BILL ANALYSIS                                                                                                                                                                                                    






                        SENATE COMMITTEE ON BANKING, FINANCE,
                                    AND INSURANCE
                           Senator Ronald Calderon, Chair


          AB 483 (Buchanan)        Hearing Date:  June 17, 2009  

          As Amended: June 10, 2009
          Fiscal:             Yes
          Urgency:       No
          

           SUMMARY   Would require a workers' compensation rating  
          organization to establish and update an Internet web site  
          pursuant to regulations adopted by the Insurance Commissioner  
          (IC) for the purpose of allowing any person to determine whether  
          an employer is insured for workers' compensation, as specified;  
          would require the IC to adopt regulations to implement this  
          provision by January 1, 2011, including a method by which an  
          employer may dispute the accuracy of the information displayed  
          on the Web site; would require the Web site to be updated to  
          reflect policy information as soon as reasonably feasible, as  
          prescribed by the IC; and would require the Web site to be  
          operational no later than 180 days after the effective date of  
          regulations adopted by the IC.

           
          DIGEST
           
           Existing law
            
           1.  Requires employers to secure the payment of workers'  
              compensation, including medical treatment, for injuries arising  
              out of, or in the course of, employment;

           2.  Allows a private employer to obtain a certificate to  
              self-insure for payment of workers' compensation by meeting  
              specified requirements and filing with the Director of  
              Industrial Relations;

           3.  Declares that the actions of employers who fraudulently fail to  
              secure the payment of workers' compensation as required by law  
              harms employees, causes unfair competition for honest employers,  
              and increases costs to taxpayers; 

           4.  Requires a rating organization, as defined, to maintain records  




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              related to losses reported by member insurance companies about  
              policyholder losses, data, statistics, or other information in a  
              manner prescribed by the Insurance Commissioner (IC);  

           5.  Requires every insurer to be a member of a rating organization;

           6.  Authorizes the IC to promulgate reasonable rules and  
              statistical plans to be used by insurers to record and report  
              their loss and expense experience;

           7.  Specifies that the IC shall designate a rating organization to  
              act as his/her statistical agent to gather and compile  
              experience statistics for all insurers in the state;

           8.  Requires the rating organization designated by the IC to serve  
              as the DOI's statistical agent, the Workers Compensation  
              Insurance Rating Bureau (WCIRB), to provide to the DIR, upon  
              request, any information in its possession or reasonably  
              attainable that would assist the DIR in identifying employers  
              who fail to secure adequate workers' compensation insurance; 

           9.  Directs the Division of Labor Standards Enforcement (DLSE) to  
              utilize data from the Uninsured Employers Benefits Trust Fund,  
              the Employment Development Department (EDD), the rating  
              organization designated by the IC, and any other sources, to  
              identify uninsured employers and contact them, and if no valid  
              reason for lack of insurance is provided, inspect them on a  
              priority basis;

           10. Requires the WCIRB to provide to the DIR, upon request, any  
              information in its possession or reasonably attainable that  
              would assist the DIR in identifying employers who fail to secure  
              adequate workers' comp insurance.
           
          This bill

            1.  Would require a licensed rating organization, pursuant to  
              regulations adopted by the IC after hearing and notice, to  
              establish and maintain an Internet Web site for the purpose  
              of allowing any person to determine whether an employer is  
              insured for workers' compensation;

           2.  Would require the IC to adopt regulations to implement this  
              section by January 1, 2011, and include a method by which an  
              employer may dispute the accuracy of the information  
              displayed on the Web site;




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           3.  Would require the Web site to be operational no later than  
              180 days after the effective date of regulations adopted by  
              the IC, and to do the following:

               a.     Permit a query for coverage information on an  
                 employer using the employer's name, address, or other  
                 identifying information as may be provided by regulations  
                 adopted by the IC;

               b.     Provide the name of the workers' compensation  
                 insurer or insurers for the employer on the date of the  
                 query according to the most recent data available to the  
                 rating organization, and provide a contact address for  
                 the insurer or a link to the insurer's information on the  
                 DOI Web site;

               c.     Be accessible for inquiries without charge;

               d.     Contain a hypertext link to the Department of  
                 Industrial Relations' web site for the purpose of  
                 locating employers who may be self-insured;

               e.     Include any disclaimers the IC may prescribe;

               f.     Be updated to reflect policy information as soon as  
                 reasonably feasible, as prescribed by the IC;

