The National Association of Insurance Commissioners (NAIC) has, quite thoughtfully, organized a system for making the voices of consumers heard when it looks at the insurance market and considers regulatory changes.
The NAIC chooses representatives from groups that identify themselves as consumer advocacy groups and other groups to represent consumer interests in NAIC proceedings. The NAIC pays the expenses of consumer reps who need financial help with participating in the regulatory process. The NAIC lets consumer reps who do not need the funding, want to stay financially independent of regulators, or both, represent consumer interests without using NAIC funding.
Many of the consumer reps are energetic, intelligent people who do a great job of translating what the NAIC does and what's happening into the insurance market into plain English.
Some of the people who write and sell private long-term care insurance may disagree with the consumer reps rep, about some issues, but chances are many would email the reps immediately if their own parents ran into difficult LTCI customer service problems.
But, on the other hand: I always feel uncomfortable when referring to people as "consumer representatives," or their groups as "consumer advocacy groups," without adding a few hundred words of disclaimers.
On the one hand, consumer group representatives may generally be intelligent, well-informed, people who care deeply about consumers' interests, but, on the other hand, they also may be demographically different from U.S. consumers and policy claimants as a whole, and consumers themselves don't have say over who is classified as a consumer rep.
Consumers at least get a chance to vote on an insurance commissioner in some states. In other states, consumers get a chance to elect, or toss out, a governor who has the authority to appoint a commissioner.
Similarly, consumer reps sometimes seem to see themselves as people who guard consumers from unscrupulous insurance agents, but consumers have a direct ability to hire and fire insurance agents.
On the third hand, even if the NAIC replaced the current, application-based system for appointing consumer reps, and somehow gave consumers as a whole a chance to elect consumer reps, that would not necessarily lead to the selection of a new group of reps who were more representative of consumers' views. The kinds of people who have the time and resources to run for any kind of national position are not likely to be typical consumers.
The NAIC and the consumer groups themselves sometimes try to supplement the appointed consumer reps by commissioning consumer surveys. Right now, for example, the NAIC and consumer groups are use reactions from consumer focus groups to assess various approaches to formatting major medical plan Summaries of Benefits and Coverage (SBCs).
When the NAIC uses focus groups to seek consumers' opinions, that means it's organizing relatively small groups of consumers, having experts brief the consumers in a structured way, and then using a structured process to get the focus group participants' thoughts. The focus group approach is similar to another widely used approach for getting ordinary people's ideas: juries.
Maybe the NAIC should supplement the consumer rep system with a consumer jury system. Pick a group of 20 consumers every quarter, along with, say, 10 consumers per product line, such as LTCI, who have actually filed claims involving a policy in that line. Let interest groups, including the consumer reps, prepare briefing papers on major topics of interest. Then have the consumer jury members read the briefing papers and weigh in.
If consumer juries say more or less what the appointed consumer reps say, then everyone will know that the appointed consumer rep system is working.
If, in some cases, the consumer juries disagree with the appointed reps, then maybe everyone will get some useful new insights regarding what consumers are really thinking about LTCI and other insurance products.
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