each occurrence amount falls short of the limit, so Jessica marks a gap.
⏳ 2 Minutes
For Workers’ Compensation Jessica has to check more than just limits, ensuring if marked that the limits meets the Statutory Limit as indicated in the Per-Statute checkbox. Workers’ Compensation rules vary by state. In the following example, Jessica is facing a tricky case. She’s confirmed the limits meet the 1 million USD requirement, but what policy number should she use for this COI?
When checking for Workers’ Compensation with multiple policies our auditors will look at the policy that covers the state the work is being done in, not the registered address of the primary organization. In this case the work is being done in Illinois, so Jessica would list the second policy.
Jessica knows that Oregon, Ohio, North Dakota, Wyoming, and Washington are monopolistic states, which means they have different Worker’s Compensation rules. If she saw that a vendor was doing work in these, she would not mark gaps in any situation.
⏳ 30 Seconds
The last row on an ACORD 25 is a free text section and can be used to show any policy. Property Insurance is often evidenced there. When Jessica checks it she may also find evidence of extended coverages like Special Form (aka “All Risk”), Business Income, Plate Glass, Flood, Earthquake, and more. Every peril or coverage related to Property Insurance required in leases or insurance requirement agreements is tracked in the Jones addendum, making it easy for Jessica to look up these uncommon types of insurance. Additionally, Jessica will not mark gaps for Waiver of Subrogation for Property Insurance on any account, even when it appears in the lease. No such endorsement exists and the usual practice is to handle rights of recovery by the lease wording, not by an endorsement to the policy. The lease itself, as a binding contract containing a Waiver of Subrogation, fulfills this requirement when signed. This row is blank on the COI Jessica is auditing today, so she doesn’t have to mark gaps for any of these special requirements.
What About the Description of Operations and Endorsements?
Rather than checking the Description of Operations in its entirety at the end of the process, Jessica will constantly refer like a roadmap to it to evidence provisions of the policies as she audits the document like she did to find the Additional Insured.
Jessica will also check for verbiage indicating a Waiver of Subrogation, Primary and Noncontributory provision, or Notice of Cancellation, provided the Waiver of Subrogation is not indicated in the checkboxes for each policy like our example COI.
However, if the requirements specifically ask for an endorsement, Jessica will not be able to use the Description of Operations to evidence these provisions. Jones will only accept an attached page to the COI to suffice for the requirement. It can either be presented as an endorsement of its own or a built-in clause in another endorsement, but the Description of Operations will not suffice in this case. The COI we’re looking at today doesn’t require any endorsements, so Jessica has finished reviewing it.
Communicating Gaps to Customers
Now that Jessica is done reviewing the COI for compliance, the three gaps will now be conveyed to the customer via an email asking them to “Please Review COI Gaps.” The customer then has the option to log into Jones and review the gaps in our system as shown below. By pressing the “send gaps” button they’ll trigger an “Insurance Coverage Gap” email that will alert the vendor, tenant, or subcontractor to the coverage gap and request updated, compliant insurance information.
Comparing Our Review Standards to Competitors
Other companies who manage the collection and review of COIs unfortunately do not review documents with the same level of scrutiny as Jessica just did. In conversations with customers who transitioned from other COI management services we’ve seen instances where documents that were marked compliant by competitors were in fact non-compliant. One example of the discrepancy comes from a Form 58001 (1-15) we recently reviewed. While our competitor accepted this form for both Primary and Noncontributory, we flagged a gap as the policy clearly grants primary but contributory coverage.
Another example of the difference in auditing standards between us and our competitors can be seen on the following forms. Our customer reported that their prior vendor marked this document as compliant. However, the auditing teams at Jones caught a tiny detail that could’ve been costly for our customer: the Policy Number printed on the Waiver of Subrogation Endorsement for Worker’s Compensation did not match the WC policy number on the COI.
The attention to detail of auditors like Jessica could be the difference between coverage and no coverage being afforded in the event of a costly lawsuit.
Putting Jones Insurance Experts to Work for You
Bringing Jones on to manage the collection and review of your COIs takes the burden of COI review off your team and puts them in the hands of insurance professionals like Jessica, who can look through a COI like the one above and catch 3 gaps in under 12 minutes. When you entrust certificate of insurance review to Jones you can ensure you’re properly transferring risk away from your company and towards the vendors, tenants, and subcontractors you bring on. Stop taking unnecessary risks with your COIs, and start protecting your organization with help from Jones.