           4.  Would specify that the rating organization would not be  
              required to disclose any confidential information, as  
              confidential is defined by the IC;

           5.  Would specify that the rating organization, its members,  
              and employees, when acting within the scope of employment,  
              could not be held liable for injury or damages caused, or  
              alleged to have been caused, directly, or indirectly, by the  
              disclosure of information pursuant to this section, or for  
              the accuracy or completeness of any information disclosed,  
              as specified;

           6.  Would not limit any authority a rating organization would  
              otherwise have to disclose information contained in its  
              records to others;

           7.  Would specify that this provision shall not be construed to  
              create liability except as provided, nor as a legislative  




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              recognition that, except for the enactment of this section,  
              a liability would exist.

           COMMENTS

          1.  Purpose of the bill  To increase access to workers'  
              compensation data, and specifically the insurance status of  
              employers, by making this information easily accessible via  
              the Internet.

           2.  Background  .  This bill was heard in this Committee in two prior  
              years. AB 483 places responsibility on the IC to adopt  
              regulations governing the Web site's operations prior to  
              implementation, including regulations to ensure accurate  
              employer identification, and a system for employers to challenge  
              inaccurate information.  The bill requires the IC to adopt  
              regulations prior to the Web site becoming effective, but no  
              later than January 1, 2011, and provide a 180 day time period  
              following enactment of regulations for the Web site to become  
              operational.  It requires the Web site to be updated as  
              reasonably feasible, as defined by the IC, rather than daily,  
              reflecting practical operational concerns.  

          3.  In an effort to meet the objection of the Governor in the  
              veto of last year's AB 507 which was identical to this bill  
              as introduced, AB 483 has been amended to add a requirement  
              that the website include the date that the site was last  
              updated.  The latest amendments to AB 483 appear to be a  
              reasonable attempt to institute a commercially feasible  
              method for putting the public users of the site on notice  
              concerning the date of its most recent update while striking  
              a balance that will keep site administration costs and  
              burdens within reasonable bounds.

          4.  At present, California has one rating organization, a  
              nonprofit located in San Francisco, the WCIRB.  The WCIRB is  
              the designated workers' compensation statistical agent for  
              the state.  In 2008, the WCIRB informed this committee that  
              it receives information about loss histories and insurance  
              status from insurance companies and employers on a routine  
              basis.  The WCIRB receives policy information, both  
              electronically and in paper format, from insurers and enters  
              the policy information in its statewide database.  According  
              to the WCIRB, insurers, by regulation, have up to 60 days  
              from a policy's inception date to report the policy to the  
              WCIRB.    




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              According to the WCIRB, there are instances where coverage may  
              be in effect, but because the insurer in the normal course of  
              business may not have reported it to the WCIRB yet, or the WCIRB  
              has not yet reviewed and accepted the policy, it may not be  
              available for posting to the Web site. Once the WCIRB receives  
              and processes the policy information, it has the capacity to  
              post that information to a Web site within one business day.   
              The database maintained by the WCIRB relies on insurers to  
              provide accurate information.  In addition, the information  
              supplied by the WCIRB in 2008 indicated that the insurance  
              policy can be entered under up to 25 named insured entities  
              (employers) but only one address.

              Currently, to obtain information from the WCIRB about an  
              employer's insurance coverage, one must be a party to a workers'  
              compensation claim, submit a request in writing or by email and  
              pay an $8 fee, and wait for a written response.  This can take  
              up to 30 days.

              Self-insured employers are already publicly disclosed on the web  
              site of the Office of Self Insured Plans within the Department  
              of industrial Relations.  Some businesses, however, may not  
              appear on the WCRIB or self-insured employer databases for  
              legitimate and legal reasons, such as a sole proprietorship, or  
              a business that has gone out of business or had no payroll.   
              Information provided by the author indicates that Florida and  
              Mississippi provide public access to verify coverage on their  
              web sites, and a number of other states are taking steps in this  
              direction.


           5.  Support  .  According to the author, public access to workers'  
              compensation data protects employers from broker fraud, protects  
              workers from employers without workers' compensation coverage,  
              and protects insured employers from competitive disadvantages  
              from uninsured employers.  Additionally, taxpayers save money by  
              reducing the need of injured workers to use other public  
              programs.
               
