The Florida Office of Insurance Regulation (OIR) is directing all insurers to review and update their business continuity and/or continuity of operations plans in light of the current outbreak of coronavirus strain COVID-19.
In a memorandum issued by OIR March 16, insurers are also asked to immediately notify OIR should they have to activate their business continuity and/or continuity operation plan in response to COVID-19.
OIR issued the memorandum to all insurers in the state and other entities it regulates and noted that the Centers for Disease Control and Prevention (CDC) and the Florida Department of Health (DOH) have issued guidance on how businesses can help prevent the spread of the virus by limiting public exposures, and said companies are “urged to heed this guidance.”
The memorandum applies to all insurance companies regulated by OIR. That does not include insurance agencies or brokers, which are regulated by the Florida Department of Financial Services.
“Understanding these measures may disrupt normal business operations, all companies regulated by OIR are directed to review and update their Business Continuity Plans and/or Continuity of Operation Plans immediately,” OIR said in the memorandum.
Insurer continuity plans must provide a framework for the continuation of company operations, including key insurance functions such as policy issuance, premium collection, claims adjustment and payment and policyholder service, OIR said. The continuity plans should also account for DOH and CDC guidance surrounding COVID-19, including executive orders issued at the state and national level.
Companies should consider all potential impacts of COVID-19 within their continuity plan, including impacts to essential operations, key personnel, supply chain, vendors, contractors and policyholders, OIR said.
In addition, companies are required to notify OIR in the event that their business continuity and/or continuity of operations plan is activated in response to COVID-19 within the same day the plan was activated.
“If in response to COVID-19, business operations are compromised to the extent that it jeopardizes the company’s ability to provide essential insurance services to policyholders, the company must immediately notify OIR, detailing the extent to which operations are compromised,” the memorandum further notes.
OIR said companies should contact Christopher Struk at Christopher.Struk@floir.com and Christina Huff at Christina.Huff@floir.com with the following information:
- Detailed information regarding the extent to which business operations are compromised, including information on how it may impact services to policyholders; and
- The name, phone number, and email address of the point of contact for this issue.
“Notice of the activation of a business continuity plan due to COVID-19 provides the OIR with a better understanding of market impacts and does not necessarily require any action on the part of OIR,” an OIR spokesperson said in a statement to Insurance Journal. “OIR is requesting this notification and point of contact so it can immediately work with insurers to avoid any disruption in consumer services in response to COVID-19.”
Florida-based insurer FedNat announced on Twitter, and OIR confirmed, that the insurer has implemented its business continuity and disaster recovery plan and now has most of its employees working from home. It has also suspended all non-essential corporate travel. While its operations remain open and at full capacity, the company said it encourages everyone to use its online self-serve portal for any policy needs or to track claims activity.
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