               The California Labor Federation supports AB 483 because creation  
              of a searchable database would allow employees to identify their  
              employer's insurance company and enable them to file an injury  
              claim directly with the insurer.  It also would allow a  
              prospective employee to confirm that an employer has coverage  
              before accepting a position.  Medical providers could use the  




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              database to identify the insurance company of an employer and  
              know where to send their bills for payment.  According to the  
              Labor Federation, more than 20 states have online proof of  
              workers' compensation coverage databases in use.


           6.  Opposition    None Received

           
          7.  Questions   None


           8.  Suggested Amendments  None

           
          9.  Prior Legislation  In 2005-2006, AB 1883 (De La Torre) was  
              approved and vetoed by the Governor.  In 2008, AB 507 (De La  
              Torre) was drafted to address the concerns in the Governor's  
              veto message for AB 1883. In 2008, notwithstanding terming  
              it a "laudable goal", the Governor vetoed AB 507

           10. Veto Messages  After offering extensive criticisms of the  
              2006 bill, in 2008 the veto message affirmed the value of  
              the proposed website but expressed concern over the  
              potential that persons accessing the site could not obtain  
              policy effective dates nor information regarding when the  
              data on the site was updated.  The latest amendments to AB  
              483 are an attempt to find a commercially reasonable method  
              for putting the public users of the site on notice  
              concerning the date of its most recent update while striking  
              a balance that will keep site administration costs and  
              burdens within reasonable bounds.

           Veto of AB 1883 of 2006
           
          I am returning Assembly Bill 1883 without my signature.

          This measure would require a workers compensation insurance  
          proof-of-coverage website be established by an independent  
          rating organization.  Though I do not question the importance of  
          ensuring public access to information on workers compensation  
          coverage, I am concerned that this bill, as written, will have  
          little positive effect on the fight against workers compensation  
          fraud and could actually generate more confusion than good.

          The parties most likely to use this new website already have  




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          sufficient access to information on workers compensation  
          coverage. For instance, enforcement agencies already have direct  
          access to the rating organizations records and individuals have  
          the ability to check for workers compensation insurance through  
          the rating organization or the Department of Insurance. 

          Unfortunately, this bill has too many gaps to merit signing.   
          For instance, the website would not address the numerous  
          employers that are self-insured or covered through a joint  
          powers authority.  In addition, many employers, such as some  
          family businesses, are legally exempt from the requirement to  
          obtain coverage.  This bill would give the public the  
          misperception that these employers are violating the law.   
          Furthermore, due to the inherent delays in processing payments  
          for compensation insurance and recording the data, the online  
          website could fail to provide the most accurate indicator of  
          whether an employer has purchased compensation.

          California employers already pay assessments of over $30 million  
          annually to fight workers compensation fraud.  This bill would  
          increase those costs for a program that, as proposed, would do  
          little to deter fraud.  I will work with the Legislature to look  
          at how the recent reforms have impacted non-compliance,  
          determine how best to target those employers committing fraud,  
          and then develop programs that do not force additional costs on  
          law-abiding employers.


           Veto of AB 507 of 2008
           
           I am returning Assembly Bill 507 without my signature.

          This bill would establish an Internet website to enable any  
          person to identify whether or not an employer is insured for  
          workers' compensation.  This is a laudable goal.  However, I am  
          concerned that the website would not be required to post the  
          effective dates of coverage of a policy, thereby significantly  
          diminishing the value of the information.  More importantly, the  
          bill does not contain any specified timing in which the  
          information must be updated, potentially leading to inaccurate  
          information on the website.

          For these reasons, I am returning this bill without my  
          signature.






                                                         AB 483, Page 8




           

          POSITIONS
          
          Support
           
          California Labor Federation (Sponsor)
          AFSCME - AFL-CIO
          California Applicant Attorneys' Association
          California Conference Board of the Amalgamated Transit Union
          California Conference of Machinists
          California Federation of Teachers
          California Nurses Association
          California Professional Firefighters
          California School Employees Association
          California Teamsters Public Affairs Council
          Department of Insurance
          Engineers and Scientists of California
          Insurance Brokers and Agents of the West 
          Professional and Technical Engineers, Local 21
          State Building and Construction Trades Council
          Strategic Committee of Public Employees, Laborer's International  
          Union of North America
          United Food and Commercial Workers Union, Western States Council
          United Transportation Union, California State Legislative Board
          UNITE HERE
           
          Oppose
               
          None Received

          Consultant:   Kenneth Cooley (916) 651-4102